ML17303B028

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Forwards Special Team Insp Rept 50-528/88-01 on 880104-0212 & Notice of Violation.Number & Types of Problems Noted Is Indicative of Need for Addl & Better Focused Mgt Attention to design-related Activities
ML17303B028
Person / Time
Site: Palo Verde 
Issue date: 03/30/1988
From: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Van Brunt E
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
Shared Package
ML17303B029 List:
References
NUDOCS 8804190104
Download: ML17303B028 (8)


See also: IR 05000528/1988001

Text

" AC't.'EIZRATED

DISTRIBUTION

DEMONSTRATION

SYSTEM

SUBJECT:

Forwards Special

Team Insp rept 50-528/88-01

on 880104-0212

6 notice of violation.

DISTRIBUTION CODE: IEOID

COPIES

RECEIVED:LTRj ENCL

SIZE: 6+~D

TITLE: General

(50 Dkt)-Insp Rept/Notice of Violation

esponse

D

05000528

S

NOTES:Standardized

plant.

REGULATORY'NFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:8804190104

DOC.DATE: 88/03/30

NOTARIZED: NO

DOCKET

g

ACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi

05000528

AUTH.NAME

AUTHOR AFFILIATION

MARTIN,J.B.

Region 5, Ofc of the Director

RECIP.NAME

RECIPIENT AFFILIATION

VAN BRUNT,E.E.

Arizona Nuclear Power Project (formerly Arizona Public Serv

RECIPIENT

ID CODE/NAME

PD5

PD

DAVIS,M

INTERNAL: ACRS

DEDRO

NRR/DLPQ/PEB ll

NRR/DOEA DIR 11

NRR/DREP/RPB

10

NRR/PMAS/ILRB12

OGC 15-B-18

RES/DRPS

DIR

TERNAL: LPDR

NSIC

NOTES:

COPIES

LTTR ENCL

1

1

2

2

2

2

1

1

1

1

1

1

2

2

1

1

1

1

1

1

1

1

1

1

1

1

RECIPIENT

ID CODE/NAME

LICITRA,E

AEOD

NRR MORISSEAU,D

NRR/DLPQ/QAB 10

NRR/DREP/EPB

10

NRR/DRIS DIR 9A

OE LIEBERMAN,J

FILE

02

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01

NRC PDR

COPIES

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'

A

D

8

A

TOTAL NUMBER OF COPIES

REQUIRED:

LTTR

27

ENCL

27

Docket No. 50-528

Arizona Nuclear

Power Project

P.

0.

Box 52034

Phoenix,

Arizona 85702-2034

Attention:

Nr.

E.

E.

Van Brunt, Jr.

Executive Vice President

SUBJECT:

NRC INSPECTION OF

PALO VERDE NUCLEAR GENERATING STATION

UNIT NO.

1

Gentlemen:

'I

This refers to the special

team inspection of January

4 through February 12,

1988,

conducted

by Nr.

M.

M. Mendonca

and other members of our staff, of

activities authorized

by NRC License

No.

NPF-41 and to the discussion

of our

findings held with you on February

12,

1988,

and other members of your staff

at the conclusi,on 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 team.

Ins ection Overview

The inspection

conducted

by the team was

a safety

system functional

inspection

(SSFI).

The objective of an

SSFI is to assess

the operational

readiness

of selected

safety systems

to function under all operational

and analyzed

accident conditions.'he first step involves the selection

of a small

number of plant systems that have significant impact

on plant

safety

and which involve a broad cross section of site activities. 'or

this inspection,

the Essential

Chilled Water System

(EC), Essential

Cooling Water System

(EW), and Essential

Spray

Pond System

(SP) were

selected for review with .additional attention to interfaces with

supporting

and serviced

systems.

These

systems

were selected

because it

is considered

essential

that they function correctly following an event

such

as

a loss of offsite power or a major plant transient.

Additionally, probabilistic risk assessment

studies of pressurized

water

reactors

have indicated that the tailure of the selected

systems,

following a loss of offsite power or a major plant transient,

generally

contributes

highly to the probability of occur rence of a core melt event

or an event with significant offsite consequences.

~In assessing

these

systems,

the team focused primarily on the capability

of your engineering

organization to establish

and access

the design basis

of the systems;

and their capability to maintain the design basis

when

modifying the systems

and during system operation.

Additionally, the

8804i90104

880330

...PDR

ADOCK 05000528

9

DCD

SEOUL

MAP 3

0

198S

team considered

the actual

implementation of the design basis

through

maintenance,

surveillance,

testing,

and plant operational

aspects

associated

with the systems

selected.

Team Findin

s

The team identified a number of deficiencies

and raised

many significant

questions

with regard to =the selected

systems.

As highlighted below,

these

include missing or inadequate

design analysis,

inadequate

implementation or maintenance

of the design, basis,

and deficiencies

in

the System

Engineer

Program:

1.

Several

examples of significant errors in design basis

documents

were identified:

Significant calculations

were missing.

There were

no

calculations available for:

Sizing the essential

chilled water or the essential

cooling water surge tanks relief valves.

Supporting the design temperatures

and pressures

of the

three

systems.

gualification of electrical

cable supports

in electrical

cable trays for SSE conditions.

Examples of inadequate

design or modification calculations/

assumptions

wer e observed:

ANPP had

made

two calculation

changes

to diesel

generator

loading calculations

and

had not first corrected

or taken

into account inaccuracies

in the original/initial

calculations.

Battery sizing and diesel

generator

loading calculations

contained

non-conservatisms

and notable errors.

Sizing the essential

cooling water system

surge tank was

based

on one half the

Rancho

Seco design with no

calculations.

2.

Several

examples

were identified in which the design basis

was not

adequately

implemented or maintained.

Procedure

and training were inadequate

for the crosstie of

the essential

cooling water (safety)

and the nuclear service

water (non-safety)

systems.

Addition of a chemical additive tank over the

SP system,

without considering

seismic aspects

in the 10 CFR 50.59

review.

Air Handling Unit Access

Panel

missing,

poor condition of

emergency lighting batteries,

electrical cabinets with several

cover fasteners

missing.

These

are indicative of a less than

adequate

level of verification of proper maintenance activity

completion.

3.

System engineers

lacked specific

knowledge with regard to

design basis,

examples

are:

The failure of system engineers

to identify the problems

identifie'd by the inspection

team.

Lack of knowledge of various interface functions with other

systems,

e.g.,

essential

cooling water system

surge tank level

setpoints,

battery pilot cell selection.

Established training programs

were not specific nor did they

assure

acceptable

system engineer

knowledge or retention.

A summary of significant, inspection

team findings is set forth in

Appendix

B', herewith enclosed.

Conclusions

Based

on these finding and the findings of the special

inspection

(50-528/88-07) related to the inoperability of the Auxiliary Feedwater

Pumps,

the team found that:

Y

ANPP has defined

as

a goal the establishment

of a plant design

basis

document;

however,

ANPP has not been effective in

implementing

an engineering

program to assemble

a complete

and

accurate

design basis

document.

ANPP has not been effective in establishing

and implementing

a

System Engineering

Program that accomplishes

the goals laid out by

ANPP.

The team concluded that these

programs

have drifted away from the

original goals

due to management

inattention.

We find this particularly

vexing in light of our past discussions

with you concerning

these

programs.

The number

and types of problems

noted is indicative of the need for

additional

and better

focused

management

attention to design related

activities.

This conclusion is also reinforced

by the findings of a special

inspection related to the inoperability of the Auxiliary Feedwater

Pumps.

In

that inspection,

we found that the problem of changing limit switch

I'JAR 3 0

198S

setpoints

inconsistent with component

design function, could have

been

found

and corrected

by respon'sible

personnel

during any one of many opportunities.

Similarly, the SSFI found examples of inadequate

implementation of the design

basis

throughout the

ANPP organization.

In this regard,

the team

had several

discussions

with licensee

management

personnel.

These

management

personnel

shared this concern

and noted that efforts have already

been initiated to

enhance

performance

in this area.

As previously stated,

the team concluded that the design basis

program

and the

system engineer

program strayed substantially

from the objectives

stressed

to

us over the last several

years.

Further,

the team determined that the root

causes

of this divergence

were that (1) management

had not effectively

established

and communicated their expectations

related to the Technology

Transfer

and the System

Engineer

Programs,

and (2) management

had not assured

implementation of the design basis into plant activities, e.g.,

operations,

maintenance,

surveillance,

and training.

Specifically,

management

had not

provided

and assured

a clear understanding

of (1) what is an acceptable

design

basis

document,

(2) what is an acceptable

design basis technical

review,

and

(3) what are the

knowledge level

and responsibilities

for engineering

personnel

to establish

and maintain the -design basis.

Finally, the team

concluded that management

must assure that their expectations

are

implemented

through

management

overview, quality audits,

and other independent

assessments.

During the team exit meeting,

you acknowledged

the team's

conclusions relating

to design

and design control deficiencies

and described

several

planned

actions to correct

these deficiencies.

You further clarified your intentions

during an

ANPP/NRC Management

Meeting held on February 29,

1988.

The team

understands

that these

actions

are intended to:

(1) consider

design basis

information and calculations

associated

with plant systems

and provide

additional

assurance

that this information is accurate

and complete with

particular emphasis

on the Technology Transfer

Program;

(2) audit plant

activities

and confirm that these activities reflect accurate,

technically

sound design basis

information; (3) provide improved programs

and control over

all organizations

implementing design basis

requirements,

particularly with

regard to the System

Engineer

Programs,

and (4) provide additional

management

overview of the technical

aspects

of design

and modification activities

including independent

assessment

of those activities.

0

You are encouraged

to assign priority to efforts to improve your performance

in this area.

Additionally, we would request that you please

provide

a

detailed written description of your action plan to improve performance

in

~ this area.

Specifically,

we would suggest that you perform a thorough

reappraisal

of the design basis

program

as well as the system engineer

program.

This reappraisal

should include your evaluation of the root cause(s)

as to why the programs

have not completely

implemented

management's

objectives

and intentions,

and assure that there is a clear,

mutual understanding

of your

objectives

by all involved.

Me anticipate periodic meetings with you and,your

staff to discuss

the status of your actions to address

the basic

problems

.identified in this inspection.

~<8 ~ 0

1S88

Based

on the results of this inspection, it appears

that certain 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.

Your

response

to this Notice is to be submitted in accordance

with the provisions

of 10 CFR 2.201.

In addition to your response

to the Notice of Violation,

please

provide your assessment

of the apparent deficiencies identified as

unresolved

items in the enclosed

report, including any corrective actions

taken or planned.

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 letter and the attached

Notice are not subject

to the clearance

procedures

of the Office of Management

and Budget

as required

by the Paperwork Reduction Act of 1980,

PL 96-511.

Should you have

any questions

concerning this inspection,

we will be glad to

discuss

them with you.

Sincerely,

Regional Administrator

Enclosures:

1.

Appendix A, Notice of Violation

2.

Appendix B,

Summary of Significant Findings

3.

Inspection

Report

No. 50-528/88-01

cc w/enclosures:

'.

G.

Haynes,

ANPP

W.

F. Quinn,

ANPP

R.

Papworth,

ANPP

L. Souza,

ANPP

T.

D. Shr-',ver,

PVNGS

W., E. Ide,

PVNGS

C.

N.

Russo,

PVNGS

J. Morrison,

PVIF

L. Bernabei,

GAP

T.

Hogan,

ACC

A.

C.

Gehr, Snell

8 Wilmer

JBurd

3/

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1

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3/p~/88

3/~88

bcc w/enclosures:

RSB/Document Control

Desk (RIDS) (IE01)

D. Persinko,

NRR

Project Inspector

Resident

Inspector

G.

Cook

B. Faulkenberry

J. Martin

Docket File

bcc w/o enclosures

2 and 3:

LFMB

M. Smith

Region V/norma

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VEST COPY ]

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