ML17303B031
| ML17303B031 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/30/1988 |
| From: | Burdoin J, Caldwell C, Mendonca M, Narbut P, Parkhill R, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17303B029 | List: |
| References | |
| 50-528-88-01, 50-528-88-1, NUDOCS 8804190113 | |
| Download: ML17303B031 (74) | |
See also: IR 05000528/1988001
Text
e
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
No:
50-528/88-01
Docket No.
50-528
License
No.
Licensee:
Arizona Nuclear
Power Project
P.
0.
Box 52034
Phoenix, Arizona, 85072-2034
Facility Name:
Palo Verde Nuclear Generating Station - Unit 1
Inspection at:
Corporate
Engineering Offices, Phoenix,
Palo Verde Site, Wintersburg,
Inspection
Conducted:
January
4 through February 12,
1988
Inspectors:
.
Me
nc
, Te
Leader
Date Signed
R
Park ill,. Assista t Team Leader
P.
ar
u
, Sr.
sident
spector
Date Signed
~i~r/t'~
Date Signed
Burdoin,
Reac or Inspectore~
C. Caldwell,
Reactor 'Inspector
Consultants:
S.
Kobylarz, Westec Services,
Inc.
S. Klein, Westec Services,
Inc.
Da e Signed
a /~Y$
Date Signed
Approved by:
S.
A. Richards,
Chief,
Engineering Section
~Summer:
33oS
Date Signed
Ins ection Janu'ar
4 throu
h Februar
12
1988
Re ort Nos.
50-528/88-01
involved the areas
of Engineering,
Maintenance,
Surveillance Testing,
Operations,
and equality Assurance
and Administration.
During this inspection,
inspection
modules
25578,
25583,
30703,
35701,
37700,
37701,
37702,
38701,
8804190ii3
SS0330
ADOCK 05000528
9
1
41400,
41700;
41701,
42700,
56700,
61700,
61725,
61726,
62700,
62702,
62703,
62704,
62705,
71707,
71710,
73051,
73055,
92700,
and 92701 were used.
Results:
The following findings and conclusions
were identified:
Understandin
Control
and
Im lementation of Plant Desi
n
Re uirements
The team noted several
examples of problems in which the licensee
appeared
to
have
a less
than adequate
understanding
of the plant design.
Specific
concerns
in this regard involve both an inadequate
licensee
understanding
of
the plant design basis
and an inadequate
implementation of design requirements
into plant modifications
and activities.
Summar
of Violations Identified,
Of the areas
inspected,
three apparent violations of NRC requirements
were
identified,
as
summarized
below:
A.
Failure to comply with certain as-built requirements
of prescribed
documented
instructions,
procedures,
or drawings.
B.
Failure to comply with prescribed
procedures
in making temporary
modifications to install
a tank to supply hypochlorite for the emergency
C.
Failure to comply with ASHE requirements
in determining the size of
pressure relief valves for the surge tanks in the essential
chilled water
system.
It should
be noted that several
areas
of potential violation of NRC
requirements remain unresolved,
pending completion of additional
licensee
review of the specific problems
involved.
Further actions in this regard
will be the subject of future correspondence,
following a review of additional
licensee
information'on these
items.
DETAILS
1.
Persons
Contacted
. See Enclosure l.
2.
Desi
n Basis
Documentation
and
En ineerin
Activities
A.
General
Observations
The design portion of the inspection
focused
on
a review of design
change
packages
and original design basis documentation'elated
to
the selected
safety systems.
The team
was impressed with the
ability of the engineering staff to provide rapid responses
to
detailed technical
questions,
and
a capability to rapidly access
design basis
documentation
and analyses.
ANPP maintains
a
calculation index which facilitated this retrieval process.
Based
on the results of the design inspection,
the team determined
that the selected
safety
systems
(essential
chilled water, essential
cooling water,
and essential
spray systems)
are functional.
However, the team found that design analyses
were not adequately
verified to assure
a comprehensive
and complete evaluation of system
and equipment performance.
In many cases,
calculations to support
the established
size of safety related
components
and equipment
were
not complete,
or missing in their entirety.
The team found that the
observations
identified in the design inspection
are indicative of a
problem in the implementation of the
ANPP Technology Transfer
Program.
This'program
was instituted to assure that design basis
documentation
developed
by Bechtel for Palo Verde is effectively
transferred
to the cognizance of ANPP engineer ing personnel.
The
team found that
ANPP had not adequately
reviewed design basis
analyses
to assure that
a complete
and accurate
design basis is
available for use in future plant design modification efforts.
Based
on the
number of observations
identified related to Bechtel
calculations,
the objectives of the Technology Transfer
Program
may
not have
been achieved.
Although ANPP has not made significant
permanent
design
changes
to the plant, the team was concerned that
future modifications
may be compounded
in difficulty and complexity
by the lack of design information.
Specific examples of these
observations
are described
in Section
B
below.
B.
Desi
n Activities
The team reviewed mechanical
and electrical
design related to three
critical safety systems:
Essential
chilled water
(EC)
Essential
cooling water
(EW)
Essential
spray pond (SP)
The
EC supplies chilled water to a number of safety related
room
coolers
from a chiller which rejects
heat to the essential
cooling
water system
(EW).
The
EW provides cooling water to the essential
chiller
and the shutdown heat exchanger.
Heat from this equipment
is rejected to the essential
spray pond by the essential
cooling
water heat exchanger.
The essential
spray
pond serves.
as the
ultimate heat sink for Palo Verde Nuclear Generating Station.
None
of these
systems
operate
during normal
power operation.
. However, in
the event of a design basis accident,
heat
loads are rejected
from
the containment
sump to the shutdown heat exchanger
and then to the
essential
spray
pond via the essential
cooling water
heat exchanger.
The team reviewed design documentation
related to these
systems
including design
change
packages
(DCPs),
system descriptions,
P8IDs,
specifications,
line lists,
and design
analyses
to assess
the
capability of these
systems
to perform their safety functions.
For
the electrical ancillary support systems,
the team reviewed the
design analyses
for the sizing of the Class lE station batteries
and
the emergency
diesel
generators,
the
AC and
DC voltage studies,
and
the protective device setting
and coordination studies.
The review
focused
on the adequacy of the methodology,
the accuracy of the
design data,
and the validity of the the design
assumptions
utilized
in the calculations.
As part of the Technology Transfer
Program,
ANPP conducted
reviews of design documentation
received
from
Bechtel.
The team assessed
the effectiveness
of these
reviews
as
an
adjunct to the design inspection.
The team identified a number of observations
which indicated
weaknesses
in several
areas
of engineering activities.
These
include missing or inadequate
design analyses
and inadequacies
in
the verification of design analyses.
The following observations
are
illustrative.
ANPP has not made significant design
changes
to the Palo Verde plant
configuration.
Consequently,
the team did not review plant design
modifications originated
by ANPP engineering.
However, the team did
review a number of design calculations
and analyses
prepared
by
Bechtel substantiating
the original plant design basis.
The team
identified weaknesses
related to the use of unverified assumptions
and methodology
used in the calculations.
In some cases,
there were
no calculations
or documented
rationale to substantiate
system
parameters
.or equipment sizes.
The team noted
a general
lack of
awareness
by ANPP engineers
of the specific design
assumptions
utilized in the calculations.
The team attributes this lack of
awareness
to a shortcoming of the Technology Transfer
Program.
(1)
Missin
Calculations
a.
Sur
e Tank Pressure
Relief Valves
The essential
chilled water and
EW surge
tanks are
supplied nitrogen through
a pressure
regulating valve to
maintain nitrogen pressures
between
2 and
5 psig for the
essential
cooling water tank and
25 and
55 psig for the
EC..
A relief valve is provided
on the essential
chilled
water tank to protect the tank from pressures
which might
exceed its design pressure
of 100 psig.
Similarly, the
essential
cooling water surge tank is provided with a
relief valve to prevent exceeding
the design pressure
of
15 psig.
Section III of the
ASME B8PV Code, Article ND-7412,
requires
pressure relief valve capacity to include
consideration
of a fully open pressure
reducing device.
The licensee
had not considered
or done calculations
which
demonstrate
that the relief valves provided for the
essential
chilled water and essential
cooling water surge
tanks"are
sized to accommodate
flows resulting from the
failure of the upstream regulating valve in the wide open
position.
Failure of the regulating valve could impose
pressures
exceeding
design pressure
on the surge tanks if
the relief valve cannot
accommodate
the resultant 'nitrogen
flows.
In response
to the team's
concern,
ANPP engineering
personnel
developed preliminary- (checked,
but unverified)
calculations to confirm the capacity of these relief
valves to meet the code requirement.
The calculation
determined that for both tanks,
the relief valve was
adequately
sized to accommodate
the flow resulting from a
failure of the regulating valve in the wide open position.
However, the calculation determined
the
Cv (flow
coefficient) for the relief valve based
on the design flow
identified on the relief valve data sheet.
This flow was
in gpm representing
the liquid flow through the valve at
design conditions.
ANPP engineering
personnel
advised
that the valve vendor
had indicated (in a telephone
conversation) that the
g'as flow calculated
using this
Cv
was conservative.
This is
a potential violation of. the
ASME code
and is identified, as inspection
item
50-528/88-01-01.
Desi
n Pressures
and
Tem eratures
The team reviewed the Line Designation List for Palo Verde
which identifies the design pressures
and temperatures
for
system piping.
The licensee
could find no calculations
or
documented
rationale to substantiate
the design pressures
and temperatures
identified for the selected
safety
systems.
In response
to the team's
concern,
ANPP prepared
and"submitted
a written "sequence
of events" outlining the
methodology
used to develop the design pressures
and
temperatures
for PVNGS systems.
This procedure
included
a
calculation which attempted to confirm the design pressure
and temperature
for the
EC.
However, the calculation did
not include considerations
such
as
an evaluation of worst
case
operating
modes
and static
heads
due to components
which might be located at elevations
lower than the
essential
chilled water
pump.
The calculation
was not
signed,
checked,
or verified.
The team was unable to
confirm that design pressures
identified for systems
listed in the Line Designation List assure that piping
systems
and components
are adequately
designed to meet
system
demands.
ANPP stated that calculations to support the design
pressures
and temperatures
for the selected
safety systems
under review (EC,
EW, and
SP) will be developed.
In
addition,
ANPP will prepare
design pressure/temperature
calculations for any system which is modified prior to the
modification if the modification affects these
parameters.
Subsequently,
the team reviewed
a calculation submitted
by
ANPP to document the rationale supporting design pressures
and temperatures
for the essential
spray pond system'SP)
and
had
no questions
on that do'cument.
This observation
is not safety significant since the
design pressures
established
for the systems
reviewed
appear
to be sufficiently conservative.
However, the team
considered
the lack of substantiation
for design
conditions to be
a weakness
in design
development
which
could impact future modifications
made to the'lant.
This
observation
(and others described
below) contributed to
the team's
concern that
ANPP may not be adequately
reviewing design basis
documentation
to assure
that
critical design parameters
are supported
by design
analyses.
This observation
remains
open pending
completion of the calculations
committed to by ANPP.
The prelimjnary schedule
was January
29,
1988 for SP
(completed), April 1, 1988 for EW, and July 1,
1988 for
EC.
This is considered
an unresolved
item and is
identified as inspection
item 50-528/88-01-02.
Seismic
Desi
n of Electrical
Cables in Vertical"Cable
~Tra
s
During the system
walkdown portion of the SSFI, the team
noted that only nylon ties appeared
to be, used to support
electrical
cables in vertical cable trays.
The utility
was asked to provide an analysis
which justified that
cables
in vertical cable trays are supported
such that
they could adequately
withstand
a safe
shutdown earthquake
without resulting in any significant loading
upon the
cable terminations.
Such
an analysis
should also include
consideration
of nylon tie wrap aging effects.
The team
reviewed the installation specification governing the
support of conductors
in vertical
raceways
and
observed'hat
the instructions
were generalized
and could not be
solely relied upon to determine
a worst case'lant
configuration.
In addition, the team confirmed via the
utility that support blocks,
Kel lum grips
and cable
clamps,
as referenced
in the installation specification,
were not utilized in the vertical cable trays,
but instead
applied only to cables
in vertical conduit.
The utility,
in an outline of a plan to resolve the concern;- dated
February
15, 1988,
committed to perform the requested
analysis within a ten-week schedule.
Before performing
the subject analysis,
the utility intends to determine
plant vertical tray configurations followed by
establishment
of worst case
models.
This approach is
considered
by the team to be acceptable
with the
understanding
that the final analysis
when completed will
be reviewed
by the Structural
and Geosciences
Branch of
NRR.
This issue constitutes
an unresolved, item and is
identified as inspection
item 50-528/88-01-03.
Class
1E Batter
Room Ventilation
The team observed that the Class
1E battery
room 'normal
and emergency
exhaust ventilation ducts
draw room air from
approximately the middle of the
room height.
This
arrangement
could allow for the potential build-up of
hydrogen gas,'hich
is released
from the battery primarily
during equalize
charging,
in the
room volume above the
exhaust
duct register.
The licensee
has provided the team
with an evaluation which documents that the ventilation
system provides
good air mixing action which would result
in the purging of potential
hydrogen entrapment
areas.
The mechanism for air mixing in the
room is provided by
the air flow from a supply air register which is located
in approximately the center of the battery
room.
Supply
air is provided from a Class
lE ventilation
system.
However, during
a kalkdown of the battery
rooms the team
observed
possible
areas
of entrapment
formed by structural
steel
members at the ceiling where it was not completely
obvious that adequate air mixing would occur.
The team questioned
whether actual
hydrogen level readings
have
been taken at the ceiling to verify the hydrogen
removal capability.
Apparently, to date,
the only
measurements
for hydrogen
have
been
made at or near
the
batteries
and not at the ceiling.
Two of the
120
VDC vital battery
rooms
have
emergency
lighting batteries
also housed in the room.
The team
identified that the emergency lighting batteries
were not
considered
in the calculation for hydrogen
(H~) generation
during design of the ventilation system for the 120
VOC
vital batteries.
In addition, the calculations
had never
been verified to determine if excessive
H~ pocketing
has
been occurring.
6
The licensee
re-performed
the
H~ calculations
and
found that it would take
92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br /> to reach
a 2X
concentration
in the battery
rooms without any
ventilation.
This was quite different from their
original calculation which did not include the
emergency lighting battery
Hz generation.
The licensee
committed to perform a test of actual
Hydrogen levels in the battery
rooms while charging
the batteries.
was prepared to
monitor the buildup of,hydrogen in all areas
of the
battery
rooms during float and equalizer charging.
'his
will determine
the potential for H~ pocketing.
This issue will remain open pending confirmation. from the
licensee that the aforementioned
tests
have
been
completed
and the results
support the current design configuration.
This is identified as inspection
item 50-528/88-01-04.
Batter
Room Minimum Desi
n Ambient Tem erature
Battery sizing is based
on a minimum cell operating
temperature
to ensure that the battery
has
adequate
capacity to satisfy the design basis
requirement.
The
team found that the licensee
did not have
a design
calculation which documents that the Essential
HVAC system
for the battery
room could maintain
a minimum 60
F design
ambient temperature,
which is the design input temperature
in the battery sizing analysis
associated
with a loss of
offsite power.
Also, the team found that the minimum
design
ambient temperature,
calculated
as
59
F in the
analysis for the normal battery
room
HVAC system during
plant start-up (Calculation 13-MC-HJ-001,
sheet
15 of 34),
did not satisfy the calculation Design Criteria, Part
II.B, which required
60 F.
However, the design margin
available in the Class lE batteries
compensates
for'he
weakness
in the minimum'design
ambient temperature
analysis.
The identified weaknesses
are
examples of
inadequate
design verification and the failure of the
Technology Transfer
Program to assure
rigorous design
analyses
which form the basis for the safety-related
design of the plant.
This item will remain
open pending confirmation from the
licensee that
a calculation,
which 'demonstrates
that the
essential
HVAC system
can maintain the required 60'F
during
a
LOP,
has
been formally issued
and supports
the
current design configuration.
Additionally., the licensee
should assure that the normal battery
room
HVAC system
has
been formally updated,
and its design basis
has
been met.
This is identified as inspection
item 50-528/88-01-05.
(2)
Inade
uate Calculations
Diesel Generator Sizin
A review of the data utilized in the Diesel Generator
Sizing calculation for the
pumps
and drive motors for the
Essential
Spray
Pond,
Essential
Cooling Water,
and
EC
indicated that incorrect and non-conservative
data
was
utilized in the diesel
generator
load analysis for the
plant conditions
under review.
Forced
Shutdown
(FSD) and
LOCA/LOP plant conditions'were
analyzed to determine the
required size for the diesel
generator.
The team found that the applicable
brake
horsepower
(Bhp)
requirement,
based
on the required
system flow for the
plant condition under review was not always utilized.
Also, the team found that the
Bhp or flow requirement
was
derived from a document
found to be not up to date,
such
as the System Description,
even though it was
a controlled
design basis
document.
Furthermore,
worse
case
load data
was apparently
not utilized in the calculation
even though
the applicability of the calculation
was for all three
Palo Verde Units.
The calculation
showed the Essential
Cooling Water
Pump
EWA(B)-POl "Load Size" brake
horsepower
(Bhp)
requirement
as
665 Bhp, with a "Maximum" requirement
of 690 Bhp.
665 Bhp on the
pump characteristic
curves correlates
with a flow requirement of 14,550
gpm (which is listed as the rated capacity in the
system description which is shown
as
a reference
, document for this data).
These
Bhps were then
converted to a motor input
kW requirement
(based
on
the motor efficiency related to 690 horsepower
(hp),
or 0.945,
which is conservative).
Nevertheless,
the
calculation
goes
on to establish
Forced
Shutdown
(FSD) and
Loss of Coolant Accident/Loss of Offsite
Power
(LOCA/LOP)
kW requirements,
based
on the "Load
Size" or normal,
and the
"Maximum" required
Bhps,
as
525
kW and 545
kW respectively,
which apply to both
plant conditions.
In this case
the calculation
methodology of a normal
and
maximum load for each
plant condition is erroneous.
The Flow Diagram for
the
EW shows the flow for a "Normal" and
a "LOCA"
shutdown condition to be the
same,
and flow during a
"FSD" to be much higher.
The hydraulic analysis for
this, system,
13-MC-EW-001, Revision 1, calculates
the
FSD flow as 17,280
gpm,
and the
LOCA/LOP flow as
15,980
gpm.
These
flows are the only flows
.
applicable for each of the plant conditions.
On this
basis,
the team calculates .that the
kW required for
FSD is 550
kW, and for LOCA/LOP 545
kW.
This
compares with the licensee
calculated
loads
as
follows:
Team Calculation
Licensee Calculation
Forced
Shutdown
550
kW
525
kW
545
kW, maximum
LOCA/LOP
545
kW
525
kW
545
kW, maximum
Therefore,
the
use of incorrect design flows for the
plant conditions analyzed resulted in a 4X to 5X
error in understating
the required motor kilowatts
(kWs) due to the erroneous
methodology.
The Essential
Spray
Pond
Pump required flow, based
on
the hydraulic analysis for the system,
13-MC-SP-302,
Revision 0, is 16,540
gpm for both
FSD and
LOCA/LOP
conditions.
This corresponds
to approximately
589
Bhp on the
pump test data sheet
M095-103-1.
However,
the calculation utilized 580 Bhp as the
pump
requirement,
in spite of the .fact that the System
Description, which was
shown as
a reference for this
data,
showed
589 Bhp as the
pump requirement.
The
Bhp requirement for the Essential
Chilled Water
pump used in the calculation,
13.3 Bhp, disagrees
with the data
on pump curve N-872, Revision 0, which
shows
14 Bhp required at the operating point, 400
gpm.
The flow requirement,
400 gpm, correlates
well
with the flow data indicated
on the Flow Diagram
13-M-ECF-001, Revision 1, which shows the
maximum
flow to be 397
gpm.
The team
was concerned that in the three (3) cases
where
the team reviewed the data utilized in the calculation,
discrepancies
and/or errors
were found, raising concerns
regarding the overall validity of the calculated results.
'As
a result of the team's
concern,
the licensee
reviewed
the calculation
and data for all motor drives greater
than
100 hp.
The results of the analysis
confirmed the team's
observation,
and found, for example, that for the Unit 2
diesel
generator,
the
LOCA/LOP load increased
3.8X (or
207.2
kW) and the
FSD load increased
2.2X (or 120.9
kW).
Nevertheless,
the resulting design margin available in the
diesel
generators
during LOCA/LOP, based
on the continuous
rating,
was at least 14.5X.
The .team also noted that the licensee's
engineers
had
initiated two (2) revisions to the diesel
generator
loading analysis
(Calculation
Change Notices),
but failed,
in the process,
to review the analysis
provided by the
original architect-engineer,
and detect the errors in the
data
and calculations
as identified by the team.
This item remains
open pending confirmation from the
licensee that the subject calculation
has
been formally
revised
and supports
the plant's current design
configuration.
This is identified as inspection
item
50-528/88-01-06.
Cl'ass
lE Batter
Sizin
The team reviewed the Class lE Battery and Battery Charger
Sizing Calculation 13-EC-PK-100,
Revision 5, for
conformance with acceptable
design criteria and the
validity of the assumptions
and the data utilized in the
calculation.
The team found that
a calculation assumption utilized
erroneous
methodology
and data which,
as
a result,
understated
the average
inverter load on the battery.
Also, other
data utilized in the calculation for auxiliary
relay cabinet loading was found to be incomplete
and,
therefore,
understated.
The "average floating voltage" of the duty cycle for
the battery
was
used to establish
the average
inverter load.
The concept of a battery
on float
during a design discharge
is incorrect since the
battery is not on float charge for this condition.
The initial .battery voltage
on discharge
was
considered
to be 130.2 volts (which is the minimum
recommended float voltage for the battery).
The
initial battery voltage cannot
be more than the
battery
open circuit voltage,
which the team
calculated to be 123.3 volts based
on the Exide
published data,
and is in fact lower due to the
initial load. on the battery during discharge.
For
example, for Battery "A" the team estimated that the
initial battery voltage is 119 volts,
based
on the
referenced
calculated battery load after one minute
and the Exide battery capacity curves.
On this basis
the average
duty cycle voltage is (105 + 119)/2 = 112
volts versus
117.6 volts calculated in Assumption
3. 1. a (where
105 represents
the voltage at the end of
the duty cycle).
The net result is 5X additional
load on the battery
on average
during discharge
due
to the increased
inverter load.
An incorrect inverter efficiency of 87X was utilized.
This is the efficiency at full load and 100K power
factor.
For the
same
load conditions
and with the
static transfer switch which is installed,
the rated
efficiency is 86K as stated in the Inverter Manual.
Apparently,
when the static transfer switch was
installed
on
the calculation
was not
identified to be updated to reflect the revised
inverter efficiency.
Nevertheless,
the conservatism
10
utilized in stating the inverter load in the sizing
analysis for the battery (Inverters
A and
B were
considered
to be
lOOX loaded,
and Inverters
C and
D
were considered
to be
SOS loaded)
compensates
for the
error in inverter efficiency.
Also, the inverter efficiency utilized applies at
inverter full load and
lOOX power factor.
The
inverters are in fact operated at less
than full load
conditions (the team observed Inverter "B" at
approximately
30K load during
a plant walkdown),
and
less than
lOOX power factor (the licensee
assumed
90K
power factor in the calculation).
The operation of
the inverters at less
than full load results in
additional
design margin in the battery.
However,
the amount of margin was not established
since the
efficiency data
was not available for variations of.
load and power factor.
The team understood that this
data is being pursued
by the licensee with Elgar, the
manufacturer of the inverter.
The auxiliary relay cabinet
load was found by the
team to be understated.
The sizing calculation for
Battery "A" showed the steady state
load as
10
amperes for the auxiliary relay cabinets,
but the
single line diagram for the 125
VDC Distribution
Panel
E-PKA-E21 showed the load to just one (1) of
eight (8) auxiliary relay cabinets
as
10 amperes
(cabinet
E-ZJA-COl, 1250 VA).
Therefore,
the load
for seven
(7) auxiliary relay cabinets
was not
accounted for in the battery sizing analysis.
The team was provided with a preliminary draft of the
battery sizing reanalysis
on January
23,
1988, for
Batteries
"A" and "C," which are considered
to be the
worst case for each type of battery cell provided
(GN-23 and GN-13, respectively).
For Battery "A,"
for example,
the reanalysis
included
an increase
in
the average
inverter
load of 11.5 amperes
and an
increase
in the auxiliary relay cabinet
load of 70
amperes,for
the
2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> duty cycle.
Also, increased
first minute loads for the aforementioned
were
identified.
A similar increase
in the inverter load
for Battery "C" was identified; however,
no
additional auxiliary relay load was applicable for
this battery.
The results of the draft reanalysis
show that the
design margin capacity available in the batteries
was
decreased
from 36.6X to 10.8X for Battery "A," and
from 19.5X to 15. 1X for Battery "C."
The resulting
capacity margin available
in the batteries
was
acceptable,
especially since additional factors for
minimum battery cell operating temperature
and aging
11
factors
have also
been included in the battery sizing
analysis.
The team attributes
the errors in methodology
and
data to a lack of adequate
design verification.
This issue will remain
open pending confirmation from the
licensee that the subject calculation
has
been formally
revised
and supports
the plant's current design
configuration.
This is identified as inspection
item
50-528/88-01-07.
c.
Ade uac
of DC Volta e
'he
team reviewed the
DC cable sizing calculation to
verify the adequacy
of- the power cables
selected
to
provide adequate
voltage at equipment.
The team observed
weaknesses
in the verification of
assumptions
and results of the calculation,
and also
apparent
typographical
errors in a design equation
and
calculation tabulation headings.
Assumption
1 assumed that the first minute voltage of
the battery will be maintained at 125 volts.
125
volts is more than the
open circuit and
no load
battery terminal voltage,
123.3 volts.
This
assumption
also disagrees
with the analysis
provided
by Exide, for each of the Class
1E batteries,
as
found in Appendix
B of the calculation.
The Exide
calculations
indicate
a minimum first minute voltage
of illvolts.
Assumption
2 stated that in the absence
of vendor
data,
a minimbm of 80K of the rated voltage shall
be
assumed
to be needed at the load terminals during
starting.
On review of the equipment specification
for motors,
the team could not verify the adequacy of
this assumption.
The specification did not address
any requirement for DC motor starting at less
than
105 volts, which is 91.3X on a 115 volt base
(the
motor rated voltage base).
The motor feeder cable voltage
dr'op on full load and
starting for the Auxiliary Feedwater
Regulating Valve
J-AFC-HV-33 is calculated
as 4.6 and 28.41 volts,
respectively,
on sheet
12.
A 4.6 volt drop on full
load violates design criteria ¹2 which states
that
the voltage drop on full load shall not exceed
2.5X
of the rated
bus voltage (or 3.125 volts).
The 28.41
volt drop on starting deviates
from Assumption
2
which states
that the minimum voltage shall
be at
least
SO% (of rated
bus voltage,
125 VDC) or 100
volts.
125 volts (based
on Assumption 1) minus
12.
28.41 volts results in 96.59 volts at the motor
on
starting.
However, the team estimates
that
on motor
starting with the battery voltage at illvolts
(during the first minute
on
a design discharge)
the
voltage at the motor is 82.5 volts.
Since this
voltage
was significantly less
than specified,
and
also did not satisfy the assumed criteria, the
licensee
was requested
to provide justification for
the adequacy of the existing design,
including
confirmation of the required valve torque
and stroke
time on the reduced
motor voltage conditions.
The team
was given the results of a draft re-analysis,
which was prepared
by the licensee
during the inspection,
which indicated that the terminal voltage available at
eight (8)
DC motor operated
valves
was less than
105
volts.
For these
valves the voltage available
ranged
from
89.99 to 103.39 volts.
The licensee
also confirmed that
the resulting stroke time for each valve satisfied the
design
minimum requirement,
although in some
cases
by only
a very small margin.
In the draft analysis
the licensee
utilized the minimum battery voltage condition during
valve operation,
while considering
the actual battery load
as
a design basis.
Therefore,
the team noted that any
future load addition
on the battery requires
careful
consideration.
This issue wi'll remain
open pending confirmation from the
licensee that the subject calculation
has
been formally
revised
and supports
the plant's current design
configuration.
This is identified as inspection
item
50-528/88-01-08.
d.
Essential
S ra
Pond
S stem
The SP, including the essential
serves
as the
ultimate heat sink for the Palo Verde Nuclear Generating
Station.
In the event of a postulated
design basis
loss
of coolant accident
(LOCA), containment
heat
loads
are
transfer red to the ultimate heat sink via the shutdown
cooling system
and
EW.
Upon initiation of post
recirculation, the containment
heat
removal path consists
of:
Heat transfer from the containment
sump to the
EW via
the shutdown cooling heat exchanger;
Heat transfer from the
EW to the essential
via the essential'ooling
water heat exchanger;
and
Heat dissipation to the environment via the essential
spray
pond and the evaporative
spray system.
13
The essential
spray pond contains sufficient inventory to
accommodate
accident heat loads,
reactor
decay heat,
and
auxiliary equipment
heat loads for up to 27 days.
The team reviewed Bechtel Calculation 13-NC-SP-007,
Revision 2, dated
September
25, 1986,
"Spray
Pond Thermal
Performance
Analysis."
The purpose of this calculation
was to confirm the thermal
performance of the spray pond
and the effect of SP bypass
flow on
EC heat exchanger
hot
side outlet temperature.
This calculation
documented
the
input, rationale,
assumptions,
and
summary of results for
a number of computer runs
as required to conduct this
analysis.
The design input indicated that all cases
assumed
an
overall heat transfer coefficient for both heat exchangers
which corresponded
to fouled conditions.
This assumption
may not always
be conservative
when all aspects
of the
total heat removal
system are considered.
The team found
that the analysis did not consider
cases
which could
result in higher essential
cooling water temperatures
and
higher spray pond temperatures.
Two other cases
must be
analyzed to adequately
envelope the total effect of heat
exchanger fouling on system performance
during
a
postulated
LOCA:
Case I.
Clean
shutdown cooling heat exchanger
and fouled
essential
cooling water heat exchanger.
This case
enhances
heat transfer to the
EM while degrading
heat transfer to the spray pond, thus maximizing hot side
essential
cooling water heat exchanger outlet temperature.
The resulting higher essential
cool,ing water temperatures
could exceed
the 125
F design limit imposed
on the system
to satisfy essential
chilled water requirements
for this
accident condition.
Higher chilled water temperatures
'ould affect the capability of the chilled water system to
provide adequate
room cooling to safety-related
equipment.
Case II.
Both shutdown cooling and essential
cooling
water heat exchangers
clean.
In this case
the total heat transfer path is at maximum
anticipated
heat rejection performance
thus maximizing
essential
spray
pond temperatures.
Since the spray pond
system supplies cooling water to the emergency
diesel
generator
equipment,
the resulting higher temperatures,
could exceed
the vendor
imposed 110'F design limit for
this equipment.
In response
to these
concerns,
Bechtel
developed
additional
analyses
addressing"these
cases.
The results
of the calculations
indicate that although cooling water
temperatures
were slightly increased,
design limits would
not be exceeded
in any case.
The team
had
no further
questions
on this issue.
Essential
Chilled Water
S stem
EC
Bechtel Calculation 13-MC-EC-252, Revision 1, is
a
calculation performed to establish
EC equipment sizes.
The team identified the following concerns with this
calculation:
Unverified and undocumented
assumptions;
No basis for design input, e.g., piping lengths,
equipment pressure
drops,
leakage,
system
volumes,
and
pump flow capacity;
and,
Chiller heat load not updated to as built conditions.
The team also reviewed Bechtel Calculation
13-MC-EC-451,
.
Revision 1, dated
September
19, 1984, which were pipe
sizing calculations.
However, this calculation determined
pipe sizes
based
on velocity limitations for the pipe size
selected.
No consideration
was given to the flow
distribution through the piping system to assure
that
component flow demands
could be achieved
based
on pressure
drops throughout the system
and the
pump flow capacity.
This. revision was
made to update the calculation to the
final "as built" piping configuration.
However, only the
line velocities were revised
based
on the "as built" pipe
diameters.
No attempt
was
made to determine
the actual
flows in the system
based
on a hydraulic network analysis
to confirm that design flow rates
could be achieved for
each
component supplied chilled water.
The team found
that the revisions
made were superficial relative to the
more significant update
which would confirm that design
requirements
had
been satisfied.
Neither of these calculations
determined
whether
pump
requirements
had been
met.
The team could find no other
calculations
which determined that adequate
NPSH was
available to the essential
chilled water
pumps
under all
operating conditions.
In response
to the team's
concerns,
ANPP provided
preliminary evaluations
which confirmed adequate
NPSH to
the essential
chilled water pump.
The team also reviewed
the results of flow balancing tests for the
EC.
Test
results
demonstrated
that design flow requirements
to the
safety related coolers
were satisfied.
15
In addition,
ANPP:
Agreed that in order to modify the system, all or
portions of the calculation modeling the system will
be revised;
Added statements
to the cover sheet of the
calculation indicating the revisions
and updates
were
required
and must be made to the calculations prior
to performing any design modifications to the system;
and,
Will provide training to the engineering staff on
these
issues.
This is identified as inspection
item 50-528/88-01-09.
Essential
Coolin
Water
S stem
EW
Calculation
13-MC-EW-200, Revision 1, dated
May 2, 1979,
is
a calculation performed to establish
the size of the
essential
cooling water surge tank.
However, the
calculation merely included
a statement
to use
one half
the size of the
Rancho
Seco
(SMUD) surge tank (apparently
a reference
to the Sacramento
Municipal UtilityDistrict
surge tank).
The volume of the tank was calculated
as 1/2
of 2000, i.e.,
1000 gallons,
where
2000 gallons
represented
the
SMUD tank'volume.
There were
no other
calculations to substantiate
the size of the surge tank
considering
thermal
expansion
and contraction,
leakage,
or
to develop operating level setpoints,
or high and low
level alarm 'setpoints.
ANPP submitted
a
new calculation developed
by Bechtel
in response
to the team's
concern to substantiate
the
surge tank size based
on coolant thermal
expansion
and
nitrogen pressurization.
However, there
was
no basis
provided in this analysis
(or any other
document) to
support the selected
level setpoints for the tank.
The
team was concerned that the tank relief valve might not be
, sized to accommodate
flows resulting from coolant thermal
expansion initiated at the level at which makeup supply is
turned off.
This setpoint could be too high to avoid
overpressurizing
the tank should the system
heat
up and
expand at this levels
Based
on preliminary calculations
performed
by ANPP I8C engineering,
the team concluded
that sufficient margin exists in the tank volume to bound
this condition.
However, this observation
remains
open
pending development of final level setpoint'calculations
for the tank.
This is identified as inspection
item
50-528/88-01"10..
Calculation 13-MC-EW-001, Revision 1, dated
September
6,
1985, is
a detailed hydraulic flow network analysis of the
16
EW.
The calculation did not determine
the
NPSH available
to the essential .cooling water
pumps or evaluate
whether
NPSH requirements
had been satisfied.
The licensee
was
unable to find any documented
evidence that this
evaluation
had been performed.
However, the team
independently
determined that sufficient
NPSH was
available to meet
pump requirements.
In general,
the team found that because
of the
use of
conservative
design,
none of the observations
identified as
related to calculations
were safety significant.
However,
these
observations
contributed to the team's
concern that the
depth of design verification is a weakness
in the performance
of design analyses
for Palo Verde safety systems.
Design
verification failed to identify inadequacies
in calculations
or
missing analyses
for all three
systems
selected for review.
Since these calculations
are
used in the development of plant
design modifications, the team was concerned that safety-
related
systems
might be modified in the future without the
foundation of an adequate
design basis to make these
changes.
(3)
Inconsistent
and Erroneous
Desi
n Documentation
ANPP has
developed
a number of documents
and drawings which
have
been identified as design
documents
to be used for design
at
Examples
include system descriptions,
design
criteria documents,
P8 ID's, and system flow'diagrams.
System
descriptions
contain design basis information, design
parameters,
and
a description of the operational
aspects
of the
system.
Design criteria identify detailed design
requirements
related to each
system.
Flow diagrams
contain in'formation
related to operating pressures,
temperatures,
and flows for
various
modes of system operation.
Based
on conversations
with a number of ANPP engineering
personnel,
the team concluded that:
It is not clear to many engineering
personnel;which
documents
are to be used for design purposes.
Conflicting opinions exist
among
ANPP engineering
personnel
as to whether or not system descriptions
and
flow diagrams
are design
documents
which-may be used for
design.
In addition to this confusion concerning
design
documents,
the
team found a number of examples
where design
documents
contained
erroneous
design information.
For example:-
a
~
Essential
Chilled Water System Description,
Revision 3,
dated October ll, 1983.
Table
EC-2 lists 45
gpm as the minimum required
chilled water flow to the Channel
"A" ("8") DC
'17
Equipment
Room Essential
ACU 8HJA(B)-Z03.
However,
flow balancing
Procedure
No.
91GT-OXX99, Revision 0,
indicates
only 39
gpm was provided during testing
and
flow balancing.
Vendor data identifies
39
gpm as the
minimum required flow to this equipment.
ANPP has
issued
a System Description Revision Notice
(SDRN
149, dated February
12,
1988) to correct this error.
Appendix EC-A identifies the rated capacity of the
chiller as
235 tons with a chilled water flow rate of
400
gpm.
However, the vendor drawing indicates
a
flow of 435
gpm is required for rated conditions to
supply the required
44
F chilled water temperature
at
235 tons.
System flow balance testing confirmed the
435
gpm flow rate.
b.
Detailed Design Criteria for Essential
Cooling Water
System,
Revision 5, dated
November 3, 1983.
Section 1.6 indicates
the
EC interfaces with the safety
injection system
and provides cooling to the HPSI,
LPSI,
and containment
spray
pumps.
The team was advised that
this is incorrect.
ANPP has
issued
a Design Criteria
Revision Notice
(DCRN 1026,
dated January
14, 1988) to
delete
the HPSI,
LPSI,
and containment
spray
pumps
as
being directly cooled
by the
EW system.
c.
Essential
Spray
Pond System Description,
Revision 4, dated
September
27,
1984
'ection
2.6.2. 1 indicates
a Limiting Condition for
Operation
as
a spray pond average
water temperature
of
less
than or equal to 110 F.
However, current Technical
Specifications
(TS) indicate the temperature
is limited to
less
than or equal'o
89 F.
ANPP has
issued
a System
Description Revision Notice
(SDRN 150, dated
February 15,
1988) to correct this error.
d.
Essential
Chilled Water P810,
13-M-ECP-OOl, Revision 22.
Note
2 on this drawing indicates that valves
V228, V229,
V230,
and V231 are locked in their throttled position.
However, the team could find no record of the throttled
position required for these
valves.
The team
was advised
that the valves are locked open
and that the
P8ID is
incorrect.
Subsequently,
ANPP issued
a Drawing Change
Notice
(DCN 82) to the
P8 ID deleting this note.
These observations
are not safety significant since the team
could not identify any consequences
of the errors
made which
would impact safety.
However, the confusion concerning
use of
documents
for design
and the errors identified in design
documents
indicates
a weakness
in design basis
documentation.
Use of the erroneous
information in the development of plant
18
design modifications or procedures
could impact safety.
The
licensee
needs to identify actions to resolve ambiguities
between the design basis
documents
and specifically identify
. which documents
are the design basis
documents.
This item is
identified as inspection
item 50-528/88-01-11.
3.
Plant
Im lementation of Desi
n Basis
A.
Reactor
0 erations Activities
The team assessed
the implementation of a sample of design
parameters
and design parameter
changes
in the operations
area
as
well as
normal operation activities.
The specific operations
attribUtes
examined
included
an examination of operator
and
auxiliary operator training for the selected
systems
and design
changes
to the systems,
valve lineup controls,
knowledge of
operating procedures,
adequacy of the procedures,
auxiliary operator
round sheet
adequacy,
and the adequacy of observing
and reporting
plant deficiencies
by operations
personnel.
The examination of these
areas
and the findings are described
below:
(1)
Failure to Translate
Desi
n Features
Into 0 eratin
Procedures
The
EW consists
of two independent
and redundant
safety related.
flow trains.
Each flow train supplies cooling water to a
shutdown heat exchanger
and an essential
chiller during
emergency conditions or to shutdown the plant.
In the event
the nonsafety-related
nuclear cooling water system
(NCWS) is
not available, e.g.,
during a loss of offsite power, the
EW
supplies
cooling water flow to nonsafety-related
components
in
the
NCWS via cross
connecting piping between
each flow train.
The cross
connect valves
on Train A of the
EW are remotely
actuated
motor operated
valves
(MOVs), while those
on Train
B
are. manually operated,
locked cl.osed valves.
The crosstie piping between crosstie
valves
and between
the manual crosstie
valves
HCV 66 or 146, is not
designed
to seismic Category I requirements.
Thus in the event
of a seismic disturbance
when the
EW is supplying the
NCWS, the
integrity of this piping cannot
be assured.
Failure of this
piping could result in draining the
EW coolant inventory and
a
loss of level in the
EW surge tank.
On a low water level in
the surge tank, the motor operated crosstie
valves are
automatically closed.
When the surge tank reaches
low-low
level, the tank makeup valve is closed (indicating a major
system leak).
Although high and low level in the tank is
alarmed,
there is no distinction made between the two alarms
(i.e., the alarm is a hi/lo level alarm).
For this case,
tank
low pressure
would be alarmed,
and
an operator dispatched
to
establish
the cause of the alarm.
Since the
EW pumps are rated at 14550
gpm,
a substantial
portion of the
EW inventory could be lost through the 14 inch
19
cross
connect line during the time required. to close the motor
operated isolation valves.
Further, if Train
B were selected
to supply the
NCWS, more inventory would be drained before the
manual
cross
connect isolation valves could be closed.
In response
to the team's
concern,
ANPP engineering
advised
that when the
EW system is cross
connected to the
NCMS, the
cross
connected
EW loop is declared
in accordance
with TS 3.7.3.
This requires that two loops
be restored "to
OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least
HOT STANDBY
within the next
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."
ANPP engineering
also noted that
operating procedures
reflect this requirement.
The team reviewed Procedure
No.
Revision 5,
Essential
Cooling Mater System
(EW), Train A, which provides
instructions
and guidance to operators for the operation of the
EM.
However, the team found that Section 8.0 of the procedure
which is entitled
"PLACING EW SYSTEM TRAIN A IN SERVICE
ON THE
NUCLEAR COOLING WATER SYSTEM" contains
no directions or
instructions for the operators
to invoke the'required action
statement
under these conditions.
Although Section 9.0 does
include
a
CAUTION to "maintain
EW loops operable
in accordance
with TS 3.7.3," this section of the procedure is used for
removing Train
A from service
on the
NCWS.
The team concluded
that operators
did not have sufficient guidance to invoke
action statement
conditions
when the cross
connection is
initially made.
The licensee
committed to revise the procedure
to assure that operators
had acceptable
instructions for cross
connecting the two systems.
Further,
based
on conversations
with operations
personne],
the
team determined that operators
had differing opinions related
to
EW operability and were not clear
on declaring the system
when the cross connection to the
NCWS is made.
However, in the review of operating history, the team did not
find any case
where the
EW system
(when required
by TS) had
been cross-connected
to
NCMS.
The licensee
in response
to this
concern
issued night orders to all operating
crews at Palo
Verde Units.
Subsequently,
the team discussed
with operators
their understanding
of the problem,
and the selected
operators
indicated that based
on the night order the
EM system would be
declared
inoperable if it was crosstied to
NCWS.
Inade uate
10 CFR 50.59 Evaluation
The essential
serve
as the ultimate heat sink for
the Palo Verde Nuclear Generating Station during emergency
conditions.
They provide sufficient inventory to supply
cooling water to the
SP for 27 days following a
LOCA.
Except
for the cleanup
and chemistry control portions of the system,
the
SP is designed, to seismic Category I requirements.
TMR No. 1-85-CI-377,
Revision 0, dated
September
27,
1985, is a
temporary modification to install tanks to supply hypochlorite
0
20
for the emergency
The
TNR includes
Safety Evaluation for the temporary
change
which addresses
the
effects of this change related to the consequences
of tornado
generated
missiles.
The Saf'ety Evaluation concludes that the
risk associated
with missiles
which might be generated
by the
tank due to the effects of a tornado are lower than those
previously considered for the site.
However, the Safety
Evaluation did not consider the consequences
of a seismic event
which might result in the failure of the plastic tank or its
anchorage
and cause it to fall into the spray pond.
Further,
the
PVC piping to the spray
pond is not seismically anchored.
In the event of a seismic disturbance,
the potential exists for
the piping and the tank to fall into the pond,
where pieces
could break off the tank or its piping.
If some of these
fragments
were sufficiently small, they could pass
through the
screens
protecting the
pumps
and become
lodged in the
pump running clearances,
bearings,
or packing.
There
was
no
analyses
to demonstrate
that failure of the tank and its
associated
plastic piping would not jeopardize
the safety
related
ESP pumps.
USNRC Regulatory Guide l.29, requires that those portions of
structures,
systems,
or components
whose continued function is
not required but whose failure could reduce the functioning of
safety related
systems
to an unacceptable
level should
be
designed
and constructed
so that the
SSE would not cause
such
failure.
In response
to this observation,
ANPP contacted
the
pump
vendor to confirm that
no damage to the
pump would be incurred
as
a result of small
PVC pieces
which might. enter the pump's
suction.
The vendor,
Bingham International, Inc., indicated
that it was unlikely that such fragments
would interrupt the
operation'of the pumps.
The team reviewed
ANPP's evaluation of
the effect on pump
NPSH and discovered that the failure of the
subject'temporary
modification would not adversely affect pump
NPSH requirements.
The inspection
team concerns
may be summarized
as follows:
Because
the subject temporary modification was installed
for over 24 years,
the effectiveness
of the licensee's
quarterly review program which authorized
the temporary
modifications
and continued implementations
should
be
evaluated.
A licensee
determination that other temporary modifications
currently installed meet the design basis
requirements
of
the associated
system,
structure.,or
component
should
be
considered.
A preliminary response
from the licensee
identified that
a specific type of electrical wiring used
in various temporary modifications in the containment
building are
21
not fire retardant,
and therefore,
do not meet design
requirements.
The licensee
should assure
that the current temporary
modification program will not result in changes
that
degrade
the design basis of the plant.
The team concl,uded that performance of 10 CFR 50.59 evaluation
for the temporary modification was inadequate.
This is a
potential violation and is identified as inspection
item
50-528/88-01-12.
Deficient Air Handl in
Unit
On January
7, 1988, the team noted
a significant deficient
.
condition on the Essential
AHU. for the motor driven auxiliary
pump room.
The deficient condition was that an
inspection
access
panel
in the duct work between the chilled
water unit and the ventilation fan was missing.
The intent of
the
AHU is to draw room air across
the chilled water coils in
the unit (thus cooling the air) and then through the fan and
discharge
the cool air back into the
room to maintain
a
satisfactory
temperature
for the essential
equipment, in the
room.
The effect of having an access
panel
missing between the
fan and cooling coils is that
a significant portion of the
recirculated
room air would bypass
the cooling coils.
Consequently,
the cooling capacity of the
AHU is significantly
reduced.
The licensee
was informed of the condition of the Auxiliary
Motor Driven Pump
Room Essential Air Handling Unit
(Component
1M-HAB-Z04) on January
7, 1988, during the
room
examination.
The licensee
was requested
to determine if the
equipment
was in active maintenance
at that time and to take
appropriate
action if not.
Thirteen days later,
on January
20,
1988,
the licensee
declared
the motor driven auxiliary feedwater
pump inoperable
(due to
the missing access
panel
on the AHU).
The
AHU was'repaired
on
January
21,
1988,
and the auxiliary feedwater
pump
declared
The licensee,
subsequent
to the inspection,
through
an
Engineering Evaluation Request
and testing,
determined that the
AHU remained
operable with one access
panel missing.
However, the condition observed,
a missing access
door
on the
AHU, is contrary to 10 CFR 50, Appendix B, Criterion 5, which
states
in part that "Activities affecting quality shall
be
prescribed
by documented instructions,
procedures
or
drawings...and
shall
be accomplished
in accordance
with these
instructions,
procedures
and drawings."
The applicable
drawing
for the air handling unit is American Air Filter Company
4
22
Drawing No. MC-134-942G, Revision
G, which shows the
AHU Access
Doors installed.
The condition observed is
a potential violation, and is
identified as inspection
item 50-528/88-01-13.
The licensee
should include in his response
to the violation a
discussion
of the ancillary problems indicated
by this finding.
Specifically, what plant material condition controls should
have identified this problem earlier (e.g.,
walkdowns by
operator's,
system engineer
and plant management),
why the
declaration of inoperability of the auxiliary feedwater
pump
was delayed for 13 days,
and what corrective actions
are being
taken in these ancillary areas.
Observin
and
Re ortin
of Plant Deficiencies
The team performed walkdowns
and discussed
observed
deficiencies with plant personnel.
The team observed that the system
walkdown discrepancies
had
not been previously identified during the tours routinely
conducted
by operations
personnel
and system engineers.
(These
discrepancies
are
documented
throughout the report, e.g.,
missing
AHU access
panels.)
These discrepancies
were obvious,
but no maintenance
work requests
(MWRs) were prepared for these
items (preparation of a
MWR is the licensee's
normal
mechanism
for initiating corrective actions for discrepancies
found in
the plant).
The plant manager provided the team with a large
package
of MWRs that had been recently prepared
from
discrepancies
that were found by licensee
personnel
to show
that problems
were being identified.
The team acknowledged this effort, but noted that the
licensee's
program for identifying discrepancies
appeared
to be
not fully effective.
In particular,
there
was nothing readily
available to personnel
performing the tours to indicate what
equipment
had already
been identified as needing corrective
maintenance.
With the large
number of outstanding
MWRs, it
appeared
easy for personnel
to think that
a deficiency had
already
been entered into the system.
Also, it was easy for
people to become distracted
by other activities and forget to
write a
MWR.
This concern
was discussed
with the licensee
management
who indicated that they used "deficiency tags" to
identify discrepancies
through the construction
and startup
phases.
However, it was found that this method
had problems
and the program
was terminated.
However,
as
a result of the
team's
concern,
ANPP management
stated that they would evaluate
the effectiveness
of their present
program for identifying
deficienci'es.
The licensee
s evaluation will be reviewed in a
future inspection
and is identified as inspection
item
50-528/88-01-14.
23
(5)
0 eratin
Procedures
The team examined selected
operating procedures
for general
adequacy
and to determine if selected
design criteria (for the
systems
examined)
had been properly implemented in the
operating procedures.
In general,
the procedures
were found to be clearly written,
reasonably
structured for ease of use,
and contained
proper
verifications where applicable.
The particular procedures
examined
were operating procedures
for the three
systems,
SP,
EW, and
EC (including valve lineups)
and auxiliary operator
round sheets.
Certain positive
and negative findings were
made
as discussed
below:
a.
Procedure
Stren th
Re ardin
Procedure
Feedback
Re orts
The licensee
appears
to have
an effective,
easy to use
vehicle to allow plant personnel
to suggest
changes
to
procedures.
The licensee's
system,
called the "Procedure
Feedback
Reports," allows any member of plant staff to
formally suggest
a procedure
change,
have that suggestion
evaluated,
and receive
a disposition of his suggestion.
Procedure
change
suggestions
are evaluated
by the
procedure writing 'group (for operations,
The Operations
Standards
Group)
and implemented in all three units if
applicable.
b.
Procedure
and Hardware
Weakness
Re ardin
~Res
oose
Control
Room observations
by the team led to the
conclusion that operator
response
to nuisance
alarms
was
being performed inappropriately,
and further,
an
administrative procedure to describe
the proper response
expected of operators
did not exist.
As an item of background,
the number of annunciators
"in"
at a given time is a well discussed
issue with the
licensee,
has
been discussed
with licensee
management
at
several
regional
meetings
and the licensee's
corrective
actions regarding annunciator reduction are well
documented
and underway.
The team's
observation
did not
deal with this issue.
The team observed
10 to 12 annunciators
in "fast flash,"
but with no audible alarm.
The reason that this condition
is inappropriate is that each annunciator
window can and
usually does
have
more than
one input.
Four or five
inputs per window is typical.
At Palo Verde,
due to the
nature of the annunciator'wiring logic, when
an
is in "f'ast flash" due to a
known recurring
I
24
nuisance
alarm (one input), it is nonetheless
precluded
from warning the operators
of an adverse
condition from
one of the other possible
inputs to the window.
That is,
fast flash precludes
other inputs from annunciating.
The annunciator circuitry at Palo Verde allows the
operator to acknowledge
the alarm partially by pushing
a
button which stops
the audible alarm.
This is a sensible
human factors feature which reduces
noise level but leaves
a flashing window to alert the operator that the condition
existed.
However, leaving the window in that condition
would blind the operator to further inputs to the
Nuisance
alarms
are
an occasional fact-of-life due to the
number
and complexity of alarm circuits.
It is equally
poor to have operators
spend their time continuously
answering
a spurious frequently occurring "alarm, diverting
them from other duties.
Therefore,
most sites
have
a method by which a single
nuisance
alarm input to an annunciator
window can be
removed from service until the problem is found and fixed,
but leaving the other inputs to the window active and able
to cause
a "reflash."
Palo Verde did not have
such
a
method at the time of inspection.
It should
be noted that the operators
are not totally
blinded to the other inputs to an annunciator in fast
flash.
They also
have
CRT displays which will print any
alarm coming in, and dependent
on the attentiveness
to
this screen,
the input could be noted.
However, this
screen
does not have
an audible alarm and consequently,
the'probability of rapid recognition of a
new input is
reduced.
In response
to the above observations,
the licensee
committed to examine other methods of dealing with
nuisance
alarms,
which wi 11 preserve
audible annunciation
of other inputs,
and to examine proceduralizing
the
expected
operator
actions in dealing with nuisance
alarms.
This item will be followed up in a future inspection
(inspection
item 50-528/88-01-15).
0 eratin
Procedures
Not In A r cement With Hi her Order
Desi
n Documents
The team examined selected
operating procedures
for
agreement
with higher order design
documents
to ensure
that design information was properly implemented in plant
procedures.
The design input documents
examined
were the
P8 IDs for the
SP,
EW, and
EC systems
and the vendor technical
manual for
25
the
for
Log
Essential
Chiller Units (Carrier Instruction Manual
19FA Hermetric Centrifugal Liquid Chillers - Bechtel
No.
13-10407-M723-213,
Revision 12).
The team identified several
instances
where design
document requirements
were not properly implemented in
procedures
and was informed by operations
standards
personnel
of an improper latitude taken
by the group to
change
procedures
in advance of having design
documents
changed.
Specific Examples of the above are:
S ra
Pond Crosstie
Valves
The normal operating position of spray pond crosstie
valves
HCV-207 and
HCV-208 were changed in operating
procedures
(e.g.,
from a normal position
of "open" to a normal position of "closed" in
Revision
1 to the procedures
issued
August 16,
1984.
The controlling design
document,
P8ID 13-M-SPP-001,-
was not likewise changed until much later,
specifically by
DCN 65 to 13-M-SPP-001,
Revision 16,
issued
December 8, 1987.
The
P8 ID should
have
been
changed
before the implementing operating procedures
were changed.
Ex ansion
Tank Water Level
Ga es Isolation Valve
Positions
Im ro er
P8ID drawing 01-M-ECP-001,
Revision 10,
a controlling
design
document for the
EC,
has
a note for expansion
tank level
gages
LG 19 and
20 that states,
"Open
LG
inst valves for test only."
This appears
to be an
appropriate
note since the
P8 ID shows that the level
gages
are non-seismic
attachments
to the seismically
designed
expansion
tank.
The team examined
these
valves
and found them to be open contrary to the
P8ID.
Fur ther, the operating procedures
41 OP-1
EC
Ol, 02 require these
valves to be normally open
(Appendix E) contrary to the
PAID.
During the inspection,
the licensee
examined the
situation
and determined that leaving the level
gage
isolation valves
open
was satisfactory
due to flow
restriction devices
and issued
DCN 81 to
13-M-ECP-001,
Revision 22,
on January
28,
1988, to
rectify the situation
by changing the PAID.
A similar situation
was noted by the team
and
corrected
on the Essential
Cooling Water expansion
tank level
gage isolation valves, by
DCN 39 to drawing
13-M-EWP-006, Revision 14, issued
January
28,
1988.
The operating procedures
should not have
been
issued with
requirements
different than those
shown
on the
P8 ID.
The
responsible
procedures
group personnel
and supervision
indicated to the team that changing
implementing
procedures
prior to requesting
engineering
approval to
P8 IDs is not uncommon.
The procedures
group indicated
that engineering
concurrence
can sometimes
take
up to a
year to obtain.
The team discussed
the need to have
a
clearly understood
and implemented
design
document
hierarchy
and that changes
to implementing procedures
without clear documented
engineering
approval
was
inappropriate.
Licensee
actions
in this regard will be
reported in a future inspection report.
This is
identified as inspection
item
50-, 528/88-01-16.
d.
Essential
Chiller Sum
Oil Tem eratures
Im ro er
The team examined
the vendor technical
manual for the
essential
chi llers.'hese
are large self-contained
refrigeration units which provide chilled water for
essential
room cooling.
The team also examined the auxiliary operator
round sheets
in the areas pertaining to the chiller units to verify
that operators
were indeed checking operating
parameter
values
recommended
by the vendor (or officially changed).
The team found that the chiller oil
sump temperatures
were
not being checked for the'roper
temperature
values.
The vendor
recommends
a
sump oil temperature
of 140-
150'F maintained
by electric heaters
when the unit is in
standby conditions.
However, the auxiliary operator log
sheets
check that
sump oil temperature
is 130 - 170 F,
which is not in agreement with the vendor recommendations.
Hi
h Oil Tem erature
At the close of the inspection,
the licensee
committed to change
the Operating
Department
Guideline
(ODG) No.
15 to reflect the proper
high oil
temperature
value
(150
F vs 170 F).
The licensee's
tracking of this item is considered sufficient and
further
NRC tracking does
not appear warranted.
Operations
personnel
stated that high oil temperature
had not been
a problem (i.e.,
above
150 F).
Additionally, the chiller operating procedure for
manual start
(410D) contains
the proper values for
sump oil temperature.
27
Low Oil Tem erature
Although the auxiliary operator
round sheets
(ODG-15)
required the operator to check that the
sump oil
temperature
was greater
than 130~F,
whereas
the
vendor required 140'F, the licensee
demonstrated
that
they had processed
a change (after contact with the
vendor) to authorize the change.
Specifically,
Engineering Evaluation Request
EER 87-EC-007
was
initiated February
28, 1987,
and approved July 17,
1987, which recommended
the
ODG-15 change.
However, in reviewing the supporting information, the
team noted that the vendor's letter of response
to
the licensee
dated
June
30, 1987, stated that they
had "no problem" with the licensee's
change,
but added
"however, with the cooler startup temperatures,
oil
foaming could become
a problem, this in turn will
cause
the chiller to trip on oil pressure
during
these startups."
The team discussed
this apparent
di,sclaimer
by the vendor with the system engineer.
The system engineer
considered that Palo Verde had
sufficient operating experience with their essential
and non-essential
chillers to show that low oil
pressure trips
on starting would not be
a problem.
Im ro er 50.59 Review of Oil Tem erature
Chan
e
In view of the vendors
apparent disclaimer,
the team
reviewed the
10 CFR 50.59 evaluation
done for EER
87-EC-007
on July 8, 1987.
That review requires'he
engineer to determine if the "probability of. a
malfunction of equipment
important to safety
be
increased.""
In this case,
the engineer
checked
"no"
and thus precluded the licensee's
Plant Review Board
(PRB) from agreeing
or disagreeing with this
decision.
The licensee
committed to further resolve with
the vendor. whether
an increased probability of low
oil pressure trips on starts is an actual
concern
and to have that decision properly reviewed by the
PRB.
This is an unresolved
inspection
item
50-528/88-01-17.
Weaknesses
in Precise
Acce tance
Values
on Round Sheets
Although operator
round sheets
were structured to tell the
operator
specific parameters
to be checked with the
acceptance
values,
several
examples
were noted where the
information was not precise.
In accompanying
an auxiliary
operator
on rounds,
the team determined that the required
values
were not clearly understood
and assumptions
were
made.
28
Although no operability questions
were raised
from further
examination,
the licensee
committed to revise the round
sheets
to describe
more precisely the parameters
required
to be checked.
Examples of lack of preciseness
are:
Freon level, in X of sightglass,
was given only for
the high level (75K); no value
was given for low
level.
Compressor oil level, in X of sightglass
was given as
25 to 50K, whereas
there is no sightglass
installed
but rather two bullseyes.
The operator explained
what 25 to 50K "probably meant."
In view of the licensee's
commitment,
no specific
NRC
'follow-up of this item is considered
warranted.
(6)
0 erations Trainin
on Desi
n Chan
es
The area of operations training has
been previously examined at
Palo Verde and is the subject of ongoing actions for
improvement.
For this inspection,
the narrow subject of design
change
implementation training was examined.
Specifically, for
selected
design
changes,
were operations
personnel
trained
on
the changes prior to operating
changed
systems.
Two DCPs were selected
dealing with changes
in alarm setpoints
for the Spray
Pond Level
and Temperature, i.e.,
85-01-,SP-037-00
and
PCP 85-01-SP-025-00.
The 1985 design
changes
were completed
and accepted
on November 18,
1986 and
January
7, 1986, respectively,
indicating all work was done,
testing completed
and necessary
procedures
changed.
The team reviewed the most recent training lesson plan for the
subject.
That was
Lesson Title Essential
Cooling Water and
Spray
Ponds
(NLC 22-00-RC-013-0A),
Revision A, dated July 19,
1987.
The team found that the training lesson plan (revised at least
seven
months after the design
change
acceptance)
did not
reflect the proper alarm setpoint for spray pond temperature
(Reference training plan page
27, Item B. l.a., "Instrumentation
and Alarms" ).
The training plan referenced
the spray
pond
temperature
high alarm as 95'F whereas
the technical
specification limits the temperature
to 89~F and 'the design
change
had lowered the alarm setpoint to 87 F.
However, the
same training plan described
an "administrative limit of" 89'F
(reference training plan
Page
2 Objective E014).
Further investigation revealed that the training department
administrative control method for factoring in design
change
information to training is described
in Procedure
No.
29
8I718.07.05,
Revision 0, dated July 28,
1986,
"Updating
Training."
For design
changes
the system
depends
on a member
of the training department,
the training auditor, to review all
design
changes
and determine if the information is pertinent
for training.
In the case of the two design
changes
examined,
the team found
that the training auditor had reviewed the changes
on
January
29,
1986 and October 29, 1985, respectively,
and
determined that there
was
no impact
on the training program,
procedures,
or activities.
This apparently
erroneous
decision
was discussed
with the training auditor who stated that
he
understood
the setpoints
were not taught in training.
Based
on
that decision,
he did not .forward the design
changes
to
training personnel
for incorporation in lesson plans.
The training manager
committed to strengthen
the design
change
review process.
The tr'aining manager also indicated that the
training department
does not generally review design
changes
for training changes until after they are completed.
He
further indicated that in the case of operations,
the
operations
department is depended
on to provide the information
to the operators
in a timely way,
and that training may take
several
months to factor in and administer training on changes.
The operations
department
manager for Unit 1 indicated that
pertinent. information was passed
on to the operators
in several
forms, specifically night notes
and incident reports.
Additionally, he stated that procedure
changes
are required to
be read
and initialled but that
no systematic training on
design
changes
was performed,
but was probably largely covered
by the procedure
change
reviews.
The licensee
committed to examine the training given in regards
to design
changes,
with'mphasis
on
a systematic
method of
ensuring
necessary
information is provided to operations
personnel
when changes
are
made to the systems
they are
operating.
The area will be examined during
a future
inspection.
This is identified as inspection
item
50-528/88-01-18.
B.
Maintenance Activities
The team reviewed the licensee's
corrective
and preventive
maintenance
programs.
This was accomplished
by performance of
system walkdowns,
review of equipment configuration control, review
of the role of system engineers
in the maintenance
process,
observation of maintenance activities,
and
a review of maintenance
data.
In addition, the team reviewed selected
portions of the
licensee's
operating
experience
review program
as it related to
specific maintenance activities.
30
(1)
S stem Walkdowns
The team conducted
walkdowns of the
EC Train A, the
EW Train B,
and various other peripheral
mechanical
and electrical
components,
such
as electrical
panels
and terminal
boxes which
supply power to components
in these
systems.
The purpose of
.
these
walkdowns
was to compare the as-built status of the plant
to the design drawings,
review the cleanliness
of the system
components
and areas,
and to determine
the operability of the
systems
from a maintenance
standpoint.
In general,
the components,
systems,
and areas
inspected
appeared
satisfactory
from a housekeeping
standpoint.
However,
during these tours,
numerous
discrepancies
were found.
An.
example of these
discrepancies
was temperature
elements
EW
TE 154 and 156,
and their respective
terminal box,
1MEWNPOlBT,
for the bearings
on,the "B" Train
EW pump.
These
showed signs
of internal corrosion
due to excessive
water leakoff from the
bearings
on the
pump.
This in-leakage
appeared
to have
been
occurring for quite
a long time.
Discussions
with the system
engineer indicated that the bearing leakoff had, at times,
been
extreme.
It was obvious that
no effective corrective action
had been
implemented
due to the amount of corrosion within
these
components.
The system engineer stated that
a design
change
had recently been submitted to change to a mechanical
seal
on the
pump (this change
should preclude
leakage of water
into these
components).
Other examples of deficiencies
consisted of dirt, debris,
and construction
acceptance
tags
found in junction boxes
and breaker enclosures..
More
noteworthy discrepancies
are discussed
in the paragraphs
below.
All discrepancies
found during the system walkdowns were
identified to the licensee for corrective action.
(2)
E ui ment Confi uration Control
During the performance of system walkdowns, the team noted
a
number of equipment configuration control problems.
The team
toured the
EC and
EW system
rooms in addition to the vital
battery, battery charger,
and static inverter rooms.
The
problems identified to the licensee
were
as follows:
Electrical
Panels
Missin
Bolts
Several
panels
and breaker enclosures
were found to have
missing cover bolts.
In particular, vital static inverter
1-E-PND-N14 was missing
9 of the
19 cover bolts
and vital
static inverter 1-E-PKD-N44 was missing
12 of the
19 panel
cover bolts.
This configuration was not in accordance
with drawing 543-201-4.
The team questioned
the licensee
as .to the ability of panel
1-E-PND-N14 to withstand
a
seismic event under 'this configuration.
This item is an
additional
example of a potential violation, inspection
item 50-528/88-01-19.
31
b.
Vital Batteries
The team found that the 120
VDC Class
1E vital batteries
were installed in accordance
with the vendor
recommended
design
and design
drawings with one exception.
The one
case identified was the lack of, the cylindrical plastic
spacers
which were required to be located
between
some
battery jars in accordance
with drawing 13-10407
EA-15467,
Sheet
3 of 6,
and drawing E050-86,
Sheets
1 and 2.
In
particular, vital battery "A" was missing two spacers,
vital battery "D" was missing two spacers,
and vital
battery "B" was missing three spacers.
The team discussed
the requirements
for these
spacers
to be installed with a
battery manufacturer
representative.
These discussions
revealed that the spacers
were inserted
between the jars
during initial installation of the batteries.
They were
required for alignment only and serve
no other purpose
such
as seismic restraint.
However, the team
was
concerned that these
spacers
were
somehow
removed
and
design
drawings were not updated to show this
configuration chang'e.
The lack of control over the
configuration of these
components
is a further example of
a potential violation and is identified as inspection
item
50-528/88-01-20.
c.
Batter
E ewash Stations
During the tours, the team noted that the licensee
had
installed permanently
mounted battery
eyewash stations
in
the vital battery
rooms.
The team questioned
the ability
of the mounting configuration to withstand
a seismic event
from a position retention standpoint (licensee's
seismic
category
9 requirement).
The team requested
the
calculations/documentation
for the eyewash station's
qualification.
The licensee
reviewed existing
documentation
and found that the calculation isometric
drawings did not show the existing configuration for the
eyewash stations.
Therefore,
the licensee
performed
an
engineering
evaluation of the existing eyewash
configuration to satisfy the team's
concerns.
The results
were documented
in engineering evaluation
request
(EER)
88-DS-001
and 88-DS-002.
In these
documents,
the licensee identified that the
existing configuration met seismic category
9
requirements.
However, the licensee
also identified that
there were discrepancies
between the as-built
configuration and the design
drawings for all
3 Units.
The discrepancy
was that the existing drawings only showed
the main header
up to the work point (first couple of pipe
supports) for the emergency
shower
and eyewash stations.
The last
10 feet of piping was field installed,
but the
calculation isometric drawing,
13-MC-DS-511,
was not
revised to show the arrangement
of the eyewash stations.
32
As a result,
the actual
mounting arrangement
could vary in
distance
from the wall or in height of the station.
This
would alter the actual
loading to some degree.
Also, one
of the eyewash stations
only had one pipe support.
The
remaining three stations
had two.
The calculations
were
based
on
a standard configuration which was different than
the actual installed configuration.
Therefore,
the
calculations
had to be re-performed to verify that the
stations
met seismic category
9 requirements.
Again, the team
w'as concerned that the missing battery spacers
and
the missing bolts from the static inverters
had not been previously
identified and, indicated
an inadequate
thoroughness
in work
completion by maintenance
personnel,
and closeout verification by
gC.
Tours were conducted
on
a routine basis
by operations
personnel
and system engineers,
in addition to the performance of preventive
maintenance
and surveillance activities
on these
components
by
personnel.
The team considered that in addition to an evaluation
of the effectiveness
of their program for performing system
walkdowns, the licensee
should evaluate
the tr aining that
maintenance
and surveillance
personnel
receive
on restoration of
equipment to its original configuration.
The licensee's
program for
restoration of equipment will be further evaluated.
The lack of'icensee
controls over the configuration of these
components
is another
example of a potential violation and is
identified as inspection
item 50-528/88-01-21.
(3)
Observations
and Review of Maintenance Activities
The team reviewed Preventive
Maintenance activities
(PMs) for
selected
pumps, valves,
and instruments
in the essential
cooling water, essential
chilled water,
and spray
pond systems.
The team also reviewed
PMs and surveillances for the vital and
emergency lighting batteries
and observed
maintenance
in-
progress
on other components.
This was
done in order to
determine if the equipment
had been properly maintained
and
vendor
requirements
were reflected in the licensee's
programs.
The observed
PM and corrective maintenance activities were
on
the stuck control element
assembly, vital and emergency
lighting batteries,
and the battery charger.
The team verified
that the required administrative approvals
had been obtained
prior.to initiation of work, that independent verification
requirements
were established
and performed
(when required),
that the craft identified discrepancies
and anomalies properly,
and that corrective actions
were initiated when discrepancies
were found.
a.
Emer enc
Li htin
Batteries
During a tour, the team identified a substantial
amount of
negative plate degradation
in the Unit 1 and
2 emergency
33
lighting batteries.
This was evidenced
by negative plate
material that formed a sediment at the bottom of the
battery jars.
This sediment
was attracted to the positive
plates
and formed an internal discharge
flowpath (short
circuit) within the jars.
The team identified this
concern to the licensee
for the Unit 1 batteries,
1E-QDN-F01 and QDN-F02.
Coincidentally, the annual
burn
(capacity) test for these batteries
was
due in February
1988.
The licensee
conducted
the test
and fouhd the
batteries
to satisfactorily meet their capacity
requirements
established
in
Task No.
054992.
The requirements
established
a voltage
minimum of 107
VDC
and
an illumination minimum of 6 foot candles for lights
in the control
room horseshoe
area.
Upon completion of
the test,
the licensee
attempted to perform an equalizing
charge to restore
the batteries
to their fully charged
state.
However, the batteries
could not be recharged
after the test because
of the significant degradation
which was apparently
due to float charging at too high a
voltage
or other
unknown factors.
In 1986, the licensee identified in licensee
event report
(LER) 86-59 and Supplement
1 to the
LER, that
PMs had not
been performed
on batteries
lE-QDN-F01 and QDN-F02.
In
this
LER, the licensee identified corrective actions to be
taken to ensure that these batteries
were tested at
required frequencies.
Since then,
ANPP had been
performing
PMs on these batteries,
but nobody had
evaluated
the results of those
PMs to determine if a
negative trend was in progress.
For additional corrective actions of a generic nature,
the
licensee identified in a memorandum
dated
June
17, 1987,
that they had evaluated
the adequacy of the testing
programs for other
non
TS components.
The team reviewed
this memorandum
and noted that the licensee
only
identified that
PMs existed for these
non
TS items.
They
did not verify that the
PMs were in fact being performed
at the required frequencies.
The team noted that
procedure
30AC-9ZZ02, Revision 4, "Preventive
Maintenance,"
allows for waiving non
TS related
and
non
licensing commitment related
up to 3 consecutive
times
by the planner coordinator.
The team did not find any
evidence that this information
(PM waiver) was supplied to
the system engineer or any central point of contact.
As a
result,
the team
was concerned that
a valuable
source of
trending data could be waived without responsible
engineering
personnel
being aware.
Review of the
licensee's
PM program with regards
to the practices of not
trending maintenance
and test results
and of waiving PMs,
in particular, with respect to batteries
lE-QDN-FOl and
QDN-F02, will be reviewed in a future inspection effort
and is identified as inspection
item 50-528/88-01-22..
0
34
120
VDC Vital Batteries
The team verified that proper survei llances
were performed
for the
120
VDC vital batteries
in accordance
with
In addition, the team verified that these
batteries
were maintained in accordance
with the
manufacturer's
recommendations
with one exception.
The
team found that the licensee
had
no criteria for selecting
battery pilot cells.
The vendor
recommended that pilot
cells (used to monitor average battery jar performance)
be
selected
based
on certain criteria and changed yearly.
The yearly change of cells was
recommended
in order to
prevent
removal of too much electrolyte which could effect
the jar performance
and
skew surveillance results.
The
team found that nobody
knew how the pilot cells were
selected.
Apparently during startup,
the engineer
established criteria and selected
the pilot cells.
However, after the plant was licensed,
the. responsibility
for performance
of tests
was switched to the surveillance
program.
At that time, the criteria for selecting pilot
cells was
removed
from the surveillance test.
As a
result,
the
same cells
have
been
used
as pilot cells since
then.
The team identified this concern to the licensee.
The licensee
committed to update their program to assure
acceptable pilot cell selection.
No further followup is
necessary:
The team
was concerned that the vital batteries
may be
susceptible. to similar degradation
of the plates
as
was
found on the emergency lighting batteries
because
of the
high float voltage that the vital batteries
experience.
The licensee
set the float voltage criteria at 134 to 136
volts.
This was
done in response
to electrolyte
stratification that
had been experienced
at lower float
voltages.
The reason for this stratification was never,
identified.
For corrective action,
ANPP obtained
vendor
concurrence
to operate
the batteries at the higher float
voltage.
However, operating the batteries at.a higher
float voltage could have impact on their operable lifetime
and
any deleterious
effects of operating at this higher
range would go unnoticed in the absence
of a formal
trending program.
The licensee
responded
to the team's
concern
by stating that they would evaluate
the
possibility of operating the batteries
in a lower float
voltage range.
In addition, the licensee
indicated that
they were in the process
of gathering information from the
system engineers
to further
advance
the status
of the
trending program.
The fact that the maintenance
department,
the surveillance
department,
or the system engineer did not know how or
who
selected
the pilot cells or that nobody was concerned
about the
state of the emergency lighting batteries until the
NRC raised
0
35
a question,
were examples of the poor coordination
between the
various organizations.
Data
Base
Reviews
The team reviewed the outstanding
maintenance
work request
and
maintenance
work order list for Unit 1.
The licensee
was
generating
MMRs at the rate of about
120 to 150 per week for
Unit 1 only.
Thus, there were
a substantial
amount of
outstanding
items.
Most of the items reviewed
by the team
seemed to be minor in nature.
The licensee
indicated that
these
would be worked as time permitted.
However, the backlog
of maintenance
items
has
been
a continuing source of concern
within Region
V.
The team reviewed the implementation status of the nuclear
plant reliability data
system
(NPRDS).
As of this inspection
pe'riod,
the licensee
had completed the data
base for all three
Units.
The Institute for Nuclear
Power Operations
(INPO) had
accepted
99K of the data
base for Unit 1, with the other
two
Units to follow.
The licensee
was in the process
of inputting
the failure analysis for the three Units.
ANPP had the ability
to retrieve information on failures at other sites.
However,
the team noted that they were not retrieving this information
on a systematic
basis
since the
NPRDS utilization had not been
initiated as of this inspection.
0 eratin
Ex erience
Review Pro
ram
The team attempted
a review of the licensee's
program for
maintenance
and surveillance of system
manual isolation valves.
However, the team found that the licensee
did not have
a
program to perform surveillances
(e.g., stroking) or
PMs (e.g.,
stem lubrication) of these
type valves.
Examples of these
were
the spray pond cross
connect valves
and locked manual
system
isolation valves.
Discussions
with the licensee
indicated
that they only check valve position of these
valves.
This issue
was discussed
in IE Notice 86-61, "Failure of
Manual Isolation Valve," which was issued
July 28,
1986.
This IE Notice discussed
the failure of manual
isolation valves (in particular,
(AFM)
manual isolation valve)
due to the lack of a preventive
maintenance
program.
In this case, it resulted in the valve
being inadequately
lubricated which caused
the valve to seize.
This item was also discussed
in NUREG-1195, Section 5.3.
The team questioned
the licensee to determine
what actions
they had taken to address
the concerns identified in IE Notice
86-61.
In this case,
the Licensing Department which was
responsible for tracking the item,
and the independent
safety
engineering
group (ISEG), which was responsible for initial
review of the Operating
Experience
Review item, sent this
Notice to the Maintenance
Department
and requested
that
a
36
review be
made to determine if corrective actions
were
required.
However,
as of this inspection period,
no response
had been sent to Licensing.
The team reviewed procedure
ES05.03,
Revision 0, "Operating Experience
Review,"
and noted
that, in the case of major concerns,
responses
were required to
be sent back to Licensing within 30 days.
Major concerns
were
considered
to be IE Bulletins or high priority IE Notices.
Discussions
with the licensee
indicated that actions
on the
information provided in this Notice were considered
to be
of'ow
priority.
The team did not dispute this, but was concerned
that more than
a year
and
a half had elapsed
since the issuance
of this Notice without -any corrective actions identified (not
even
a response
from the responsible
organization).
The
licensee
stated that informal discussions
had taken place.
It
was believed that this was
a problem that was unique to the
site identified in the IE Notice; but, it was not a problem at
Palo Verde.
In addition, it appeared
that
no final decisions
were
made
and that nobody was quite sure
when these
informal
discussions
had taken place.
As a result of the team's
concerns,
the licensee
indicated that
they would review this item to determine if and
how a program
'should
be implemented to perform
PMs and/or surveillances
on
system
manual isolation valves.
The licensee's
evaluation will
be reviewed
and is identified as inspection
item
50-528/88-01-23.
The Licensing Department indicated that, in general,
long
overdue
responses
to the licensing commitment tracking system
(LCTS) are flagged to the responsible
organization.
Flagging
of this particular item to the responsible
organization
was not
verified by the team.
The team
had several
additional
concerns
over the licensee's
operating experience
review program:
(1)
the program allows
an infinite amount of time for the
responsible
organization to make
a response
on non high
priority items,
(2) the long lack of a response
was not
identified to the next higher level of management
for
resolution,
(3) the licensee
did not review this Notice with
sufficient detail to determine if it was applicable to Palo
Verde and,
(4) the seriousness
of the loss of ability to
operate
a system
manual isolation valve was apparently
not
considered.
The team identified these
concerns
to the licensee
for evaluation.
This evaluation will be reviewed
and is
identified as inspection
item 50-528/88-01-24.
(6)
Motor 0 crated Valve Testin
Discussions
with ANPP personnel
indicated that several
motor
operated
valve
(MOV) motors were found to be marginally sized
to perform their function.
These
motor operators for MOVs
SI-604 and SI-,609, in the safety injection system for all
3
Units, were subsequently
replaced.
The improper sizing was
found during performance of motor operated
valve analysis
and
testing
(MOVATs) of these
valves.
The team discussed
the
37
licensee's
program for performing testing of motor operated
valves.
The valves required to be tested
"Motor Operated
Valve Common
Mode Failures
During Plant
Due To Improper Switch Settings,"
have
been
completed.
However, the team questioned
the licensee
to
determine if they planned to extend their valve testing program
to all safety-related
valves.
This was
due to the team's
concern that marginally sized motors or associated
problems
with other safety-related
valves could exist.
The licensee
stated that they were evaluating the
need to extend the
MOVATs
program to other valves.
The licensee',s
evaluation will be
reviewed in the future.
This is identified as inspection
item
50-528/88-01-25.
Surveillances
Instrument Calibration
and Monitorin
Pro
rams
(1)
Surveillance
Pro
ram
The licensee's
surveillance
programs for the
EW, the
EC,
and
the
SP were reviewed to determine their conformance with, the
plant
TS surveillance
requirements.
The following procedures
were examined
by the team:
Procedure
73AC-9ZZ04, "Surveillance Testing"
Procedure
73AC-1ZZ24, "Technical Specifications
Surveillance
Requirements
Cross-Reference
- Unit 1"
The first procedure
describes
the methodologies
and
responsibilities
requisite to the administration
and
implementation of the surveillance
testing program.
The second
procedure
provides
a complete cross-reference
of the Unit 1
standard
TS surveillance
requirements
and associated
test
procedures.
The following TS surveillance
requirements
were reviewed along
with the licensee's
implementing
and surveillance
procedures:
TS Section 4.0.5, "Surveillance
Requirements
for Inservice
Inspection
and Testing of ASME Class
1,
2 and
3
Components"
The team discussed
the
engineer
and examined the following two procedures
which
are applicable to the three Class
3 systems
(EW,
EC,
and
SP) under inspection:
Procedure
No. 73TI-9ZZ13, "Visual Examination for
Leakage"
t
Procedure
No. 73TI-9ZZ18, "Visual Examination of
Support
Components"
38
The NDE'rogram requires
a visual examination for leaks
during a functional/pressure
testing of Class
3 piping
systems
every ten years.
Welded attachment
and pipe
supports/hangers
on piping systems
greater
than
4 inches
in diameter shall also
be inspected
every ten years.
One-third of the Class
3 piping systems
and supports
are-
inspected
in a three
and
a half year period.
Since Unit 1
is still in its first three
and
a half year period,
no
inspections
of the
EW,
EC,
and
SP systems
have
been
made.
The inspection effort to date
has
been devoted to the
Class
1 and Class
2 piping systems.
The team examined the programs
for functionally testing
pumps
and valves
as described
in Procedure
"Inservice Testing of Safety Related
Pumps
and Valves."
Pumps
and check valves are functionally tested quarterly
(every 90 days)
under the following surveillance test
procedures:
"Essential
Chilled Water
Pump
Operability"
"Essential
Cooling Mater
Pump
Oper abi 1 ity"
"Essential
Spray
Pond
Pump Operability"
73ST-1ZZ05, "Section XI Check Valve Operability,
Normal Operations"
Some twenty-seven surveillance
records for pumps
and check
val.ves performed over the past two years in the three
systems
under inspection
were examined to verify
compliance with TS requirements.
The records
appeared
to
satisfy the
TS requirements
and conformed to the
surveillance
procedures.
The relief valves are off-line set
and pressure
verified
every five years in accordance
with Procedure
"Section XI PSV Off-Line Pressure Verification."
During
the first refueling outage,
three relief valves
SPAPSV-0029,
SPBPSV-0030,
and
SPAPSV-0141
on the
system were set
and pressure
verified.
These
are the only
relief valves of the systems
under inspection tested to
date.
The surveillance test
packages
for these
valves
were examined
and found to conform to the above procedure.
The following TS surveillance
requirements
with the
applicable
implementing procedures
were inspected
by
examining the appropriate
procedures
and reviewing past
surveillance
records:
TS 4.7.6. 1, "...demonstrate
two
ECW loops operable
every
31 days
by verifying positions of those valves
39
(manual,
power operated,
or automatic) -- not locked,
sealed
or otherwise
secured
in position."
This
surveillance
requirement was.performed
under
procedure
41ST-lECOl, "Essential
Chilled Water Valve
Ver ificati on. "
The following surveillance
requirements
were
performed under surveillance
procedure
"Locked Valve and Breaker Control."
"Once per
18 months during shutdown, verify that
each valve (manual,
power-operated,
or
automatic) servicing safety-related
equipment
that -is locked, sealed,
or otherwise
secured
in
position, is in its correct position for:"
Two independent
essential
cooling
water loops.
Two independent
essential
spray
pond loops.
Two independent
essential
chilled
water loops.
"At least
once per 31 days
by verifying that
each valve (manual,
power-operated,
or
automatic) servicing safety-related
equipment
that is not locked, sealed,
or otherwise
secured
in position, is in its. correct position."
Two independent
essential
cooling
water
loops.
TS 4.7.4. 1
Two independent
essential
spray
pond loops.
TS 4.7.3.C-
"The ultimate heat sink shall
be
determined
OPERABLE at least
once per
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
by verifying the average
water temperature
and water depth to
be within their limits for each
essential
This
surveillance
requirement
was performed
under procedure
"Routine
Surveillance Daily Midnight Logs."
"At least
two essential
cooling water
loops shall
be demonstrated
OPERABLE:
At least
once per 18 months duiring
shutdown
by verifying that the
essential
cooling water
pumps start
on
an SIAS test signal."
This'urveillance
was performed for "B"
40
train under
procedure
"Class
IE Diesel Generator
and
Integrated
Safeguards
Surveillance
Test - Train B."
The different procedures
for the various
TS surveillances
appeared
to be adequate
and the surveillances
test records
were complete in their content.
Of the many surveillance
records
sampled
(over sixty) for the- above
TS, all were
readily recovered
from the files, and none were missing.
Surveillances for 4160 Volt and 480 Volt Switch ear
and Motor
Control Centers
The surveillances for 4160 Volt switchgear relays are
described
in "Guideline for Frequency of Relay Testing,"
No. 14-3-1,
dated
December
14,
1981.
The 4160 Volt switchgear relays
are calibrated
and tested
on four year intervals.
The calibration
and test records
performed in August 1984 for the relays of circuit
breakers for two
EW pumps,
two SP pumps,
and two
EC
chillers were examined
and appeared
to be in order.
The periodic testing of trip settings for 480 Volt
switchgear
and motor control center circuit breakers
are
accomplished
under preventive
maintenance
(PM) work orders
as described
in Procedure
30AC-9ZZ02, "Preventive
Maintenance
(PM)."
The testing of circuit breakers
is
accomplished
during the regular
PM of the circuit
breakers,
at three year intervals during refueling.
However,
no
PM was performed
on any 480 Volt circuit
breakers
a'ssociated
with the three
systems
under
inspection during the first refueling outage,
which was
completed during January
1988.
The licensee's
surveillance
program appeared
to be
conducted in accordance
with the licensee
approved
procedures
and appears
to satisfy the requirements
of the
FSAR and the
TS requirements.
(2)
Calibration and
NOTTE Pro
rams
a 0
Instrument Calibration Pro
ram
The licensee's
instrument calibration program
was examined
by reviewing procedure
30AC-9ZZ02, "Preventive
Maintenance,"
the controlling procedure for instrument
calibration.
Instrument calibration schedules
were
reviewed.
Instrument calibration records for nine
instrument loops for the three
systems
(EW,
ECW, and
ESP)
under inspection
were examined.
This involved
approximately thirty-five instruments
in the three
systems.
Samples of history records for these
instruments
were also reviewed.
The history record included
a
chronology of calibrations,
maintenance,
and repairs for
the instrument.
The calibration
and history records
were
found to be in order
and complete.
The documentation
reviewed
and examined
supports
the conclusion that the
instrument calibration program appears
to operate
in
accordance
with the controlling procedure
and appears
to
be adequate.
b.
Measurin
and Test
E ui ment
(M&TE) Pro
ram
The licensee's
program for measuring
and testing equipment
(M&TE) was inspected to determine whether procedures
were
established
and implemented to assure that tools,
instruments,
and other measuring
and testing
equipment
used in activities affecting safety are properly
controlled, calibrated
and adjusted to maintain precision
and accuracy within specified limits.
The following procedures
were examined to evaluate
the
implementation of the
M&TE program:
34AC-.OZZ03
Measuring
and test equipment
(M&TE)
control program
Control of nonconforming
M&TE and
calibration standards
Control of automated
M&TE calibration
program
Control of procurement,
shipping,
packing and receiving inspection of
Calibration requirements
for M&TE and
calibration standards
34AC-9ZZ08
M&TE users administrative
requirements
M&TE work control
-
Receipt inspection of M&TE and
calibration standards
Two audit reports,86-019
and 87-027, of audits
conducted
in the area of measuring
and test equipment
were examined
with the following items noted:
The finding of audit 86-019 (performed June 16-30,
1986) identified a backlog of approximately
200
out-of-tolerance
notices
(OTNs), including four
dating back to 1984.
42
This situation
was previously identified to
management
in audit report 85-018 with no significant
improvement noted to date
(June 1986).
Corrective action report
(CAR) CA86-0163
was written
September
30,
1986, after the
same findings had been
identified during an
INPO evaluation,
to correct the
findings of audit 86-019.
CAR CA86-0163 was closed in May 1987 with this
statement:
"Since the issuance
of .this
CAR, the
program for OTN evaluations
has
shown significant
improvements
and can
be considered
to be in
conformance with the intent of ANSI N18.7-1976,
Para.
5. 2. 16."
The findings of audit 87-027 (performed July 6-23,
1987) again identified problems
such
as not
completing out-of-tolerance
evaluations
in the
required sixty (60) day time period, delinquent
(overdue for calibration) not being returned to the
Metrology Laboratory,
excessive
amounts of MTE being
lost/stolen in a sixteen
(16) month period,
inadequate justifications
on out-of-tolerance
evaluation replies,
etc.
CAR CA87-0091 written July 30, 1987, to correct the
deficiencies of'udit 87-027 contains this statement:
"Based
on the following adverse
conditions,
the
implementation of the present
measuring
and test
equipment
program is ineffective in controlling
nonconforming
METE, lost and stolen
M8TE; evaluation
of nonconforming items in a timely manner
and
recalibration of METE at specified intervals, to meet
,the intent of ANSI N18.7 and to minimize any
potential
adverse
impact on the operability of
safety-related
systems,
structures
or components."
, The licensee
as
a result of their
own preliminary self
evaluation (prior to the performance of audit 87-027
and
the issue of CAR CA87-0091)
had enlisted of an outside
industrial contractor
i'n conducting
a detailed in-depth
study of distributed
METE Responsibilitiesat
ANPP.
This
.
self-evaluation identified the
same
scope of concerns
as
those in CAR No.
CA87-0091.
Upon completion of this
study,
a final report will be issued
and (if applicable)
a
proposal for changes
to enhance
the program at ANPP.
The
licensee
has established
a target date of April 30, 1988,
to implement
recommended
changes
(determined to be
appropriate
and practical) identified at the conclusion of
. the study.
It is concluded that the licensee's
program for the
control of measuring
and test equipment is deficient in
43'everal
respects
as identified in CAR CA87-0091.
It
appears
that'actions
taken in the past to correct these
recurring deficiencies
have
been
inadequate.
This item
remains
as
an unresolved
item pending
a review by the
licensee
to determine whether
or not any of the
out-of-calibration instruments
were used in surveillances
of safety systems.
This is identified as inspection
item
50-528/88-01-26.
(3)
Monitorin
Pro
rams
a.
Heat Exchan er Monitorin
Pro
ram
The Palo Verde
FSAR Section 9.2. 1.4 indicates that an
important design basis is that the Spray
Pond
System
pressure
at the Essential
Cooling Mater Heat Exchanger is
maintained
higher than the
EW pressure.
This is to ensure
that in the event of a tube leak in the heat exchanger,
potentially radioactive water in the
EW would not be
injected into the Spray
Pond System where it would be
released
to the atmosphere.
The team found no evidence that the licensee
had
implemented
a proceduralized,
periodic assessment
of this
design parameter.
The team noted that
no pressure
gages
were in place at the heat exchanger
on the Essential
Cooling Mater side although they were in place
on the
Spray
Pond System side.
The team verified, by document
review, that the parameter
had been
measured
and found
satisfactory in preoperational
testing.
The licensee, installed
gages
and conducted
a test
on
January
18, 1988, in response
to the
NRC concern
and
verified that the spray pond system pressure
was indeed
higher than the
EM pressure.
The licensee's
surveillance
program for heat
exchangers
was discussed
with the lead performance
engineer
for
balance of plant,
and it was learned that at this time no
program
has
been
implemented.
The licensee
committed to
initiate a proceduralized periodic verification of this
design parameter.
The licensee's
implementation of this
commitment will be examined during
a future inspection.
This is identified as inspection
item 50-528/88-01-27.
b.
S ra'ond
Performance
Monitorin
Pro
ram
The licensee
has established
a program for monitoring
monthly (every 31 days) spray pond performance,
under
Administrative Procedure
"Spray
Pond Piping
Integrity Verification."
The spray pond nozzle
performance is monitored under this monthly program.
In
reviewing this-program with the
EWs engineer,
nozzle
performance
was 'examined.
A drop as slight as
one tenth.
44
pound in nozzle discharge
pressure
indicates
a loss of two
square
inches in nozzle capacity.
Documentation of the
testing of spray
pond capacity
and effects of removal of
nozzles
on spray pond performance
conducted
during startup
testing prior to initial operation of Unit'
was examined.
It is concluded that the spray pond performance
and nozzle
.monitoring program is adequate.
4.
Desi
n Basis
Documentation
and
En ineerin
Efforts
A.
Technolo
Transfer
Pro
ram
The technology transfer
program was originated
by ANPP to establish
the methodology associated
with its receipt
and control of the
design basis
documents
from the original architect-engineer.
The
purpose of this turnover is to ensure that
ANPP is in total control
of the design;
however, it does
not imply that the utility is
independent
from the
need of architect-engineer
services.
The
current utility staffing assumes
that 50K of the design
changes will
be done in-house
and the remaining
50X will be contracted.
Further,
the utility is proceeding to be in the position of either doing the
design
change itself or have the option to select
an architect-
engineer for the task.
The selection will be based
on which option
is most advantageous
to the project for a specific design
change.
As stated in ANPP instruction
No. 7I414.00. 17, Revision 0, dated
March 27,
1987, entitled,
"Engineering Turnover Documentation
Instruction," the technology transfer
program was'intended
to enable
ANPP to reassess
the completeness
and acceptability of the design
input and output documentation
required to support the operation
of.
the plant and any related engineering,
licensing,
and maintenance
activities.
In accordance
with the aforementioned
instruction, the
corporate
engineers
are required to review the turnover packages
in
accordance
with a three-page
checklist that requires
a
random'ampling
of drawings, calculations,
and components.
Also, the
reviewers
were to determine if certain
randomly selected
calculations
had assumptions
that were properly described,
justified, and correct.
Also, they were to determine if the
turnover package
was complete.
The
NRC inspection
team identified that the technology transfer
program failed to identify as missing several
calculations
associated
with the systems
reviewed, that
a properly implemented
program should
have identified.
These missing calculations
are
required to support the following systems:
design pressure/temperature
ratings of systems,
chilled water system flow balance,
the surge tank relief valve is sized for a failed open,
upstream regulator valve for the essential
chilled and cooling
water systems,
45
vertical cable supports capability to withstand seismic
event'ver
life of plant,
battery
room minimum temperature
resulting from LOP.
Also, contrary to the guidelines of the Engineering Turnover
Documentation Instruction's checklist where reviewers
were to
randomly select calculations to verify assumptions,
the
NRC
inspection .team identified that
ANPP had not adequately
reviewed the
calculation assumptions.
Specifically, for the three
systems
reviewed
by the
NRC inspection
team,
the technology transfer
program
did not identify the unjustified assumptions
in the following
calculations:
Essential
chilled water surge tank sizing calculation
Chiller sizing calculation
Spray pond's capability to reject heat from clean heat
exchangers
Battery/charger
sizing calculation
DC cable sizing calculation
DG load study calculation
Battery room
HVAC calculation
The team concluded that the root cause of the technology transfer
program not identifying the missing calculations
is a lack of
in-house
design experience,
e.g., architect-engineer
experience.
The team notes that
ANPP management
had previously identified the
need to augment their staff with experienced
design engineers,
but
the final staffing has not yet been
completed.
With regard to the
technology transfer
program fai ling to identify unjustified
assumptions
even though
such actions
were required
on a sampling
basis,
the
NRC team concluded the root cause to be
a lack of
management
involvement and commitment to ensure that the subject
'-programmatic instructions
were effectively implemented.
Another aspect of the technology transfer
program was the
establishment
of the design basis
manual.
This manual is intended
to provide
ANPP a reference
to the design basis
documents.
It is
being prepared
by in-house architect-engineer
personnel
(Bechtel)
under the direction of ANPP management.
It is also reviewed by ANPP
via a five-page checklist to ensure that the information required to
maintain the design basis is referenced,
and that the referenced
documentation
has
been received.
For the three
systems
reviewed by
the
NRC inspection
team,
none of these
had
a design basis
manual
which had been finally approved
by ANPP.
However,
a review of the
ANPP comments
revealed that they had not identified the missing
calculations that the
NRC had identified and their comments
could be
characterized
as editorial.
Clearly,
ANPP had hot performed the
46
type of review necessary
to accomplish their stated
purpose of
ensuring that the information required to maintain the design basis
-is referenced.
The final aspect of the technology transfer
program is the
performance of a detailed review of the engineering turnover
documentation
associated
with two safety-related
systems.
At the
time of the
NRC inspection,
ANPP had not yet started this review of
two selected
systems,
but it was scheduled
to be completed
by April
1988 and it is to include
a detailed review of calculations.
These
concerns will be followed as
an unresolved
item, pending
ANPP's review and assurance
that acceptable
design basis
documents
have
been established
(Inspection
Item 50-528/88-01-28).
Trainin
Pro
rams for ANPP Cor orate
En ineers
The normal training program for ANPP corporate
engineers
is
described
in ANPP instruction
No. 8I718.00.01,
Revision 1, dated
March 5, 1987, entitled,
"Nuclear Engineering Indoctrination and
Training Program."
This program intends to define the initial and
continuous training requirements
for ANPP corporate
personnel
performing quality-related design,
engineering
and other technical
activities.
Elements of this program include an orientation reading
list, general
design requirements
training (e.g.,
reading
FSAR,
design criteria manual,
NRC rules
and regulations, etc.),
system
design training (review in detail specifications,
drawings,
design
calculations,
etc.)
and finally administrative controls training.
This program also provides for the preparation of individual
training plans which identify the training considered
necessary
by
management
and
may include in-house
and out-of-house training.
The
cornerstone
of the identification of the
need of training is the
skills inventory matrix which is prepared for an individual by the
immediate discipline supervisor.
The skills inventory matrix is a
comprehensive
listing of rating factors associated
with an
individual's knowledge of work, quality of work, quantity of work,
interpersonal
effectiveness,
planning
and job control.
Individuals
are rated against
performance
standards
established
by the
engineering
manager for that particular engineering discipline.
Once the skills matrix has
been completed, it is used
by management
to identify individuals'trengths
and weaknesses.
Where weaknesses
are identified for a rating factor that is applicable to the
original work of the individual, the supervisor
has the option of
specifying the type of training required.
Additional design training is attained
by the
ANPP corporate
engineers
as
a result of the process
used to approve
DCPs.
Every
design
change
independent
of the initiating organization
must be
presented
to the
ANPP design review board by the responsible
corporate
engineer.
The design review board is comprised in part by
the engineering discipline supervisors
in accordance
with ANPP
Procedure
No. 7I4I2.01.09,
Revision 0, dated August 5, 1987,
entitled,
"Design Review Board."
All members of the design review
board
have
10 years of relevant
power plant experience,
5 years of
47
which is related to power plant design.
The responsible
engineer
must verbally present
the design
change to the design review board
and convince
them that it is necessary
and technically justified.
Thus, this process
causes
the responsible
engineer to understand
the
associated
design
change
even if it was prepared
by another
organization.
Training received
by the
ANPP corporate
engineers
as
a part of the
technology transfer
program
was through courses
by Bechtel
and
on-the-job training from Bechtel.
For more than
one year,
ANPP has
been the recipient of various technical
courses
being conducted
by
Bechtel senior engineers.
In total, there were 38 courses
scheduled
with an average
length of classroom instruction of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.
Examples of the courses
include support design,
engineering,
qualifications of equipment, electrical physical
design,
overcurrent protection principles, pipe stress,
ASME Codes,
control valve'fundamentals,
flow measurement,
etc.
Where
applicable,
standard calculational
methods
were reviewed
as part of
the classroom training.
Most of the courses
had been
conducted
by
December
1987, with a few remaining to be taught in the first half
of 1988.
In addition to the courses,
ANPP has
had Bechtel provide
on-the-job training to the corporate
engineers.
Bechtel senior
engineers
are currently working in the
ANPP offices to assist
the
licensee's
personnel
in becoming familiar with the design
and
architect-engineer
methods.
It is noted
by the team that Bechtel
personnel
are working in accordance
with ANPP procedures.
The
NRC inspection
team reviewed
ANPP's training program for
corporate
engineers,
the individual training records of one randomly
selected
ANPP corporate
engineer
and the architect engineer
design
experience
for corporate
engineers
in the electrical
and mechanical
disciplines.
Based
upon this review, the team believes that an
adequate
training program is in place.
However, the team is
concerned that the training program is not being vigorously
implemented.
The basis for 'this observation
is that the corporate
engineers
have not reviewed in detail
any of the calculations
associated
with the systems
reviewed
by the
NRC team.
This is
contrary to the
ANPP procedure,8I718. 00. 01 which requires
system
design training to include
a detailed review of system calculations.
Additionally, the team is concerned that the corporate
engineers
lack appreciable
design experience,
e.g., architect-engineer
experience.
However, the team notes that
ANPP had identified in its
1987 staffing and training requirements
the
need to hire "qualified
engineers
with previous design experience
at an operating facility
to avoid extensive training."
The team reviewed the qualifications
of the last six employees
hired into the mechanical
and electrical
disciplines collectively.
The results of this review indicate that
4 of the
6 had architect engineer
design experience
and that
management
was appropriately acting
upon
a weakness it had
identified.
The team encourages
the continued augmentation of ANPP
staff with engineers
with applicable
design experience.
In-summary
ANPP needs
to fully implement the training program it has
in place
and continue to augment the current staff with engineers
48
having significant nuclear design experience,
e. g., architect-
engineer
experience.
C.
Site
S stem
En ineerin
The team discussed
system design
and design basis,
and performance
monitoring and trending with various site system engineers,
as well
as training and responsibilities,
throughout the course of the
inspection.
Desi
n Basis
In the area of system design the system engineers
were
generally
knowledgeable
of how their systems
operate.
However,
when discussions
and walkdowns lead into the design basis,
the
site systems
engineers
lacked specific knowledge in several
areas,
e. g., various interface. functions with other systems
and
EW surge tank level setpoints.
This finding is of concern,
in
that, the site system engineers
may not be able to effectively
discharge their responsibilities
and assure
continued function
of the system without a clear understanding
of the design
basis.
During the system walkdowns,
NRC team identified significant
problems with various
systems
and components
discussed
in other
sections of this report.
The team concluded that most of these
problems
should
have
been identified by site system engineers
in their walkdowns;
and the fai lure of system engineers
to
identify the problems
may be attributed to a lack of
understanding
of design basis
and/or
walkdown functions.
The
team also recognized that the problem is compounded
by a
difficult to use plant problem reporting program,
which is
discussed
in another section of this report.
(2)
,S stem Performance
Monitorin
and Trendin
The team reviewed
and discussed
the system
engineers'esponsibilities
related to system performance
monitoring and
trending.
This included monitoring and trending of equipment
history (corrective maintenance),
testing (surveillances,
operational verifications,
and preventive
maintenance
with
emphasis
on verification of design basis),
and
use of industry
experience
(NRC Information Notices
and Bulletins,
and INPO's
Nuclear Plant Reliability Data System
and Significant Operating
Experience
Reports).
With regards to equipment history, the licensee's
program
currently consists
of:
a corporate
engineering
computerized
sort of equipment history which identified components
with a
number of failures beyond
an acceptance
criteria;
and
a review
of this computerized sort by the site system engineers
or their
supervision to determine if additional evaluation of component
or system performance is required.
In reviewing the status
of
this program,
the team found that the corporate sort
had been
C-
4
49
completed,
but this sort
had not been
reviewed by selected site
system engineers
or their supervision.
The team's
review of
the computerized sort information found that for'he selected
systems,
one component with a number of failures
beyond the
acceptance criteria had not been
reviewed by the site
engineering
department.
Engineering
management
indicated that
other work (Unit 1 outage related activities)
had taken
priority over equipment history review.
Also with regard to "equipment history monitoring, the team
determined that there
was
no formalized policy to assure that
system engineers
were kept apprised of significant mai,ntenance
or testing activities
on their related
systems
on a real time
basis.
Licensee
management
indicated that a program to route
all work orders through site system engineers
has
been planned
(this program is to include
a review of b'acklogged
work orders
and prioritization).
An example
of'
situation where system
testing should
have
been reviewed
by the system
engineer
was
the delay of an annual test committed to in LER 86-59 on the
emergency lighting (this problem is discussed
in detail in
another section of this report).
In the area of monitoring and trending of testing,
the licensee
was developing
a surveillance
test trending program.
The
status of this program
was that the system engineers
were
providing a list of parameters
required to adequately
monitor
system performance.
Licensee
management
indicated, this was to
be
a plant-wide integrated effort to utilize not only
surveillance tests,
but also operations verification,
preventive maintenance,
and engineering tests (for example,
With regard to verifying key system design basis
parameters,
the licensee's
program to verify heat exchanger
performance for
the
SSFI systems
was reviewed.
The team found that the
licensee
had not developed
a plan to monitor heat
exchanger
heat transfer capability.
Also, the licensee
had not verified
that
SP pressure
was higher than
EW pressure
at the
EW heat
exchanger to assure
no potential radioactive
leakage to the
environment (the licensee
has subsequently verified this
function and established
a rationale
and process
to assure this
important design. parameter).
However, these findings are again
indicative that site system engineers
may lack an adequate
design basis
understanding
to assure
testing
and verification
of important design functions.
(3)
~Tra i ni n
The team reviewed recently issued
documents
related to training
for site system engineers.-
The training document
lacked
sufficient specificity to assure that system engineers
were
fami liar with applicable
TSs,
design criteria,
FSAR sections,
technical
manuals,
surveillance tests,
and operational,
.emergency
and maintenance
procedures.
Also, the training
50
document did not specify techniques
to assure
adequacy
and
retention of training, nor did it assure that system engineers
would be knowledgeable
of changes
related to their system.
Licensee
management
has discussed
a plan to address
these
concerns.
(4)
Res onsibi lities
The current site systems
engineer responsibilities,
document
(EEDG-034, Revision') specified
a set of duties for site
system engineers.
These duties include
a knowledge of system
design
and operational
requirements,
trending
and monitoring of
system performance,
review of design
changes,
assistance
to
operations
and maintenance
organizations,
root cause failure
analysis,
and
many others.
The team verified that most system
engineers
were responsible for a number of different systems
(3
to 7, dependent
on system complexity).
Also, the team
determined
from the review of the aforementioned
duties that
the system engineers
have not been able to fulfillall their
responsibilities,
e. g., trending of system performance.
Further,
the team observed that there is extensive
use of
overtime
among the system engineers.
The inspection
team concluded that licensee
management
has not taken
a
proactive role in the definition and monitoring of, the site system
engineer
program.
This conclusion
was based
on the findings related to
the lack of system engineer
knowledge of design basis,
system
engineers'ailure
to identify problems that the team identified, failure of the
engineering
department to monitor and trend key equipment
performance
conditions,
the lack of specific training criteria and verification, and
a fai lure to assure that all system engineer responsibilities
were
appropriately discharged.
Discussions
with licensee
management
concluded
that they plan to re-evaluate
system engineers'esponsibilities,
training,
and workloads, to assure that management's
expectations
are
clearly defined
and attainable.
This is identified as inspection
item
50-528/88-01-29.
5.
Unresolved
Item
Unresolved
items are matters
about which more information is required to
determine
whether they are acceptable
or
may involve violations or
deviations.
The licensee is requested
to provide additional information
on these
items,
as noted in the forwarding letter to this report.
6.
Exit Interview
On February
12,
1988,
an exit interview was conducted with the licensee
representatives
identified in paragraph
1.
The team reviewed the scope
of the inspection
and findings as described
in the
Summary of Significant
Inspection
Findings section of this report.
Enclosure
1
PERSONS
CONTACTED
Arizona Nuclear
Power Pro ect
ANPP)
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B.
D.
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C.
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R.
R.
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D.
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T.
L.
N.
K.
R.
W.
R.
M.
n Support
er
ervisor
rvisor
Van Brunt, Jr.,
Executive Vice President
Allen, Director, Engineering
and Construction
Haynes,
Vice President;
Nuclear Production
Kirby, Director, Site Services
guinn, Director, Nuclear Safety and Licensing
Papworth, Director, guality Assurance
Allen, Unit 1 Plant Manager
Zeringue, Unit 3 Plant Manager
Driscoll, Assistant Vice President,
Nuclear Productio
Butler, Director, Standards
and Technical
Support
Sterling,
Engineering
Manager
Fasnacht,
Construction
Manager
Godwin,
Records
Management
Manager
Fernow, Training Manager
Vorees,
Nuclear Safety Manager
Lo Cicero,
Independent
Safety Engineering
Group Manag
Rogers,
Licensing Manager
Shriver,
Compliance
Manager
Craig, guality Systems
and Engineering
Manager
Fowler,
Procurement
equality
Manager
Souza,
equality Audits and Monitoring Manager
Russo, guality Control Manager
Younger, Operations
Manager
Beecken,
Maintenance
Manager
Dennis,
Work Control Manager
Blackson,
WRF Manager
Brandjes,
Outage
Management
Manager
Nelson,
Central
Maintenance
Manager
Adney, Plant Standards
and Control Manager
Sowers,
Engineering Evaluations
Manager
Berg, Protection Relaying and Control Maintenance
Sup
Powell, Unit 1, Electrical Supervisor
Karimi, Compliance
Engineer
Kropp, Technical
Support
McCaskey, Surveillance
Program Coordinator Supervisor
Simko,
Lead Mechanical
Engineer
Hansen,
Weber,
Lead Technical
Engineer
Perea,
Lead Performance
Engineer
Hall, Lead NSSS/Radwaste
Engineer
Trouy, Technician,
Technical
Support
Hallas,
System Engineer,
EW System
Cutler,
I8C Standards
Supervisor
Page,
I8C Support Supervisor
Goodman,
Lead Metrology Technician
Vallely, Senior Reactor Operator Shift Supervisor
Zerkel, Senior Reactor Operator,
Assistant Shift Supe
D.
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A'p
"W.
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M.
M.
H.
M.
J.
A.
D.
W.
R.
F.
M.
AJ
S.
"A.
p.
F.
J.
Hackbert,
qual ity Audit Super visor
Rouse,
Compliance
Engineer
Coffin, Compliance
Engineer
Jump,
Outage
Manager
Juan,
Licensing Engineer
Hodge,
Mechanical/Chemical
Engineer
Radoccia,
Lead Mechanical/Chemical
Engineer
Riley,
Lead Mechanical/Chemical
Engineer
Winsor,
Lead Mechanical/Chemical
Engineer
Deluca,
Mechanical/Chemical
Engineer
Amr, Mechanical/Chemical
Engineer
Bhasin,
Mechanical/Chemical
Engineer
Phalen,
Mechanical/Chemical
Engineer
Kershaw,
Lead Instrumentation
and Controls Engineer
Prawlocki,
Lead Methods
and Training Engineer
Hypse, Electric Engineer
Barrow, Electrical Engineering Supervisor
Kesler,
Lead Electrical
Engineer
Demlong, Electrical Engineer
Mueller, Electrical Engineer
Horner, Mechanical/Chemical
Engineer
Clarke, Operations,,Technical
Support
2.
Other Personnel
"S..Terrigino,.Participant
SVCS, Coordinator
"M. Wharton,
Southern California Edison Co., Assistant Technical
Manager
NRC Personnel
In addition to the inspection
team,
the following NRC Regional Office
Managers
and Supervisors participated in the inspection activity and/or
attended
the associated
management
meeting:
J. Martin, Regional Administrator
"D. Kirsch, Director, Division of Reactor Safety
and Projects
"R. Pate,
Chief, Reactor Safety Branch
"E. Imbro, Chief, TIAD Section,
"Denotes
those
personnel
in attendance
at an exit meeting
on February 12,
1988.