ML17298B718
| ML17298B718 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/29/1984 |
| From: | Hollenbach D, Kellund G, Miller L, Narbut P, Sorensen R, Wagner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17150A251 | List: |
| References | |
| RTR-NUREG-0578, RTR-NUREG-0660, RTR-NUREG-0737, RTR-NUREG-578, RTR-NUREG-660, RTR-NUREG-737, TASK-1.A.2.1, TASK-1.B.1.2, TASK-1.C.5, TASK-1.C.6, TASK-2.K.1, TASK-TM 50-528-84-47, 50-529-84-36, 50-530-84-25, IEB-79-06B, IEB-79-6B, NUDOCS 8412270397 | |
| Download: ML17298B718 (36) | |
See also: IR 05000528/1984047
Text
U.
S.
NUCLEAR REGULATORY COHHISSION
REGION V,
Report Nos.
50-528/84-47,
50-529/84-36
and 50-530/84-25
Docket Nos.
50-528,
50-529
and 50-530
Iicense Nos.
CPPR-141,
142 and
143
Licensee:
Arizona Public Service
Company
P.
O. Box 21666
Phoenix,
85036
Facility Name:
Palo Verde Nuclear Generating Station - Units 1,
2 and
3
Inspection at:
Palo Verde Construction Site, Wintersburg, Arizona
Inspection conducted:
Octob
15 - November 2,
1984
Inspectors:
R.
C.
o
s n,
Rea tor Inspector
. J.
Wagner,
Reactor
nspect
Dat
Si ned
ad
Da
e
S gn
D. Holle bach,
eactor
Sp
P.
P. Narb
, Reactor Inspector
D
e
igned
li Z36
Date Signed
Approved by:
G.
e
und,
Reac or Inspector
T3PQ ~
L. F. Hiller, Jr., Chief
Reactor Projects
Section
2
Dat
S gned
li zg
Date Signed
~Summar
Ins ection on October
15 - November
2
1984
(Re ort Nos. 50-528/84-47,
50-529/84-36
and 50-530/84-25
R
of IE Circulars, 50.55(e) items, previously identified open items,
and
implementation of Three Hile Island Lessons
Learned actions in Unit 1, with
some examinations
carried over into Units
2 and 3.
The inspection involved
303 inspector-hours
onsite by five NRC inspectors.
Results:
One Severity Level IV violation of NRC requirements
was identified,
concerning
improper welding of pipe supports in the Auxiliary Feedwater
System
(paragraph 2.f).
8412270397
84i205
)
ADOCK 05000528
g
C
I'
DETAILS
1.
Persons
Contacted
a
~
Arizona Public Service
Com an
(APS)
"W
""C.
"R
d T
'B
~T
J J
F.
P.
B.
J.
R.
J.
G.
R.
J.
S.
J.
Quinn, Licensing Manager
Souza, Assistant Corporate
QA/QC Manager
Russo,
Manager, Quality Audits 8 Monitoring
Hamilton, Quality Monitoring Supervisor
Green,
Supervisor of Training Support
Adney, Plant Superintendent,
Unit 2
Bloom, Licensing Engineer
Smith,
Compliance Engineer
Hicks, Training Manager
Wiley, Licensed Training Supervisor
Rudolph, Sr. Simulator Instructor
Allen, Operations
Manager
Bernier, Operations
Support Supervisor
Minnicks, DC Superintendent
Olson, Electrical Superintendent
Meyer, Fire Protection Supervisor
Stoudt, Mechanical Superintendent
Pennick,
QA/QC Engineer
Sherrin,
QA/QC Engineer
b.
Bechtel Power Cor oration (Bechtel)
-D. Hawkinson, Project
QA Manager
'"W. Stubblefield, Field Construction
Manager
"P. Huber, Project Quality Coordinator
"=A. Foster, Quality Control Manager
D. Freeland,
Engineering
Group'Supervisor'.
Guire,
QA Manager
>'Denotes
those persons
attending Exit Meeting, November 2,
1984.
The inspectors
also talked with other licensee
and contractor personnel
during the course of the inspection.
2.
Licensee Action on 10 CFR 50 '5(e) Construction Deficiencies
(DERs)
The following potential 50.55(e)
items were reviewed by the inspectors
for reportability and to determine
the thoroughness
of the licensee's
corrective action.
The items marked with an asterisk (-) were judged by
the licensee
to be reportable
under the
10 CFR 50.55(e) criteria; the
others
were considered
not reportable.
a
~
(Closed) Defects Discovered in Stainless
Steel Pi e
S ools (Licensee
DER No. 78-03
),
0
The licensee
informed the
NRC on September
27,
1978, that
deficiencies
might exist in certain stainless
steel pipe spools
delivered to the jobsite.
The pipe spools
were fabricated by
Pullman Power Products
from material supplied by Youngstown Welding
and Engineering
Company.
The corrective action called for a
100
percent ultrasonic examination to be performed
on all the Youngstown
material manufactured for the licensee.
These inspections
revealed
defective material that resulted in the rejection of 44 out of 103
pipe spools,
and
1 out of 4 pipe supports.
The inspector
reviewed documentation that revealed that these
examinations
were performed
on all Youngstown material,
under
observation
by Bechtel Quality Assurance
and Quality Control
personnel.
The inspector also verified accountability of all
Youngstown material received.
All the material had been identified,
located,
and all rejectable material shipped to Pullman for repair
or replacement.
The 45 rejectable
items were identified on Bechtel
Shipping Notice 3280 and 3519.
The corrective actions
taken by the licensee provide assurance
that
all items manufactured
by Pullman containing Youngstown material
conforms to ASME Code and specification requirements.
This item is
closed.
I
I
l
(Closed) Incorrectl
Installed
Han er Su
ort Assembl
(Iicensee
DER
No. 84-33
This it'em was initially reported to the
NRC by" the licensee
as
a
potential
reportable deficiency but was subsequently
determined
by the licensee
to be not reportable.
The licensee
based
this conclusion
on engineering calculation analysis
13-MC-SI-503R
which provided justification that the nonconforming pipe support
would not degrade
the structural integrity of the pipe support if
left uncorrected.
Nonconformance
Report
(NCR) No. PA-8390 was
dispositioned
to "use-as-is".
Subsequently,
a new NCR No. PA-8630
was initiated and dispositioned to add the weld in order to preclude
any possible
concern regarding addition of possible future loads to
the support.
Both of these
NCR's are closed.
The inspector also
reviewed documentation indicating that training sessions
were
conducted to give Quality Control Engineers
specialized -training on
inspection techniques.
A weld between
a Hanger Support, Assembly and the base plate
was
accepted
by two different Quality Control Engineers
(QCEs)
even
though the weld was missing.
The inspector
asked the second
QCE who
inspected
the weld how he missed it.
The
QCE thinks this particular
weld was covered by a wood plank and scaffolding making it
inaccessible
at the time of his inspection.
The licensee
examined
a sample of both QCE's work.
For one
individual, no deficiencies
were identified.
For the second person,
a single undersized
weld was identified which was dispositioned
"Use-As-Is",
Based
on this reverification of past work the licensee
0
believes that the missing weld was an isolated instance of
inadequate quality control inspection.
This item was not reportable
under
requirements
and
is closed.
(Closed)
Unit 2 Reactor Coolant
Pum
Delivered With Sand
In Cooler Chamber Housin
Unit 2 Reactor Coolant
Pump
(RCP) lllO-B, supplied by Combustion
Engineering
(C-E), was delivered to the job site with foreign matter
in the cooler chamber housing.
The foreign matter was later
identified by C-E as sandblast
material saturated
with oil from the
50 hour5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> test.
The material
was found in the former overflow chamber
which was plugged
and seal welded.
The pump finished its 50 hour5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> test in March,
1981.
In May,
1981
insufficient thickness
and poor adhesion of paint was observed
on
the cooling chamber housing.
In September,
1981 the cooling chamber
housing
was stripped
and repainted.
C-E feels the blasting
sand
came from this stripping procedure.
C-E also feels this is an
isolated
case
because
this is the only pump with the converted
overflow design which was sandblasted
and repainted.
The inspector
examined the Nonconformance Report,
NCR NC-724,
documenting the sand found in the cooling chamber housing.
The sand
was found during the field cleanliness
inspection required prior to
pump assembly.
The NCR was dispositioned
remove the sand
and
continue assembly.
The
NCR was signed off as complete.
The pump is
assembled
and has
been tested.
This item was not reportable
under
and is closed.
(Closed)
DER 84-29 " Plastic Coatin
on Diesel Generator
Heat
~Exchaa
era
While testing Train A of the Unit 2 Essential
Spray Pond the
licensee
discovered
an epoxy material in the temporary startup
strainer.
A Nonconformance
Report
(NCR SM-2935)
was written by the
licensee
to inspect the Unit 2 Diesel Generator
(D.G.) jacket water
cooler and lube oil cooler for plastic lining failure.
The
inspection revealed
extensive failure of plastic lining including
severe,
dense blistering and widespread
rusting.
(Construction Inspection Plans)
were written to examine,
document,
and correct the Diesel Generator
cooling system in Units
1 and 2.
The D.G. cooling system consists of:
the Lube Oil Cooler, the
Jacket
Water Cooler,
the Air After Cooler, the Governor Oil Cooler,
and the Fuel Oil Cooler.
The Lube Oil Cooler, Jacket
Water Cooler,
and Air-After Cooler all contained Plasite lining failures requiring
extensive repair.
The Governor Oil Cooler and Fuel Oil Cooler are
not Plasite lined.
However they contained
a significant buildup of
foreign material.
The foreign material
was cleaned off returning
the coolers to the appropriate
cleanliness
class.
Tl
J
pl
The licensee
stated
the cause of the Plasite failure was the
improper application of the Plasite
by subcontractors
at the
factory.
Plasite
must be applied in thin coats,
less than
18 mils
thick, and allowed to cure for 4 to 6 days in air depending
on
weather conditions.
The licensee believes that the subcontractors
applied Plasite
coats in excess of 25 mils and sealed
the coolers
before the Plasite
was fully cured.
The inspector
examined
the system set up on site to correct. the D.G.
Cooler Plasite lining problems.
The inspector
examined
MPP/QCI
60.3, Plasite
Coating Application.
This procedure
establishes
instructions
and criteria for the field application
and inspection
of Plasite coatings.
All the Plasite manufacturers
specifications
are included in this procedure.
This procedure also
documents
and
requires
QC verification of the important factors which insure
proper application of the Plasite lining such as:
film thickness,
film integrity, and curing time.
The inspector also interviewed the Field Coating Engineer
responsible for correcting the plasite, lining problem.
He indicated
he has been using this material for over
6 years
and his supervisor
has over 20 years
experience
with. this material.
He also indicated
the craft personnel
responsible for recoating the coolers
have been
extensively trained in the precision
and care needed
when working
with Plasite.
The craft personnel
interviewed by the inspector
confirmed this.
The Plasite recoating of the Unit l. D.G. Coolers .'is finished.
The
plasite recoating of the Unit 2 D.G. Coolers is approximately 75/
complete
and all the necessary
documentation is in place to track it
thru to completion.
Any Plasite lining failures in Unit 3 will be
identified during its startup
inspections.'his
item is closed.
(Closed)
DER 84-46- Refuelin
Mater Tanks Penetration
Following completion of the final stress
calculation for the
Chemical
and Volume Control System
(CVCS) the licensee
learned that
no design calculation had been performed for the sleeve-to-pipe
cap
plate connection for two 20-inch diameter pipes penetrating
the
Refueling Water Tank
(RWT).
Calculations,
subsequently
performed,
revealed that the connection would be overstressed
during a seismic
event
due to loads resulting from seismic anchor movement.
To
prevent this movement,
the annular
space
between the sleeve
and the
pipe was filled with non-shrink grout.
Calculation No.
13-CC-C7-015
was performed to verify that this modification would prevent the
overstressed
condition.
15C,
2CC,
3CC-ZY-134 have been issued
to correct this problem in Units 1, 2,
and
3 respectively.
The inspector verified these
DCPs have been issued.
The
DCP for
Unit 1 is signed off and stamped
by QC as being complete.
The
inspector
examined the Unit
1
and found them
filled with grout.
h
n
-This item is closed.
(0 en)
DER 84-38-
Im ro erl
Welded Flan
e
Pipe support
$/13-AF-005-H-007,
Rev.
1 was installed
and accepted in
Unit 2 by Field Engineering
and Quality Control.
During piping
rework,
two discrepancies
in the original installation were
discovered
and documented in NCR PC-8290:
The miscellaneous
steel
attached
to the pipe support
was at
a higher elevation than called
for and the beam attachment
was welded
on the East-Vest
sides
instead of the North-South sides of the lower beam'flange.
The
change in elevation of the miscellaneous
steel
causes
no additional
loading so the structural integrity of the pipe support is not
degraded.
However, incorrectly welding the beam attachment
to the
bottom flange causes
the flange to, improperly transfer
loads to the
structural
member.
The beam attachment
should be welded to the
I-Beam flange
so that the weld crosses
the web of the I-beam.
This
will transfer the loads
from the pipe support to the entire
beam
instead of just to the lower flange.
In this case,
transferring
loads to only the bottom flange results in 'exceeding
the structural
capacity of the bottom flange during
a DBE.
The inspector
examined
the proposed corrective action to repair the
improperly welded flange.
NCR PC-8290
was issued to add welds
on
the North-South sides of the beam attachment.
The'NCR was signed
off and stamped
by
QC as complete.
The inspector verified the
North-South sides of the beam attachment
were welded to the flange.
The licensee
feels this is an isolated
case
based
on a
1983
CAT
(Construction Assessment
Team) Inspection
and
a reverification
program of 2199 pipe supports
and pipe racks in Unit 1.
The inspector
examined
the
same pipe support in Unit 1 and found the
same deficiency.
A subsequent
inspection of this hanger in Unit 3
showed it is properly installed.
The inspector
then examined
35 pipe supports in Unit 1 against their
as built drawings.
Twenty-nine of the hangers
were part of the Unit
1 reverification program called for in WPP/QCI 543.0.
There were
2199 pipe supports
and pipe racks reinspected
in VPP/QCI 543.0.
All
problems identified by the inspector,
except Unit 1 pipe support
AF-005-H-007, were documented
on NCRs and FCRs.
This pipe support
was,
however,
documented in NCR PX-7902 for a missing Bracket Pin
North Retaining Ring.
VPP/QCI 543.0 identified problems with beam attachments
being welded
on the wrong sides.
All these
problems
were dispositioned
"Use As
Is".
The difference between these
hangers
and the
one identified in
DER 84-38 is hanger configuration.
The hanger identified in DER
84-38 is the only one which involves
a combination of a heavily
loaded hanger improperly welded to a light gauge
I-beam.
The inspector
found Pipe Hanger No. 13-AF-005-H-007, located in Unit
1, welded
on the East
and West sides to the lower I-Beam flange.
Pipe Support Assembly Drawing No. 13-AF-005-H-007, Revision 2, dated
0
A'
July 26,
1984, details the pipe support be welded to the lower
I-beam flange on its North and South sides.
This is the
same
problem with the
same
hanger in Unit, 2 identified in DER 84-38.
This DER states
the hanger in Unit 2 would fail during
a seismic
event.
This appears
to be
a violation of 10 CFR 50, Appendix B,
Criterion V, Instructions,
Procedures
and Drawings; which states in
part, "Activities affecting quality shall be prescribed
by
documented instructions,
procedures
or drawings of a type
appropriate
to the circumstances
and shall be accomplished in
accordance
with these instructions,
procedures
or drawings."
(Violation 50-528/84-47-01)
3.
Licensee Action on Previousl
Identified Items
a
~
(Closed) Follow-U
Item (50-528/84-20-01)
Receivin
Ins ections of
Materials Procured
from Vendors
b
C-E.
Previous
Ins ection
During a previous inspection,
the inspector
reviewed six
documentation
packages
of material procured by C-E (Combustion
Engineering)
from vendors.
The inspector
was unable to determine if
the proper quality documentation,
such
as specifications
and
purchase
orders,
was
on site.
The inspector
determined that the licensee
had reviewed all the Unit
1 C-E Purchase
Orders
(P.O.s)
and Field Material Requisitions for
completeness
of required documentation.
During this review the
licensee
discovered that
some material procured by C-E was shipped
without a procurement inspection.
This was documented in Nonconformance
Report
(NCR) NX-1491.
The
lists all P.O.s which did not have
a procurement inspection.
The
licensee
rereviewed all the P.O.s
and verified all the required
documentation
was present
and conformed to specifications.
The
licensee
also retrained
the receiving inspectors
to recognize
C-E
procured material requiring
a procurement inspection.
The inspector
randomly chose five purchase
orders for review.
Each
purchase
order package
and all required quality documentation,
and
the appropriate specifications,
were referenced
and available
onsite.
Based
on this sample, this item is closed.
b.
(0 en) Unresolved Item:
50-530/82-09/02 Flare Bevel Weld Re uirement
NRC Inspection Report No. 50-530/82-09
documents
the concerns
raised
by the inspector regarding
gC inspection of flare bevel weld joints.
The inspector questioned
whether
a
(}C inspector could actually
measure
and verify a flare bevel weld size
as called out on the pipe
support drawing,
and whether the effective throat of the weld was
y
achieved
using the criteria stated in Bechtel Drawing No.
13-S-ZAS-519.
Bechtel issued
Drawing Change Notice
(DCN) No.
5 to Drawing No.
13-S-ZAS-519 to provide further clarification for gC inspection of
flare bevel weld joints.
This action resolved the question
regarding the acceptance
criteria used by gC inspectors
during
verification of flare bevel weld size.
The question regarding effective throat requirements
has not been
addressed
by the licensee.
The licensee is committed to the 1972-73
edition of AWS Dl.l Structural Welding Code,
which does not address
flare bevel weld joints.
The
1975 "and subsequent
code editions,
however, did include flare bevel weld joints as being prequalified
provided certain conditions were met.
These conditions included
taking random sections of production welds to verify that the
effective throat is consistently obtained.
Since the licensee is
not committed to these later requirements,
the inspector
questioned
whether the effective throat was being achieved.
Bechtel
Interoffice Hemorandum
No. HB-104-03 of 10-12-84,
stated that tests
were conducted to determine
the minimum effective throat for flare
bevel weld joints,
and that the tes't results
were recorded in PgR
830.
However, the test results
were not representative
of the
structural materials of concern.
Therefore,
during the exit meeting
of 10-26-84,
the licensee
committed to provide the inspector with
objective evidence
demonstrating reconciliation of design
requirements for effective throat with that actually achieved in the
field.
This item will remain open.
(0 en) Deviation 50-528/84-25-03:
A Audits of the Subcontractor
Installin
S ra
On Pire roofin
Had Not Been Performed
The inspector
examined
the licensee's
response
to the deviation,
I,etter ANPP-30484-EVB/WEl dated
September
12,
1984.
Back round
The deviation was given because
the
APS commitment, given in the Fire
Protection Evaluation Report,Section IV Part
C indicates fire
protection work would be performed under the auspices
of a equality
Assurance
program.
The deviation addressed
the specific activity of spray-on-
fireproofing since it appeared
that no comprehensive
(}uality
Assurance
audits
had been conducted of the Spray-on-fireproofing
contractor's
work.
This Ins ection
The inspector
examined
the
gA audit addressed
by the
APS response
and concluded
the audit encompassed
only a very limited look at
spray-on coating thickness
(three probes for thickness)
and
a
confirmation that the specified spray-on material is included in the
U.L. Directory.
Ten specific equality Assurance .criteria are committed .to in the Fire
Protection Evaluation Report.
This represents
a gA program of
reduced
scope
from that used for safety related
systems
Appendix B) but is
a
QA program that fulfills the requirements
of
the
NRC guidelines set forth in BTP A'PCSB 9.5-1 for fire protection
systems.
The deviation was cited against the tenth
QA criterion committed to
in the Fire Protection Evaluation Report, that is, "Audits" because
this criterion would typically encompass
the other nine criteria.
The "Audit" criterion states:
"Audits should be-conducted
and
documented to verify compliance with the fire protection program
including design
and procurement"'documents,
instructions,
procedures
and drawings,
and inspection
and test activities."
The licensee's
limited gA audit review of the spray-on coating
contractor's
work does not appear to meet the commitment to perform
rocedures
ins ection and test activities.
The licensee's
response
also states
that the applied coating
thickness
was also monitored by contract coordinators
and that the
presence
of coatings in the 'required places
was walked
down by
engineering personnel.
C'owever,
the response
did not provide rationale for whether adequate
control of spray proofing design, material procurement,
application
procedures,
and other applicable inspection or test attributes
(other than thickness)
has been exercised.
In discussions
with licensee
management
the inspector
concluded
that, if controls
have not been exercised
on certain aspects,
a
rationale for why these certain aspects
are not of technical
significance should be provided.
Additionally, in discussing
the original deviation and the
response
with site management
personnel
during the week of October
15,
1984, it became
apparent that the issue involved was larger than
indicated by the original deviation, that is, applicable to more
than the spray-on-fireproofing contractor.
Specifically, the licensee
had earlier identified a lack of QA
involvement in several of the fire protection system contractors,
including the sprinkler piping installations
and
some of the Bechtel
controlled fire protection system installations.
As a result
a fire
protection audit was performed
(C83-10) which had
some significant
findings including improper seismic design criteria used for Bechtel
installed fire protection piping and indications of a lack of
control over the subcontractor for sprinkler installation.
Independent
NRC inspections of a limited scope, in the area of fire
protection conducted after the single
APS gA audit have identified
additional problem areas
(e.g.
improper seismic design by a fire
LII
protection subcontractor
and seismic design criteria not in
accordance
with FSAR commitments
(reference
report 50-528/84-25)).
These additional
NRC findings apparently indicate that the single
APS gA audit was not sufficiently comprehensive
to assure
that the
QA attributes
committed to in the Pire Protection Evaluation Report
were adequately
implemented.
During the week of October 15,
1984 licensee
management
indicated
that other independent verifications had been performed in various
areas
which could provide the assurances
required.
At the exit interview on October 26,
1984
a licensee
representative
committed to provide
a comprehensive
study of the fire protection
system work done by the contractor
and subcontractors
which will
demonstrate
the adequacy of controls
on design,
procurement,
procedures
inspection
and testing,
or alternately,
define the
actions that need to be taken to demonstrate
that adequacy.
This deviation,
expanded in scope,
remains
open pending receipt
and
evaluation of the licensee's
study of the adequacy of controls in
the construction of fire protection systems.
4.
Review of IE Circulars
(Closed) Circular 80-01
Service Advice for General Electric Induction
Bechtel letter B/ANPP-E-57954
MOC 112581 of April 22,
1980 provided the
results of examination of relays
from all suppliers
except Metalclad
Switchgear.
Evidently General Electric could not confirm whether
defective type relays
were shipped in Metalclad Switchgears.
Therefore,
Bechtel committed to examine all Metalclad Switchgear
and issue
a
Nonconformance
Report if defective relays
are found.
Design
Change
Package
(DCP) No.
10E-PB-017 for Unit
1 was issued to inspect
and repair
as required the =GE supplied 4.16
KV Class
1E switchgear
as described
by
Circular 80-01.
The work under this
DCP is completed for Unit 1.
Identical
DCPs have been initiated for Units 2 and 3.
This Circular is closed.
5.
Im lementation of Three Mile Island Lessons
Learned
The inspector
reviewed the below listed items which represent
a portion
of a comprehensive
and integrated plan to improve safety following the
events at Three Mile Island, Unit. 2 in March,
1979.
(The item numbers
are from Enclosure
2 of NUREG-0737).
I.B.1.2 Inde endent Safet
En ineerin
Grou
(ISEG) (0 en)
V
r
10
This item involves establishment
of an independent
group located
onsite to feedback operating experience
to plant personnel
and
monitor plant operations
to improve safety.
One concern raised in Inspection Report 84-43
was
a deviation from
the commitment
made in the Palo Verde Lessons
Learned Implementation
Report.
The licensee
had stated in the ILIR that Shift Technical
Advisors
(STAs) and
ISEG would be
a single group, i.e.,
STAs will
perform the functions of the
ISEG when not on duty or assisting
the
shift supervisor.
However, the arrangem'ent
implemented by the
licensee
involves the
STAs and
ISEG being two separate,
independent
groups.
NRC has
reviewed this arrangement
and found it acceptable
as
documented in the upcoming Supplement
6 to the Palo Verde
SER.
The inspector
reviewed the experience qualifications of,each
new
member of ISEG by .interviewing each individually. It was confirmed
that the
6 individual ISEG members
and the supervisor
possess
experience
and college
degrees
consistent with the Technical
Specifications,
Paragraph
6.2.3.2.
The inspector also reviewed
a draft ANPP policy procedure that
governs the functioning of ISEG, 7N405.02.00,
Rev.
1.
No
deficiencies
were identified, however,,this
item will remain open
until an approved version is available for review.
In addition, the
inspector will review the ISEG staff's familiarity with this
procedure
and other implementing procedures
to ensure that
ISEG is
a
functioning body, with an understanding
of their role in pl'ant
safety.
I.C.5 Feedback of 0 eratin
Ex erience
(0 en)
Review of operating experience
and dissemination
to plant personnel,
is
a function of ISEG.
The inspection of this TMI Action Plan Item was first documented in
Inspection Report 84-23.
At the time, responsibility for this
function was assigned
to the
STA group.
At that time, the inspector
had
comments
concerning procedure
79AC-9ZZ03, Operating Experience
Review, which the licensee
had agreed to incorporate.
Subsequently,
responsibility for review o'f operating experience
was transferred
to
ISEG.
ANPP policy procedures
are
now used to govern this function
of ISEG vice Station Manual procedures,
therefore,
procedure
79AC-9ZZ03 has been superseded
by procedure
7I405.02.01,
lSEG
Operating Experience
Review.
The inspector
reviewed the draft
version of 7I405.02.01
and identified two aspects
of the TMI Action
Plan item that are inadequately
addressed:
(1) Identifying the
recipients of various categories
of operating information and (2)
Assuring plant personnel
do not routinely receive
extraneous
or
unimportant information that would obscure priority information and
detract from overall job performance.
The
ISEG staff agreed
to incorporate
these
comments into procedure
7I405.02.01.
This item will remain open pending procedure
approval
p, '
and subsequent
NRC verification of the incorporation of these
comments.
I.C.6 Procedures
for Verif in
the Correct Performance
of 0 eratin
Activities
Closed
This TMI Action Plan Item involves independent verification of
operator activities
as
a means of reducing
human, error.
The inspector interviewed cognizant licensee
personnel
and reviewed
samples of the following procedures:
(1), Sire protection
surveillance tests,
(2) ISC surveillance 'tests
and preventive
maintenance
tests,
(3) electrical surveillance tests
and preventive
maintenance
tests,
(4) mechanical surveillance tests
and preventive
maintenance
tests,
(5) operational surveillance tests
and operating
procedures,
(6) work order facsimiles.
Although some operational
surveillance test procedures
and ISC surveillance test procedures
have yet to be completed
and approved,
the inspector verified that
an independent verification program, is in place at Palo Verde.
Applicable licensee
procedure writers and supervisors
are aware of
the requirement
and have incorporated
independent verification
criteria into the applicable procedures
that the inspector
reviewed.
The applicable
ISC and operations
procedure writers committed to the
'nspector
to continue to write procedures
in light of independent
verification criteria.
Additionally, training will be given within the next
2 weeks for all
Senior Reactor Operators in the conduct of all aspects
of
independent verification.
The inspector verified that open aspects
from Inspection Report 84-43 have been satisfactorily resolved by
the licensee.
However,
one additional deficiency was identified.
Procedure
73AC-9ZZ04, Surveillance Testing,
does not include provisions for
independent verification.
The licensee
representative
committed to
including guidance in 73AC-9ZZ04 for independent verification.
This
procedure revision will be completed prior to licensing
and followed
up as part of routine inspection.
This item is closed.
New Items
I.A.2.1 Immediate
U
radin
and
RO and
SRO Trainin
and
qualifications
0 en
NRC Position
References:
a)
b)
Denton Letter of March 28,
1980
c)
f'
IJ
8
Applicants for SRO license shall have
4 years of responsible
power
plant experience,
of which at least
2 years shall be nuclear power
plant experience
(including 6 months at the specific plant) and no
more than
2 years shall be academic or related technical training.
Certifications
that= operator license applicants
have learned to
operate
the controls shall be signed by the highest level of
corporate
management for plant operation.
Revise training programs to include training in heat transfer, fluid
flow, thermodynamics,
and plant transients.
Licensee
Commitment
Reference:
PVNGS TMI-2 Lessons
Learned Implementation Report
ln summary,
the licensee's
commitment generally follows the
applicable guidelines of NUREG 0694 and the Denton letter of March
28,
1980.
Ins ector Findin s
References:
a)
b)
c)
Procedure
82TR-9ZZ03 Requalification Procedure for Iicensed
Operator Retraining
Procedure
82TR-9ZZ01 Cold License Training
Procedure
82TR-9ZZ02 Hot License Training
The inspector
examined lesson plans,
course
manuals
and training
records to ensure
the licensee's
compliance with this TMI Action
Plan Item.
In addition, training procedures
were reviewed
and other
applicable documentation
as necessary.
The inspector
was satisfied that the licensed operator training and
retraining program is adequate
and follows NRC guidelines, with the
exception of 3 identified deficiencies:
1.
The requalification training program does not include
Mitigating Core
Damage
as part of the curriculum,
as required
by the Denton letter.
The licensee
representative
committed to revi'se procedure
82TR-9ZZ03 to make inclusion of this material mandatory
and to
create
lesson plans for inclusion of Mitigating Core
Damage in
the requalification program.
2.
All operator control manipulations
required
as part of
'equalification
training in Enclosure
4 of the Denton letter
are included in 82TR-9ZZ03.
However, the checksheet
used to
track the training the operators
receive in these manipulations
is missing
one control manipulation from the Denton letter,
"Loss of Protective
System Channel".
The licensee identified
4
I
lh
C
13
this previously and is in the process
of revising the checklist
to include the missing manipulation.
3.
Due to the omission of the radiation monitoring portion of
Mitigating Core Damage, all operators
must receive this missed
training prior to fuel load..
This item will remain open until these corrective actions
can be
verified by the inspector.
II.X.1.5 Review of ESF Valves
(o en)
NRC Position
References:
a)
b)
J
Review all safety-related
valve positions, positioning requirements
and positive controls to assure
that valves, remain positioned
(open
or closed) in a manner to ensure
the proper operation of engineered
safety features.
Also review related procedures,
such
as those for
maintenance,
testing, plant and system startup,
and supervisory
periodic (e.g., daily/shift checks),
surveillance to ensure that
such valves are returned to their correct positions following
necessary
manipulations
and are maintained in their proper positions
during all operational
modes.
Licensee
Commitment
Reference:
PVNGS TMI-2 Lessons
Learned Implementation Report
Refer to CESSAR Appendix B, Item II.K.1.5.
In addition,
PVNGS will
have tagout procedures
and surveillance test procedures
that will
control safety system status.
They will provide appropriate
logs
and checklists to ensure control of plant systems.
Additionally,
reviews will be conducted
to verify that procedures
for
safety-related
systems
return those
systems
to service after having
been tagged out for repair or surveillance testing.
Refer to item
I.C.2 for a discussion of procedures
for shift relief and turnovers
to ensure current plant conditions
and system status is conveyed to
the oncoming shift.
Periodic audits will also be conducted
to verify that tagouts
are
removed
and systems
returned to normal when the repair/testing
has
been completed.
Ins ector Findin s
References:
a)
40AC-9ZZ02, Conduct of Shift Operations
l
i j"
tt
a
t
4
14
b)
c)
d)
e)
Operating Department Instruction No.
17
40AC-9ZZ16, Shift Turnover
73AC-9ZZ04, Surveillance Testing
40AC-OZZ05, Station Tagging and Clearance
The inspector
reviewed the above procedures
in addition to samples
of various surveillance test procedures
a'nd preventative
maintenance
procedures.
Interviews with plant personnel
were also conducted.
The inspector
determined that the provisions of this TMI Action Plan
Item have been satisfactorily addressed
by the licensee.
Procedures
are in place to independently verify restoration of safety systems
and control safety system status.
The Shift Turnover procedure will
ensure that the oncoming shift is made
aware of safety system status
and overall plant conditions.
However,
one deficiency was identified.
The periodic audit referred
to in the licensee
commitment is not being conducted,
nor have plans
been
made to begin conducting this audit., The licensee
has opted to
pursue
an LLIR revision to delete this commitment to a periodic
audit.
Per discussion with the
NRR Project Manager
on November 2,
1984,
this item may be closed contingent
upon the licensee
issuing the
ILIR revision.
Any NRC comments
would be directed
from NRR to the
licensee.
This item will remain open pending issuance
of the LLIR revision.
II.K.1.10 - 0 erabilit
Status of Safet -Related
S stems
(Closed)
NRC Position
References:
a)
b)
IEB 79-06B
Review and modify as necessary
your maintenance
and test procedures
to ensure that they require:
a.
Verification, by test or inspection,
of the operability of
redundant safety-related
systems prior to the removal of any
safety-related
system from service.
b.
Verification of the operability of all safety-related
systems
when they are returned to service following maintenance
or
testing.
c.
Explicit notification of involved reactor operational personnel
whenever
a safety-related
system is removed from and returned
to service.
Licensee
Committment
V
Reference:
PVNGS TMI-2 Lessons
Learned Implementation Report
The licensee states:
The
PVNGS evaluation of item I.C.6 adequately
addresses
the concerns
of this item.
Ins ector Pindin
s
References:
a)
b)
c)
d)
Procedure
73AC-9ZZ04, Surveillance Testing
Procedure
70AC-9ZZ02, Conduct of Shift Operations
Operating Department Instruction No.
17
Procedure
40AC-OZZ05, Station Tagging and Clearance
The inspector
reviewed
a sample of surveillance
and preventative
maintenance
procedures,
and interviewed several licensee
personnel.
It was noted that specific guidance is given in this area,
in the
Procedure for Surveillance Testing,
73AC-9ZZ04. If an individual
surveillance procedure
removes
a redundant train or channel
from
service,
the shift supervisor or his assistant
signs in the
prerequisite
section to verify operability of the remaining train or
channel.
The inspector
reviewed
a sample of surveillance procedures
to ensure
this policy is implemented
and identified no deficiencies.
Provisions
are
made in the Conduct of Shift Operations
procedure,
40AC-9ZZ02 and in the Station Tagging and Clearance
procedure,
40AC-OZZ05 to ensure that the shift supervisor authorizes
removal
and return to service of safety systems.
In addition,
adequately
addresses
properly return'ing safety systems
to service.
Finally, the inspector interviewed
an
SRO to ensure
operator
knowledge of this requirement.
In summary,
no deficiencies
were identified concerning ths
Action Plan Item,
and therefore, this item is considered
closed.
I.C.l.l Guidance for the Evaluation
and Develo ment of Procedures
for Transients
and Accidents - Small Break Loss of Coolant Accident
0 en
NRC Position
References:
NUREG 0578
Analyses,
procedures,
and training addressing
the following are
required:
i
1.
Small break loss-of-coolant accidents;
2.
Inadequate
core cooling;
and
3.
and accidents.
Some analysis
requirements for small breaks
have already been
specified by the Bulletins and Orders
Task Force.
These
should be
completed.
In addition, pretest calculations of some of the Loss of
Fluid Test
(IOFT) small break tests
(scheduled
to start in September
1979) shall be performed
as
means to verify the analyses
performed
in support of the small break emergency procedures
and in support of
an eventual long term verification of compliance with Appendix K of
Licensee
Commitment
Reference:
PVNGS THI-2 Lessons
Learned Implementation Report
PVNGS intends to submit
a Procedures
Generation
Package,
in
accordance
with Section 6.0 of Draft NUREG-0899, to the
NRC for
staff review following NRC approval of C-E Owner's
Group emergency
procedure
guidelines.
A target submission
date of August 1,
1982
has been established
for this package.
Emergency operating
procedures will be developed
and implemented in accordance
with this
package
and will be ready for NRC onsite review 60 days prior to
fuel load.
Ins ector Findin s
References:
a)
b)
c)
Small Ioss of Coolant Accident
CEN-152,
Rev.
01, Combustion Engineering
Emergency Procedure
Guidelines
Palo Verde Emergency Procedure
Generation
Package
The licensee
uses
the Emergency Procedure
Guidelines to develop the
Emergency Procedure
Generation
Package.
The Procedure
Generation
Package is then used to generate
the Emergency Operations
Procedure,
and the
10 recovery operations
procedures,
which
includes the
SBLOCA procedure,
The inspector
reviewed the Small Break
LOCA procedure
to compare
the procedure with the Generic Guidelines
and the
Procedure
Generation
Package.
The inspector questioned
a deviation of the procedure
from the
Generic Guidelines which was identified by APS in the Procedure
Generation
Package.
The
SBLOCA procedure
uses different criteria for determining the
mode of Iong Term Cooling (LTC) than called for in the Generic
Guidelines.
The Generic guidelines dictate
use of pressurizer level
and subcooling margin to determine if the Shutdown Cooling System
can support plant cooldown.
The licensee
uses pressurizer
pressure
e,
1
~ 7
of 538 psi, which is recommended
by the
CESSAR, or RVLMS (Reactor
Vessel Level Measurement
System) level of 73/,'o
make this
determination.
lI
Per discussion with NRR on November 6,
1984 as to the technical
acceptability of this deviation, it was determined that the
licensee's
approach is acceptable.
However,
NRR still has
comments
concerning
the
SBLOCA procedure
which the licensee is resolving, but the 'inspector identified no
additional deficiencies
or deviations of hi;s own.
Finally, the inspector
observed
a training session for recovery
operations
procedures.
Two or three procedures
are covered in
classroom training and then practiced by the operators. on the
simulator.
Thus, the aspects
of analysis,
procedure preparation
and training
have been adequately
addressed
by the licensee,
as far as the
procedure is concerned.
This item remains
open pending assurance
that the
SBLOCA procedure is actually in place in the Control Room,
with the latest revision incorporated,
and approved.
6.
Exit Interview
The inspectors
met with the licensee
management
representatives
denoted
in paragraph
1 on November 2,
1984.
The scope of the inspections
and the
inspector's
findings as noted in this report were discussed.
~
.
0