ML17304B405
| ML17304B405 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/03/1989 |
| From: | Ang W, Andrea Johnson, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17304B402 | List: |
| References | |
| 50-528-89-34, 50-529-89-34, 50-530-89-34, NUDOCS 8908290079 | |
| Download: ML17304B405 (14) | |
See also: IR 05000528/1989034
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-528/89-34,
50-529/89-34
and 50-530/89-34
Docket Nos.
50-528,
50-529,
50-530
License
Nos.
Licensee:.
Arizona Nuclear
Power Project
P.
0.
Box 52034
Phoenix,
AZ
85072-2034
Facility Name:
Palo Verde Nuclear Generating Station Units 1,
2 & 3
Reactor
ProJects
Branch,
Sect>on
Ins ection Summar:
Inspection
Conducted:
July 17-21,
1989
Inspectors:
N~
roy ct
nspector
s
A. Jo
son,
Enforcement Off>cer
Approved By:
S.
Rl hard,
Ch>ef
II
g-3- EQ
ate
>gne
D te
signed
8-3- Qg
ate
S>gned
Ins ection
on Jul
17-21
1989.
Re ort Nos.
50-528/89-34
50-529/89-34
and 50-530 89-34
During this inspection
the following Inspection
Procedures
were utilized:
30703,
37700
and 35702.
Safe
Issues
Mana ement
S stems
(SIMS) Items:
None
Results:
Of the two areas
inspected
one violation was identified.
This
violation identified a lack of timely completion of post trip review
corrective actions,
paragraph
2.6.
General
Conclusions
and
S ecific Findin
s
Si nificant Safet
Matters:
Overdue post trip review corrective actions
was identified.
Summar
of Violations:
Summar
of Deviations:
0 en Items
Summar
None
Two new items identified.
R
Sl<<~~
.)r
()tc'sooo~s>'-'iIF'VOCA"'
~ IC
r.
DETAILS
1.
Persons
Contacted
Arizona Nuclear
Power Pro'ect
B. Ballard, Quality Assurance Director
- J. Reilly, Standards
and Technical
Support Director
- C. Russo, Assistant Quality Assurance Director
- T. Shriver,
Compliance
Manager
- G. 'Sowers,
Engineering Evaluations
Manager
The inspectors
also met with other licensee
and contractor
personnel
during the course of the inspection.
- Attended the Exit meetings
held
on July 20 and 21, 1989.
2.
Desi n, Desi
n Chan
es
and Modifications
37700
An inspection
was performed
on design
changes
and modifications to verify
licensee
compliance with NRC requirements
and licensee
commitments.
The
inspection
included
a review of system engineer activities, their
responsibilities
and authority.
Applicable portions of the following
licensee
procedures
and work documents
were reviewed.
Licensee
Procedures
42 OP-2ZZ04, revision 3, Plant Startup,
Mode
2 to Node
1
42 OP-2Z207, revision 2, Plant Shutdown,
Node
1 to Mode
2
70 PR-OAPOl, revision 0, System Engineer
Program
73 AC-OEE01, revision 0, Engineering
Evaluation
Request
73 AC-ONS01, revision 0, Plant
Change
Package
73 AC-ONS02, revision 0,
Change Control
Process
73 AC 9MS28, revision 0, Site Modification
Post Tri
Review
Re orts
PTRR
- PTRR 1-88-004 -
Unit
1 Auxiliary Transformer Fire and Reactor Trip
of July 6,
1988, report dated July 29,
1988
-
PTRR 2-88-001 -
Low Steam Generator
h'
Level Trip During
Downpowering of Hovember
16,
1988, report dated
November 22,
1988.
,
Site Modification
S-MODS
- S-MOD SM-EW-002,
July 14,
1988, Essential
Cooling Water to Nuclear
Cooling Water Crosstie
Valves Limitorque Operator
Rotor Assignments
- S-MOD 2-SM-SF-005,Completed
7/88,
Control
System Electronic Setpoints
a 0
S-Mod SM-EN-002
-PTTR-1-88-004,
Concern
B. 1 noted that during the July 6,
1988
auxiliary transformer fire and associated
reactor trip, difficulties
were encountered
in attempting to cross-tie
nuclear cooling water
with essential
cooling water by remotely opening cross-tie
valve
EWA-UV-145.
Auxiliary Operators
were subsequently
able to partially
open the valve at the valve location.
The
PTRR further stated that
the suspected
cause of fai lure was that the valve limitorque
operator
torque switch bypass setting
was improperly set.
S-MOD
1-SYi-EW-002,
t>ad been
prepared
(5-11-88) to correct the suspected
problem.
This
S-MOD was however, in the approval
cycle at the time
of the trip (7-6-88).
The
PTRR recommended
corrective actions
were
to implement the
S-YiOD in Unit
1 prior to entering
Mode
4 and to
implement the
S-MOD in Units
2 and
3 during the first outage of
sufficient length but not to extend past
the next refueling outage.
At the time of this
NRC inspection,
the S-Mod had
been completed in
Unit 1,
was being performed in Unit 3 and
was scheduled
for
accomplishment
in Unit 2 during its next refueling outage.
The
licensee
considered
the Unit 2 valves to .be in conformance with
Technical Specification requirements.
The inspector
observed
from
a review of the licensee's
evaluation
and surveillance test results
that the valve would perform the required safety function of
closure if the valve was open.
The valve continues
to remain in
its closed position
as required
by the technical specification for
system operability.
During the review of S-MOD- SM-EW-002, the inspector
noted that part
of the reason for performing the
S-MOD was also to address
significant operating
experience
report
(SOER) 86-20.
The
reported
a
San Onofre experience "regarding Limitorque bypass
switches that were
on the
same rotors
as the valve position
indication contacts
and resulted in valves
remote position
indicating shut,
when the valves
were not fully shut
due to bypass
torque switch settings
prematurely terminating valve closure motion.
This condition was not the
PTRR identified condition and did not
appear to have
been
a problem experienced
at Palo Verde.
The
S-MOD
corrects
both the
PTRR noted problem
and the potential for the
noted problem.
However, since the
S-MOD had not been
performed in
Unit 2, the inspecto'r
attempted to determine
how the licensee
confirmed that the
SOER condition did not exist for the
EW cross-tie
valves that still had both the bypass
torque switch and the closed
valve position indication on the
same rotor.
In addition,
the
inspector inquired
how the licensee fulfilled EW System Technical
Specification
(T/S) surveillance
requirement 4.7.3.b - at least
once
per
18 months during shutdown,
by verifying that each
automatic
I
I
valve servicing safety-related
equipment actuates
to its correct
position
on
a Safety Injection Actuation Signal
(SIAS) test.
This
would require verification that the
EW cross-tie'alves
shut during
a SIAS.
The System En'gineer
informed the inspector that the
surveillance
had
been
performed
by verifying the remote valve
position indication lights.
The System Engineer
agreed that if the
SOER noted condition existed,
depending
on remote valve position
indication, lights could be incorrect.
The system engineer further
stated
however, that significant leakage
past the valve would also
be noted, if the valve was not fully shut, but no such
leakage
had
been identified in the past.
During subsequent
discussions
with the
licensee,
the licensee
agreed
to perform an engineering
evaluation
to confirm that the
SOER valve misposition (i.e. not fully shut)
condition did not exist for the Unit 2
EW cross-tie
valves
and that
T/S 4.7.3.b,
surveillance
requirements
had
been met.
The licensee
performed this evaluation
on
EER 89-EW-014 and confirmed that the
Unit 2
EW cross-tie
valves
were shut.
S-NOD 2-SM-SF-005
Concern
5 of PTRR 2-88-001,
low steam generator
82 level trip durin9
November
16,
1988,
noted that
S-NOD 2-SM-SF-005
changed
the feedwater control
system
(FWCS) electronic setpoints for main
feedwater turbine
speed control.
The
PTRR further noted that
necessary
revisions to the operating
procedures
governing feedwater
pump operation with the
new
FWCS program was not made subsequent
to
the
S-NOD ard before the plant trip.
The
PTRR also noted that the
administrative
procedure
(73AC-9MS28) for processing
of S-MODs had
been
changed
subsequent
to issuance
of S-NOD2-SN-SF-005
to require
cross-discipline
technical
reviews of S-MODs prior to issuance,
and
hence
precluae further repetition of S-MODs being completed without
necessary
changes
to affected
procedures
being issued.
The
PTRR, the
S-MOD administrative
procedure
and the noted
S-MOD
were reviewed
and discussed
with the system engineer.
The system
engineer
acknowledged
that
he misunderstood
the needed
procedure
changes,
and at the time considered
that the procedure
changes
needed
was for the I 8
C calibration procedure,
and
he did in fact
change
the
ISC calibration procedure.
The system engineer stated
that the affected operating
procedures
(42 OP-2ZZ04
and 42 OP-2ZZ07)
had since
been
changed
to provide operators
with additional
instructions related to the
FWCS setpoint changes,
and provided the
inspector
the procedure
changes.
The
PTRR provided additional corrective action to assure
that
significant similar occurrences
were also identified and corrected.
The corrective actions required evaluation of the site-mod
procedure,
the system engineer
program
and
system engineer
interface
responsibilities
with the procedure writers, Plant Standards,
to
"determine if they are designed
to prevent
a similar event in the
future."
The
PTRR further required the Engineering
Evaluations
Department
(EED) to perform
a "backfit" cross discipline review on
a
sample of current site-mods
to evaluate
the impact
on plant
operations.
The above
noted
PTRR corrective actions
were discussea
with the
EED Manager
and the Director of Standards
and Technical
Support.
They confirmed that, at the end of this
NRC inspection;
the noted
PTRR corrective actions
had not been completed
and would
not be completed for another
30 days.
At the
end of this
NRC
Inspection
the
PTRR corrective actions
were at least
5 months
overdue
past their original 90 day completion date.
In attempting
to determine
the promptness
of the above
PTTR corrective actions,
the inspector
reviewed the'Standards
and Technical
Support Directors
"PTTR/SPEER
Overdue Action Items" database.
The July 17,
1989
database
indicated that approximately
115 PTRR/IIR/SPEER action
items were overdue,
some of those
items being overdue
by
approximately
16 months.
10 CFR 50 Appendix "8" Criterion XVI
requires that measures
be established
to assure
that conditions
adverse
to quality are ~rom~tl
identified and corrected."
The lack
of timely completion of the above
noted post trip review corrective
actions,
which represent
potential contributors to future plant
trips,
was identified as Violation 50-528,
529, 530/89-34-01,
"Lack
of Timely Completion of Post Trip Review Corrective Actions."
Desi
n Chan
e and Modification Process
Various processes
for initiating design
changes
and modifications
were outlined in licensee
procedures
73 AC-OEE01 (EER's),
(PCP's),
73 AC-OMS02 (Change Control)
and
73AC-9MS28 (S-MOD's).
System engineers
functions in these
processes
are further outlined
in procedure
These
procedures
and processes
were
reviewed
and discussed
with both the Engineering Evaluations
Department
(EED) Manager
and the Standards
and Technical
Support
Director.
These
reviews
and discussions
resulted
in the following
inspector observations.
System Engineers
perform
a central function in these
processes.
System Engineers
have significant responsibilities
in these
processes.
System Engineers
have
some authority but ultimate
authority for approving accomplishment of design
changes
and
modifications rests with Palo
Verde Management.
For example,
system engineers
recommend
design
changes
and modifications
and
provide an initial recommended priority for accomplishment of
the changes.
The
EED Manager
and
a Plant Change
Review
Committee decides
what changes
are to be made
and sets
the
final priority for accomplishment
of the changes.
The
Standards
and Technical
Support Director stated that System
Engineer authority will be increased
with the implementation of
a nonconformance
report=(NCR)
process
(scheduled for issue
8/1/89).
The
new
NCR process will require correction of NCR
conditions within the time frame specified
by the System
Engineer
and approved
by his/her supervision.
The Plant
Change
Review Committee
was
composed of the
EED
Yanager
(Chairman)
and the Plant Managers.
The Standards
and
Technical
Support Director stated that the licensee
is
currently studying changing
the Plant
Change
Review Committee
to
a Plant Modifications Review Committee
composed of the Site
Director (Chairman),
the Standard
and Technical
Support
Director, the Engineering
and Construction Director and the
Plant Managers.
The proc'edure for the
new process
was still in
draft form (scheduled for issue 9/1/89)
and
had not yet been
implemented.
No procedure outlining the composition
and
functions of the Plant
Change
Review Committee
was available.
The
EED Manager
informed the
NRC inspector of the following
statistics.
(1)
S-MODs designed
but not implemented or completed - Unit
1-35, Unit 2-34, Unit 3-33
(2)
Design
Change
Packages
issued
but not installed - Unit
1-151, Unit 2-67 and Unit 3-71
(3)
Design
Change
Packages
in preparation
stage - Unit 1-109,
Unit 2-98, Unit 3-97
These
design
changes
and modifications were of various
significance
and priority.
The design
change
and modification procedures
noted
above
contained
requirements
for establishment
of a priority for
implementation.
However, only the
EER procedure
defined the
priorities.
The
S-MOD procedure,
the
Change
Control
Process
procedure,
the Plant
Change
Package
procedure
and the System
Engineer
Program procedure
did not reference
the
EER procedure
for establishment
of priority.
The
EED Manager stated
that it
was the
EER procedure priority codes that was utilized for
definition of implementation priorities.
The
EED Manager
agreed that further clarification of the other procedures
to
.,reference
the priority codes
was in order.
Pending
issuance
of the Plant Modifications Review Committee
procedure
and clarification of the implementation priority code
requirements,
this
was identified as Unresolved
Item 50-528,
529,
530/89-34-02 -. Plant Modifications Procedures
Questions.
Ins ection of Qualit
Verification Function
35702)
a
~
A Hotline Investi ations
An inspection
was performed
on the licensee
QA Hotline process.
Hotline File Number 89-31
was reviewed
and discussed
with the
licensee.
The Hotline item consisted of approximately
32 employee
concerns
dealing primarily with industrial safety.
However, the
Hotline item also included concerns
dealing with ALARA, fitness for
duty and "seismic scaffolding".
Discussions
with the
QA Director
and the
QA staff indicated that Arizona State
OSHA had already
performed
an inspection
on
some of the industrial safety concerns.
However, the licensee's
QA Hotline staff had just started
preliminary investigations
and information gathering
on the Hotline
item.
The
NRC inspectors
encouraged
the licensee
to perform
a
thorough
and unbiased
investigation of the Hotline concerns.
This
Hotline concern will be examined
upon completion of the licensee's
investigation.
No violations or deviations
were identified during this inspection.
4.
Unresolved
Items
Unresolved
items are matters
about which more information is required to
determine
whether they are acceptable
or may involve violations or
deviations.
One
new unresolved
item identified during this inspection is
discussed
in paragraph 2.c.
5.
Exit Interview
The inspection
scope
and findings were summarized
on July 20 and 21,
1989, with those
persons
indicated in paragraph
one above.
The inspector
described
the areas
inspected
and discussed
in detail
the inspection
findings.
No dissenting
comments
regarding
the inspection findings were
received
from the licensee.
The following new items were identified
during this inspection.
Violation 50-528,
529, 530/89-01 - Lack of timely completion of Post Trip
Review Corrective Action.
Unresolved
Item 50-528,
529, 530/89-34-02
- Plant Modifications
Procedures
(}uestion,