ML17299A910
| ML17299A910 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/19/1985 |
| From: | Kirsrh D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| Shared Package | |
| ML17299A911 | List: |
| References | |
| NUDOCS 8601080514 | |
| Download: ML17299A910 (9) | |
See also: IR 05000528/1985031
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Docket No. 50-528
UNITED STATES
NUCLEAR REGULATORY COMMISSION
AEGIDN V
1450 MARIALANE,SUITE 210
WALNUTCREEK, CALIFORNIA94596
DFg 19
1985
Arizona Nuclear Power Project
P. 0.
Box 52034
Phoenix,
Arizona 85072-2034
860i0805i4 85i2i9
- DOCK 05000528
9
Attention:
Mr. E. E. Van Brunt, Jr.
Executive Vice President
Gentlemen:
Subject:
NRC Inspection of Palo Verde Unit 1
This refers to the special
team inspection
conducted
by Mr. S. Richards
and
other members of our staff on October
28 - November 8, 1985, of activities
authorized
by NRC License No. NPF-41,
and to the discussion of our findings
held by Messrs. Martin, Kirsch and Richards
and other members of our staff
with Mr. Haynes
and other members of your staff at the conclusion of the
inspection.
Areas
examined during this inspection are described in the enclosed
inspection
report.
Within these
areas,
the inspection consisted of selective
examinations of procedures
and representative
records,
interviews with
personnel,
and observations
by the inspectors.
This inspection focused
80 percent of its effort upon your administrative
controls associated
with the Auxiliary Feedwater
System
(AFWS), the Emergency
Diesel Generators
(EDG), and the Pressurizer Auxiliary Spray System
(PASS)
and
the implementation
and compliance with those controls in the following areas:
Calibration Program;
Maintenance
Program; Surveillance
Program;
Vendor Field
Change Notices;
and Design Changes
and Modifications.
The other 20 percent of
the team's effort was focused
on administrative controls in the following
areas:
Operating Staff Training; Quality Assurance Audits (onsite
and
offsite); and Plant Operations.
Overall Conclusions
The strengths
and weaknesses
found in the areas
examined are discussed
in the
attached
inspection report and also in the paragraphs
summarizing the
inspection results.
In general
the team found your organization to be
competently staffed
and functioning in an acceptable
manner.
However, in the
area of technical work we have several
concerns.
There appears
to be
weaknesses
in the implementation of the design
change process
and your
oversight of the contractor presently performing most of that work.
Further,
your review and control of temporary modifications at Unit 1 is lacking.
We
encourage
you to take actions to ensure that technical work at your facility
is being performed
and reviewed in a formal documented
manner.
0
~t)
jt
Areas Ins ected
and Results
A.
Calibration Pro ram
An inspection
was performed to determine
whether
a
QA program for the
control of measurement
and test equipment
had been implemented that was
in conformance with regulatory requirements,
commitments
and industry
guides
and standards.
Particular attention
was directed to installed
instrumentation
used for surveillance activities.
Your staff has
implemented
a satisfactory program.
Effective use
was being made of the
plant computerized
data base to ensure
compliance with requirements
for
equipment accountability, calibration,
and maintaining equipment history
and usage
records.
B.
Surveillance Testin
and Calibration Control Pro
ram
An inspection
was performed to ascertain
whether programs
had been
developed for control and evaluation of surveillance testing
and
calibrations required by the Technical Specifications.
The inspection
also included
a review of programs for the calibration of safety-related
instrumentation not specifically controlled by Technical Specifications.
The program for control of the testing frequency for the emergency
diese>
generators
was weak and appeared
to have resulted in the diesels
having
been tested
more frequently than required.
C.
Maintenance
Inspection of maintenance activities included
a review of the maintenance
program
and verification that the program was being properly implemented
to assure
that the systems
examined
can function as required to prevent
or mitigate accidents.
Areas inspected
were preventive maintenance,
corrective maintenance,
equipment control, special processes
and
housekeeping.
It is concluded that the maintenance
program is
satisfactory;
however,
areas for improvement were observed
and an open
item was identified regarding procedural control of the work
authorization process.
D.
Motor 0 crated Valve Maintenance
The motor operated valve maintenance
program was found to be
satisfactory.
Preventive
maintenance,
corrective maintenance
and
inservice testing of motor operated
valves
was being conducted in
accordance
with approved procedures.
Some
room for improvement
was
observed with regards
to tabulation of data,
and an open item was
identified regarding valve stroke times.
E.
Plant Procedures
Plant procedures
were reviewed
and found to be in agreement with the
and the piping and instrumentation
drawings.
The technical .content of
the procedures
was consistent with the Technical Specifications
and the
vendor manuals.
W
DEC 19
1S85
Implementation of corrective actions resulting from findings identified
by gA audits
was found not to be timely.
The
1985
ANPP Objectives Letter
specified
90 days
as the goal to complete corrective actions,
on the
average.
This time frame is considered
excessive
by the
NRC.
We
recommend that
APS management
take steps
as necessary
to assure
corrective actions
are accomplished
on
a more timely basis,
such
as
30
days.
G.
0 eratin
Staff Trainin
A detailed
review of the training department
programs that pertained to
the non-licensed plant staff was conducted to ascertain
whether the
overall training and retraining activities for non-licensed
employees
and
general site training for licensed
employees
are in conformance with
requirements
as set forth in the station license, Final Safety Analysis
Report
(FSAR),
and committed regulatory guidelines.
The inspection found
that training is being performed in accordance
with the requirements,
however,
the non-licensed auxiliary operator training program, while
within requirements,
does not measure
up to current industry standards.
H.
Vendor Field and Technical Manual Chan
e Notices
The inspection reviewed the administrative controls
and plant records to
assess
the licensee's
program to effectively identify, control,
distribute,
and implement vendor technical manual
changes for
modifications
and to ascertain that technical manuals
are 'controlled and
maintained current in accordance
with a document control program.
The
inspector
found that the overall program appears
to be satisfactorily
controlled and that an aggressive
program is in effect to control
identified changes
and issue
these
changes
to the users in a timely
manner.
I.
Desi n Chan
es
and Modifications
In order to evaluate
the licensee's
program for controlling design
changes
which modify plant systems,
structures
and components,
the
inspector
reviewed applicable procedures,
examined records
and in-process
documents,
and interviewed responsible
personnel.
It was concluded that
the licensee's
program
was generally in conformance with regulatory
requirements,
FSAR commitments,
and industry standards.
Implementation of
the design
change control and plant modification program was determined
to comply with the programs'ritten
procedures.
However, the Bechtel
engineering organization
was determined to have deviated
from the
licensee's
FSAR commitment concerning supervisory design verification
reviews.
OEC le 1S85
Although strength
was perceived in several
aspects
of the program, there were
many areas
observed
by the inspector which warranted further management
attention.
These are identified as
open or unresolved
items
and are
characterized
as follows:
Inadequate
design control program for proposed
minor onsite modifications,
incomplete
10 CFR 50.59 reviews,
design
verification review elements
not fully implemented,
technical specification
required station supervisory staff reviews not clearly addressed,
and
criteria training requirements insufficiently defined by procedure.
Additionally, control of temporary modifications
was found to be weak.
Two
violations were noted in the administration of temporary modifications.
Additionally, the documented
technical justification for the acceptability of
several
temporary modifications appeared
minimal.
Increased
management
attention in this area
appears
warranted.
Based
on the results of this inspection, it appears
that two of your
activities were not conducted in full compliance with NRC requirements,
as set
forth in the Notice of Violation, enclosed
herewith as Appendix A. You are
required to respond to the Notice of Violation (Appendix A) in accordance
with
the provisions of 10 CFR 2.201
and requested
to respond to the Notice of
Deviation (Appendix B).
In accordance
with 10 CFR 2.790(a),
a copy of this letter and the enclosures
will be placed in the
NRC Public Document Room.
The responses
directed by this Notice are not subject to the clearance
procedures
of the Office of Management
and Budget as required by the Paperwork
Reduction Action of 1980,
PL 96-511.
Should you have any questions
concerning this inspection,
we would be pleased
to discuss
them with you.
Sincerely,
Enclosures:
A.
B.
Notice of Deviation
C.
Inspection Report No. 50-528/85-31
D. F. Kirsch, Acting Director
Division of Reactor Safety 8 Projects
cc w/enc:
J.
Bynum,
W. F. Quinn,
T. D. Shriver,
W. E. Ide,
C. N. Russo,
Ms. Jill Morrison, PVIF
Lynne Bernabei,
GAP
Duke Railsback
ACC
Arthur C. Gehr,
Esq.
J. Jankovich,
NRC
J. Partlow, IE'
P
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gpss 19 5986
bcc w/enclosure:
RSB/Document Control Desk (RIBS)
Mr. J. Martin
Mr. B. Faulkenberry
G.
Cook
Resident Inspector
Project Inspector
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