IR 05000530/1987006
| ML20207T160 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/05/1987 |
| From: | Richards S, Sorensen R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20207T151 | List: |
| References | |
| 50-530-87-06, 50-530-87-6, NUDOCS 8703230268 | |
| Download: ML20207T160 (10) | |
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s U. S. NUCLEAR REGULATORY COMMISSION
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Report No.
-50-530/87-06'
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Docket No.
50-530 i.
Construction
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Permit No.'
CPPR-143-
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Licensee:
Arizona Nuclear Power Project P. O. Box.52034
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Phoenix, Arizona 85072-2034
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Facility Name:.Palo Verde Nuclear Generating Station - Unit 3 Inspection at: Palo Verde Site, Wintersburg, Arizona
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Inspection Conducted:
ebr ary 2-20, 1987
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RfA(ofD Inspector:
taf E ' Sorer'sen, te' actor Inspector Datd Sitjned Approved by:
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S. A. Richards, Chief Datd Sfgned'
Engineering Section Summary:
. Inspection on February 2-20, 1987 (Report.No. 50-530/87-06)
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Areas Inspected:
Unannounced inspection by a regional based inspector of
-QA/QC Administration, Audits, Records, Special_ Tests and Experiments, Surveillance _and Calibration Control, Maintenance, Safety Committee Activity,
'50.55(e) Rep' orts, Document Control, and Temporary Modification Control.
The-inspection covered Unit 3.
'NRC' Inspection-Procedures 30703, 92700, 40301B, 35740B, 357418, 357428, 35743, 357448, 35745B, 357488, and 357498 were covered during this inspection.
Results:
Of the areas inspected, no violations or deviations were identified.
However, two items were identified that are unresolved.
8703230268 870306 PDR ADOCK 05000530
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DETAILS 1.
Persons Contacted Arizona Nuclear Power Project (ANPP)
- E. E. Van Brunt, Jr., Executive Vice President
- W. E. Ide, Director, Corporate QA/QC
- J. Bynum, PVNGS Plant Manager
- J. Vorees, Manager, Nuclear Safety
- T. Shriver, Compliance Manager
- 0. Zeringue, Technical Support' Manager J. Allen, Operations Manager
+*C. Russo, Manager, Quality Audits and Monitoring V. Rhodes, ABRM Supervisor D. Holmes, NPRM Supervisor
+*R. Baron, Compliance Supervisor S. Penick, Quality Engineering Supervisor D. Stover, Supervisor, Nuclear Safety Group
- Attended the exit 1 meeting of February 12, 1987.
+ Participated in telephone conversation of February 23, 1987.
The inspector also talked with numerous other licensee and contractor personnel during the course of the inspection.
2.
QA/QC Administration The inspector reviewed the administration of the licensee's QA program for the operations phase. This included interviewing cognizant licensee QA supervisory personnel and briefly reviewing applicable procedures.
The procedures and documents which defined the scope of the QA program were:
a.
7N414.03.00 Quality Classification for Structures, Systems, Components, Spare Parts and Activities; b.
Operations Quality Assurance Criteria Manual; c.
FSAR Chapter 17.2; and d.
FSAR Table 3.2-1.
Various other policies, procedures and department instructions govern the activities of the QA organization.
Procedure 1N.001.01.00 established the methods used to review, approve, and delete these various policies procedures and department instructions.
The QA organization compiled a monthly QA/QC status report and a semi-annual Quality Assurance effectiveness report.
Both reports were distributed to ANPP management.
The monthly report was used by ANPP
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overall quality. The semi-annual report evaluated the effectiveness of
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the licensee's QA program.
The inspector reviewed recent examples of
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both of these reports.
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-Finally, the licensee trended deficiencies using ANPP procedure
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6N417.14.00.
Currently, trend reports are, issued quarterly, and are compiled from various input sources such as LERs, nonconfornance reports (NCRs), corrective action requests (CARS), 50.55(e)s, etc.
This report was also distributed to various ANPP management personnel to make them aware of trends and elicit appropriate action as necessary.
The inspector reviewed the trend report for the third quarter of 1986 and also noted management response to it.
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No violations or deviations were identified.
3.
Audits The inspector reviewed the licensee's quality audit program and the implementation of it.
The inspector reviewed procedure 6N417.13.00, Quality Auditing, in order to develop an understanding of how auditing is controlled.
The licensee Quality Audits organization used " scoping matrices" to implement the various audits required by the Technical Specifications.
There were 35 different scoping matrices.
Each matrix described certain areas to be audited and included such things as audit scope, organizations to be audited, what Technical Specification requirements which are to be met, implementing procedures, etc.
Typical topics covered by the scoping matrices were:
Fire protection, document control, plant. chemistry, test control, and others.
The inspector reviewed two recently completed audit packages, one on document control and the other on fire protection.
Audit checklists were prepared and used.
The auditors were either members of the licensee's QA organization, the Nuclear Safety Group, or other organizations independent of the organization being audited.
The inspector observed evidence of deficiencies being identified, and CARS being generated and carried as open items to satisfactory resolution.
The inspector also reviewed the applicable CARS generated as a result of these two audits and noted that they were answered in writing by the responsible organization.
Finally, the audit reports were distributed to the highest levels of ANPP management and to t he management of the audited organization, in accordance with procedure.
No violations or deviations were identified.
4.
Records The inspector examined the provisions the licensee has put in place to maintain records required to be maintained by the Technical Specifications.
The inspector also verified that record storage controls have been established and were being followed and that retention period controls were establishe _ _ _ - - _ _ _ _ _ -__ - ____
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'i-The procedures that control the retention and storage of records were:
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9N219.05.00 - Document / Record Turnover Control b.
78AC-0ZZ07 - Document / Record Vault Storage and. Maintenance c.
9N219.04.00 - Final Disposition of Hard Copy Documents
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Interviews were conducted with cognizant licensee personnel to assess their knowledge of these procedures and to gain an additional understanding of the licensee's records retention program.
Completed records to be maintained were. turned over from the originating organization.to Nuclear Projects Records Management (NPRM), where they were microfilmed and indexed into the Records Management Computer System (RMCS).
The RMCS allowed ready access to an index of all records that were being stored.
Microfilm was stored in the Drawing and Document Control (DDC) vault for the life of z the plant.
Temperature and humidity in the vault were maintained in accordance with applicable ANSI standards
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and were recorded continuously...These temperature and humidity records were retained for one year and were verified by the inspector.
After microfilming, original records were destroyed on the authority of the NPRM manager.. Records that are unfilmable were kept in folders on shelves in the vault.
The inspector randomly selected a sample of 10 different kinds of records to determine if they were properly stored.
All records that were turned over to NPRM were retrieved.
No violations or deviations were identified.
5.
Special Tests and Experiments
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The inspector interviewed key personnel, and reviewed the applicable procedure to ensure that the licensee has established a program for handling special tests and experiments.
The governing procedure was 70AC-0ZZ19 - Special Test and Experiments, which described the review and approval cycle for special tests.
This cycle included a Plant Review Board (PRB) review and Plant Manager approval.
If unreviewed safety questions were identified, procedure 7N407.03.00, Handling of Unreviewed Safety Questions, provided guidance for disposition including review by the Nuclear Safety Group (NSG) and submittal to NRC for approval.
Procedure 79AC-9ZZ07, Nuclear Safety Review and Evaluation, required a written 50.59 evaluation be conducted for special tests and that they be included into the annual 50.59 report.
The inspector briefly interviewed the Operations Manager and the Technical Support Manager to assess their familiarity with these requirements.
They each had a general understanding of them.
However, per the licensee personnel interviewed, the procedure for special tests and experiments has yet to be invoked, therefore, implementation of it could not be verified.
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No violations or deviations were identified.
6.
Surveillance and Calibration Control The inspector selected five plant instruments in Unit 3, not specifically-required to be calibrated by the Technical Specifications, but which are required to verify the operability of certain Technical Specification required components.
Instruments chosen included safety injection tank level and pressure, high pressure safety injection flow, low pressure safety injection flow, atmospheric dump valve N accumulator pressure.
All calibrations were scheduled on a master schedule contained in the Site Information Management System (SIMS) computer.
Calibration procedures have been written for the instruments selected and were stored in the SIMS computer and used repetitively after each calibration interval.
Calibration and periodic testing intervals were based on the
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following:
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Type of Instrument b.
Stability and Reliability Characteristics c.
Required Accuracies d.
ALARA Since the calibration program was just being initiated in Unit 3, the inspector also chose a sample of instrumentation to review in Unit 1, to further evaluate program adequacy.
The program was well-establishr:d in Unit 1 and identical to Unit 3.
No deficiencies were identified.
All instruments selected were contained on the master schedule, and were previously calibrated per preventive maintenance work order.
The inspector noted several examples in Unit 1 of trending of instrument calibration characteristics, and calibration frequencies were accelerated due to continued instrument drift.
Also, concerning cont'.rol of surveillance testing, the inspector selected a random sample of approximately 25 surveillance requirements from the Unit 3 Proof and Review Technical Specifications.
These requirements were then compared with procedure 73AC-3ZZ24, Technical Specification Surveillance Requirements Cross Reference - Unit 3.
This procedure listed individual surveillance requirements, the procedure that performs it, the frequency it is to be performed, the operational modes the surveillance requirement applies to, and which licensee organization performs it.
All surveillance requirements that the inspector randomly chose were accounted for in the Cross Reference.
This Cross Reference was then used to help schedule surveillance tests, based on when initial surveillance tests to meet Technical Specification reouirements were actually completed.
This is the same program that existed in Units 1 and 2 and, for the most part, have been successfully implemented.
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No violations or deviations were identified.
7.
Maintenance The inspector reviewed a representative sampling of 13 work orders (W0)
that documented routine maintenance activities.
The W0s were chosen from the mechanical, electrical, and I&C areas, and reviewed to ensure proper controls, as applicable, were included.
Items reviewed included:
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Personnel involved were identified b.
Measurement and test equipment (M&TE) used was identified c.
Appropriate procedures were prepared d.
Proper review and approval were accomplished e.
Any replacement parts were identified f.
Appropriate cleanliness was maintained g.
Corrective action was documented h.
QC hold points were incorporated, as applicable.
Other attributes of work orders were evaluated also.
The inspector also chose a random sample.of routine preventive maintenance activities to ensure that they were performed and documented.
Finally, the licensee's-program for maintaining the qualifications of personnel involved in special processes was reviewed.
This included persons involved in nondestructive examination (NDE) and special welding processes.
The inspector interviewed a welding technician, whose only function was to maintain these qualifications current, and an NDE technician.
There were four persons qualified at Palo Verde to perform NDE and their qualifications were current.
Approximately eight ANPP persons were qualified welders and their files appeared to be current.
Also, qualification files were maintained for temporary contractors involved in welding processes.
No violations or deviations were identified.
8.
Safety Committee Activity The Nuclear Safety Group (NSG) is the ANPP offsite safety review committee and the Plant Review Board (PRB) is the ANPP onsite safety review committee.
The requirements for the two ANPP safety committees are established in Sections 6.5 and 6.8 of the Technical Specifications and were implemented by the licensee in the following procedures:
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7P405.00.00 - Safety Review Group Policy
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7N405.01.00 - Nuclear Safety Group (NSG)
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7N405.04.00 - Plant Review Board (PRB)
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7N405.03.00 - Nuclear Safety Department iL, e.
70AC-0ZZ06 - Plant Review Board The inspector interviewed the NSG supervisor and the Nuclear' Safety Manager and assessed their knowledge of these procedures, as applicable, and also discussed the experience and qualifications of the NSG l
supervisor and the five NSG members.
Per the licensee representatives interviewed, these are the same pers'nnel as when the NSG was last o
inspected prior to licensing Unit 2,'where their qualifications were evaluated to be adequate.'.NSG conducted ongoing activities but met monthly to discuss various NSG review and audit activities.. A monthly report was generated of reviews ~ conducted and~ distributed;to the Vice President Nuclear Production, the Plant Manager, and the management of the departments reviewed. Methods for. followup action by NSG to identified deficiencies have also been' established.
The inspector reviewed a monthly NSG report to further assess their activities.
Per discussion with the NSG supervisor, NSG maintains cognizance of audits required by the Technical Specifications by assisting QA in planning the audit, providing audit team members, and reviewing all QA audits after completion.
PRB responsibilities are defined in Section 6.5 of the Technical Specifications.
ANPP procedures 7N405.04.00 and 70AC-0ZZ06 implemented these responsibility requirements and also implemented the requirements concerning PRB composition, quorum, alternate members, meeting frequency, and meeting minutes.
The inspector reviewed PRB meeting minutes from the last three months (six meetings).
Based on this review, the PRB appeared to be fulfilling their functions required by the Technical Specifications.
No violations or deviations were identified.
9.
Followup of 50.55(e) Reports (0 pen) DER 87-01 Brown-Boveri Breaker Racking Gear Problems This report documented the licensee's investigation and evaluation of a problem with the racking gear on Brown-Boveri circuit breakers.
It involved a potential condition where control wire harnesses in the breaker could come in contact with the breaker racking gear.
The gear teeth could damage the wires, with the resultant loss of some control and indicating functions of the breaker.
The final report states that only minor damage was found to the wire harnesses in all three units at Palo Verde, but not enough to require replacement.
The inspector examined the condition of wire harnesses in two representative breakers and observed no detectable damage.
However, the licensee has elected to instali gear guards in all applicable breakers in
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all three units as a preventive measure.
No gear guards had been installed in Unit 1 as of the time of this inspection.
All but four had been installed in Unit 2 and six had been installed in Unit 3.
This 50.55(e) report will remain open until gear guard installation has been completed.
10.
Document Control The inspector selected a representative sample of drawings, procedures, and technical manuals, and compared the revisions to these documents in the field to the current revisions contained in the master copies retained by DDC.
Specific areas in Unit 3 where documents were examined included the Control Room, the Work Control Center, the I&C shop and the maintenance shop.
This inspection also included verification that applicable drawing change notices (DCNs), procedure change notices (PCNs), and supplier document change notices (SDCNs) were incorporated, as applicable.
A relatively small sample of each type of document was reviewed.
Both controlled-by-user copies and controlled copies were reviewed, where applicable.
The drawings appeared to the inspector to be updated satisfactorily in all areas where the stick files and aperture cards were kept.
The inspector noted that the drawings used in the Control Room for system status were in the process of being changed from the design drawings to the as-built drawings.
In addition, procedures, including working copies in the control room, were being updated properly, with one exception, which was corrected and appeared to be an isolated case based on the sample reviewed.
However, numerous problems were found with the control of Technical Manuals, both controlled copies in the Control Room and controlled-by-user copies in the maintenance areas. _ Deficiencies were found such as, wrong revisions, SDCNs missing, SDCNs included which should have been removed, and portions of Technical Manuals missing.
The deficiencies in the controlled copies had been identified and documented by a scheduled DDC audit the day before the inspector identified them.
However, the deficiencies in the controlled-by-user Technical Manuals had apparently not been identified previously.
Procedure 78AC-0ZZO3, Dechtel-Generated Technical / Instruction Manual Control and Distribution, indicated that for controlled-by-user documents, 00C provides revisions to the user, and it is the responsibility of the user to update documents in their custody.
This apparently was not being consistently done.
The inspector informed the licensee that it is imperative that personnel using Technical Manuals to do maintenance work on safety-related equipment and components do that work in accordance with the latest revision to the Technical Manual. The above procedure also indicated that the user of a controlled-by-user document is responsible for verifying the current revision of the document against a DDC controlled copy.
Although the inspector did not identify any instances where this was not being done, no attempt was made to do so due to time constraints on the
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Therefore', this matter remains unresolved.
(Unresolved item
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87-06-01).
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11. Temporary Modification Control The inspector reviewed the licensee's program for controlling temporary modifications (T mods).
The governing procedure was 73AC-9ZZ05, Temporary Modification Control.
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procedure, three T-mods were selected in Unit 3 (only six were active at the time.in Unit 3) to review and verify that what actually existed in the unit was accurately reflected in the T-mod documentation.
The three T-mods chosen were:
3-85-FP-005 in the fire protection control system, 3-86-PE-018 in the diesel generator control system, and 3-87-FH-007 in the fuel handling crane control system. The first two T-mods were found to be satisfactory.
3-87-FH-007 was found to be unsatisfactory in that ten jumpers and T-mod tags were indicated as being installed on the T-mod documentation, however, only nine jumpers and T-mod ttgs were found installed.
Subsequent followup into this matter revealed that T-mods were actually installed in accordance with a procedure described in a work order.
Apparently, the implementing work order had initially installed jumpers in the wrong places.
When a jumper was removed per a work order revision, to be reinstalled in a different location, this removal was not reflected on the T-mod status sheet.
Procedure 73AC-9ZZ05 clearly indicated that restoration shall be indicated by the restorer signing and dating the appropriate blocks of the T-mod status sheet with an independent verifier.
The inspector could not determine if this was an isolated occurrence, or a more pervasive problem, due to time constraints.
In a subsequent telephone conversation on February 23, 1987, licensee QA and compliance management presented to the inspector additional information concerning quality monitoring of T-mods.
They stated that approximately one-third of the 147 T-mods that currently exist in Units 1 and 2 have been reviewed by QA, since the T-mod program was changed nine months ago, and no other deficiencies of this kind have been identified.
Therefore, this matter remains unresolved.
(Unresolved Item 87-06-02).
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Unresolved Items Unresolved items are those items identified during an inspection for which further inspection will be required to determine whether a violation of a requirement occurred.
Sufficient information was not available during the inspection to make this determination.
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Exit Meeting The inspector met with the licensee management representatives indicated in Paragraph 1 on February 12, 1987.
The scope of the inspection and the inspector s findings, as noted in this report were discussed.
Also, the inspectorspokewiththelicenseerepresentatIvesindicatedinParagraph
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l'in a telephone conversation on February 23, 1987,.to receive and assess-
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.further information provided by the licensee concerning temporary modifications.
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