ML17306A241
| ML17306A241 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/15/1991 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17306A240 | List: |
| References | |
| 50-528-91-30, 50-529-91-30, 50-530-91-30, NUDOCS 9111040050 | |
| Download: ML17306A241 (15) | |
See also: IR 05000528/1991030
Text
Report
Nos.':
Docket Nos.:
License
Nos.
U. S.
NUCLEAR REGULATORY COYiNI
SSJOY'EGION
V
50-528/91-30,
50-529/9'1-30,
50-530/91-30
50-528,
50-529,
50-530
Licensee:
Arizona Nuclear
Power Project
P.O.
Box 53999, Station. 9012
Phoenix, Arizona
85072-3999
Facility Name:
Palo Verde Nuclear Generating Station
(PVNGS) Units 1, 2,
and
3
Inspection at:
Palo Verde Site, Wintersburg,
Inspection
Conducted:
August 12-30,
1991
Inspectors:
W. J.
Wagner,
Reactor
Inspector,
RV
Approved by:
~Summar:
F.
R. Huey, Chief,
ngineer
Date Signed
Ins ection
Au ust 12-30,.1991
(Re ort Nos. 50-528/91-30,
50-529/91-30,
50-530/91-30
Areas
Ins ected:
An announced
routine inspection
by
a regional
inspector of
licensee act>vities taken to address
previously identified items in the area
of fire protection.
Inspection
procedures
64704
and 92702 were used
as
guidance
during this inspection.
Results:
General
Conclusions
on Stren ths
and Weaknesses:
Areas of Stren th:
The licensee
has
implemented
an Emergency Lighting Team
(ELT) which appears
to
have
been effective at focusing
emergency lighting system
improvements.
Numerous
design modifications
have
been
implemented
which have significantly
improved available
design margin in the emergency lighting system.
Areas of Weakness:
The licensee
does
not appear
to have effectively implemented
a method to
monitor whether recent
system modifications are actually resulting in
improved emergency lighting system performance.
9111040050
911016
ADQCK 05000528
8
Several
types of emergency lighting system deficiencies,
similar to those
noted during previous
NPC inspections
appear
to be recurring.
Appropriate licensee
engineering
and management
personnel
do not. appear
to be properly involved in the timely evaluation
and correction of those
recurring deficiencies.
Si nificant Safety Matters:
None
Summar
of Violations or Deviations:
None
DETAILS
Persons
Contacted
~E.
Simpson,
Vice President,
Engineering
and Construction
- B, Ballard, .Sr,, Director, Quality Assurance
~E. Dotson, Director, Site Nuclear
Engineering
- R. Stevens,
Director, Nuclear. Licensing
and Compliance.
- C. Stevens,
Yanager,
Nuclear Engineering Analysis
"L. Henson, Electrical Supervisor,
Site Nuclear Engineering
- Y,. Hypse, Electrical Supervisor,
Balance of Plant
- C. Cooper,
System Engineer
- R. Bouquot,
Senior Specialist,
Quality Audits
- C. Emmett,
Owner Services
- K. Clark, Senior Engineer,
Licensing
- R. Henry, Site Representative,
Salt River Project
- S. Gross,
Engineer,
El
Paso Electric
L. Y;itchell, System .Engineer
'. Braddish,
Manager,
Compliance
R,
Rouse,
Supervisor,
Compliance
J. Baxter,
Compliance
Engineer
The inspector also interviewed other licensee
employees
during the course
of the inspection.
'Denotes
those attending
the Exit tleeting
on August 30,
1991 which was
also attended
by Nr.
F.
R.
Huey of the
NRC Region
V offices.
Fire Protection/Prevention
Pro
ram (64704)
and Followu
on Fire
rotection
n orcement
tems
9
0
The purpose of this inspection
was to review licensee corrective actions
'taken to address
enforcement
items related to emergency lighting
identified in
NRC Inspection
Report 50-528/90-25.
Although none of the
.enforcement
items were closed out during this inspection,
considerable
progress
was being
made
by the licensee
to resolve
concerns.
To ensure that management
and employees
are kept informed of emergency
lighting issues
and that all regulatory
commitments in this area
are
'addressed,
the licensee
established
a task force, referred to as the
Emergency Lighting Team
(ELT) in January
1991.
The inspector
attended
an
ELT meeting held
on August 13,
1991.
The
ELT consists
of
a
team leader
and
representatives
from Site Nuclear Engineering,
System Engineering,
Electrical Yiaintenance
Standards,
Unit Maintenance/Operations,
Compliance,
Nuclear Engineering,
Fire Protection
and Quality Assurance.
The following observations
were noted
by the inspector
and presented
to
licensee
management
during the
NRC Exit Yieeting on August 30,
1991:
The
ELT Team Leader
had
an understanding
of both
new and old issues
and provided
a documented
aoenda for review and updating of actior.
items.
t
Team members
appeared
to cooperate
in providing input to action
items.
These
action items were not only tn resol.ve essential
anC
emergency lighting issues
but also included items
such
as spurious
actuation/pre-fire
strategies
review, fire barrier concerns
in the
Auxiliary Building, and developing
a transition plan for team
demobilization.
The fire protection representative
had
been
absent
from these
meetings
over the past several
months.
The inspector
expressed
concern that information from ELT meetings
would not be integrated
into the fire protection
program if the fire protection
representative
did not attend
the
ELT meetings.
The
ELT was scheduled
to dissolve
.in September
1991 in a'ccordance
with the
ELT demobilization plan.
The inspector
expressed
concern
regarding responsibility for ensuring that incomplete work is
accomplished.
Durino the exit meeting
the licensee
stated
that the
ELT task force would not be abandoned
in September
and that
emergency lighting would be
a continuing high priority item at Palo
.
Verde,,
The corrective actions
taken
by the licensee
to address
the following
emergency lighting enforcement
items, although still in progress,
were
reviewed
by the inspector.
a.
(0 en)
Enforcement
Item 50-528/90-25-01:
Failure of A
endix
R
Emer enc
>
tsn
This violation was issued for failure to provide reliable emergency
lighting, as required
by the Facility Operating
License to support
safe
shutdown in the event of
a fire.
Specific concerns
were that
the Emergi-Lite, Holophane
and Exide lighting units were
experiencing
high rates of failure without appropriate
engineering
evaluation or corrective action being taken
by the licensee.
I
The Emergi-Lites, which experienced
a high failure rate in 1990,
were all replaced
under
Design. Change
Package
(DCP) 1, 2, 3FE-QD-025
with fluorescent lighting fixtures powered
from 2 centralized,
16
battery,
Holophane
MPS units located
on the
120 foot level of the
Auxiliary Building.
The
new Holophane units
have
been in service
since
December
14,
1990.
The Johnson
Controls
Model 6VHC-96, Dynasty
GC 12V-100 and
lead-acid
and gel-cel batteries
were replaced
by Holophane
MPS Units
as
a design equivalent
change
by Material
Nonconformance
Report
(MNCR) Numbers
90-QB-004
and 90-QB-005.
The replaced
batteries
were
unable to meet capacity requirements
at worst case
minimum
temperatures.
The Holophane
MPS Units were subsequently
replaced
by
upgraded
Holophane units that were installed under Site
Modifications 1, 2, 3-SM-QD-007,
Data
showing that these
upgraded
power stations
(Holophanes)
are capable of providing
125 percent of
the battery
load profile requirements will be reviewed during
a
future inspection.
j
l'
)I
The inspector
toured the following Unit 2 locations
where essential
and emergency lighting changes
were made:
( 1)
Switchgear
Room Train
B - the 8olophane inverter,
replaced
under
SN-.QD-007,
now includes
8 batteries
whereas
the original
had
4 batteries.
(2)
Battery
Room
D - the batteries
located
ir. Room
D feed the Exide-
inverters which supply half the Control
Room lighting.
The
500'foot long length of wiring between
the
20 batteries
that
feed the Exide inverters
had experienced
a voltage drop of 6-7
volts which was
a major reason
why the batteries
would not
support
an
8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge test,
DCP 1, 2, 3-XE-QD-026
modified the design to reduce
the loads
on the power supply -so
that their associated
batteries
could carry the load for the
required
8
hours'3)
Diesel
Generator
Room - 6 normal
and
2 essential
lights are
located in this room.
The inspector
noted that
a space
heater
partially blocks the light emitted from the essential
light
bulb and questioned
whether, with loss of,normal lights, there
would be sufficient l-ighting to perform safe
shutdown
operations.
The licensee identified this deficiency in
Incident Investigation Report
No. 3-1-91-037, entitled
"Insufficient Essential
Lighting for Safe
Shutdown Operations",
which states
on page
11,
Item 14, that "Essential
Lighting
alone is insufficient to perform Safe
Shutdown tasks at valves
= EQIDs 2P-DGB-V013,
V059 and V064."
. b,
(0 en)
Enforcement
Item 50-528/90-25-04:
Failure to Provide
Emer enc
Li
for Outdoor
Use
The lighting concerns
were that Appendix
R Emergi-Lite units
installed in the
VASSS Breezeway
(an outdoor
"damp" location) were
not of an approved
design for outdoor use to support
safe
shutdown
tasks,
The Emergi-Lites were replaced
by fluorescent fixtures under
DCP 1, 2,
3 FE-QD-025,
Other licensee
actions
taken to ensure
more
reliable operation of emergency lighting, such
as increased
preventive maintenance
and performance of periodic capacity tests,
will be reviewed during
a future inspection.
The inspector
noted that, although the licensee
had issued
numerous
ELT status
reports
to plant management,
providing detailed status
on
the progress
of numerous
ELT action items,
the licensee
had not
developed
an appropriate
document for monitoring whether
emergency
lighting performance
was improving as
a result of the actions.
During the exit meeting,
plant managers
could not quantitatively
address
recent
emergency lighting system performance.,
The licensee
agreed
to more closely monitor specific emergency lighting
component
performance
in
a manner similar to that performed in
response
to previous
NRC inspections,
In order to develop
a sense
of current
emergency lighting system
performance
and licensee
actions
to preclude
recurrence
of lighting
system fai lures similar te those
noted during previous
NRC
inspections,
the inspector
reviewed
an "Individual Failure Record
Report", dated
August 27,
1991.
This review identified several
examples
of emergency, lighting system deficiencies similar to those
experienced
prior to licensee
implementation of their emergency
light task force.
In some instances, it also
appeared
to the
inspector that the licensee
had not aggressively
pursued root cause
evaluation or correctior of'he observed deficiencies,
resulting in
emergency lighting system operability problems similar to those
noted during previous
NRC inspections.
In particular,
the inspector
noted the fnllowing specific deficiencies:
')
On June
28,
1990, control
room emergency lightinq unit 1E(DNFOI
failed as
a result of its associated
low voltage cut out relay
being unable to achieve
the required target
drop out voltage of
105 vdc.
Actual recorded
drop out was
119 vdc and could not be
adjusted
below 118 vdc.
Although, this same'ype failure had
been
noted before,
the cause of the failure was listed
as
"unknown" and possibly attributed to "normal/cyclic wear",
2)
On January
7,
1991,
the Exide battery for control
room emergency
lighting unit 3EgDNF02
was noted to be degraded
as
a result of
improper cell specific gravities'.
Similar specific gravity
deficiencies
were again
noted
on Hay 23,
1991.
At that time,
the cause
of failure was listed
as
"unknown" and
one battery
jar containino
some of the deficient cells
was replaced.
Finally on June 6,
1991,
emergency lighting unit 3EODNF02
failed an
8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge test after 6.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />.
At that
time, the "entire battery
bank"
was determined
to have
been
"degraded
to approximately
79K of rated capacity".
3)
Although not punctuated
with a discharge test failure similar
to emergency lighting unit 3E(DNF02, similar repetitive battery
specific gravity problems
were noted
on emergency lighting unit
2E(DNF01 during maintenance activities in October,
1990,
December,
1990, January,
1991
and March,
1991;
In each
instance,
no specific cause
of the failure was indicated,
During the exit meeting,
the inspector
noted that the above
types of
repetitive battery deficiencies, without apparent timely licensee
engineering
evaluation or corrective action,
appeared
to indicate
an
'nadequate
level of engineering
or management
involveme'nt in correcting
the types of problems for which the emergency light task force was
created,
The inspector
requested
that the licensee
evaluate this concern in
conjunction with completing their assessment
of improved emergency
lighting system
performance.
The licensee
agreed,
This item will remain
unresolved,
pending completion of the licensee
evaluation
(50<<528/91-30-02),
The reportability of essential
lighting deficiencies
was discussed
with
licensee
personnel,
INCR 91-gB-9005 identified five specific locations
with insufficient essential
lighting; also
numerous
other locations, with
similar inadequate
essential
lighting, were identified to the inspector
in reports of walkdown inspections
conducted
by the licensee
in 1989,
1990
and
1991,
In addition, Condition Report/Disposition
Request
(CRDR)
910004 identified that the essential
lighting fixtures
and the emergency
lighting units are fed from two different circuit breakers
which, during
a fire event concurrent with loss of offsite power, could result in the
loss of illumination in 83 different safe
shutdown areas,
At the time
of this inspection, it was not clear to what extent lighting would be
simultaneously lost in the different safe
shutdown areas,
This question
will be followed up during
a subsequent
inspection,
Although the
licensee
had notified the
NRC Resident
and Regional Offices of these
deficiencies,
the inspector questioned
whether these conditions
should
have
been reported
by issuance
of
a Licensee
Event Report
(LER).
The
licensee's
position was
as follows: according
to Technical Specification
(TS)
6 .9,3
two conditions
are required for reportabi lity in accordance
with 10 CFR 50.73;
these
are:
( 1)
a violation of the requirements
of the fire protection
program
described
in the Final Safety Analysis Report,
and
(2)
an adverse affect on the ability to achieve
and maintain safe
shutdown in the event of a fire,
Insufficient essential
lighting is
a violation of the fire protection
program which the licensee
has
documented
in INCR 91-98-9005.
However,
the second
TS requirement
necessary
for issuance
of an
LER is not met
because,
according to the licensee,
hand held lights, allowed
by Branch
Technical
Position
(BTP) 9.5-1,
are provided
as compensatory
measures
to
provide sufficient lighting for operator actions to achieve
and maintain
safe
shutdown in the event of
a fire.
The inspector
reviewed the
following requirements
for licensee
compliance:
( 1)
FSAR Section 9.5,3.1,
Safety Design Basis
Two, requires
a lighting
system,
comprised of normal,
emergency
and essential
subsystems
to be
designed
so that
a single failure of any subsystem
cannot terminate
the
system's ability to illuminate areas
occupied during
a reactor
shutdown
or emergency.
(2)
10 CFR 50.73 (a) (2) (v) requires
the reporting of any condition that
alone could have prevented
the fulfillment of the safety function of
a
system
needed
to shut
down the reactor
and maintain it in
a safe
shutdown
condition.
(3)
NRC Branch Technical
Position 9.5-1 Section 5(b)
states
that "Suitable sealed
beam battery
powered portable
hand held
lights should
be provided for emergency
use."
The licensee
states
in
Table 98-1 that they comply with this
BTP.
(4) Administrative Procedure
14AC-OFP01 "Fire System Impairment,"
Revision
2 of March 29,
1990, did not address
BTP 9,5-1 regarding
hand
held lights until issuance
of Procedure
Change
Notice
(PCN) 01, Revision
2.
PCN 01, Revision 2, effective date of October 26,
1990
added
Section
9 addressing
use of portable
hand-held lighting when emergency lights are
This
PCN was issued
by the licensee
to address
previous
NRC
concerns
regarding
compensatory
measures.
Based
upon
a review of the foregoing requirements
and procedures,
the
licensee
concluded that the essential
lighting deficiencies
did not
represent
a condition that alone would have prevented
the fulfillment of
a safety function, or have significantly compromised plant safety.
The
licensee's
evaluation of this condition is documented
in a letter -to
Region
V, k'.
F;
Conway
(APS) to J.
B; Yartin (NRC)
on July 1, 1991, that
the essential
lighting deficiencies
described
in INCR 91-QB-005 are not
reportable
in accordance
with TS 6,9.3.
The licensee
has
implemented
action to correct the essential
lighting wiring deficiencies,
however,
the matter of reportability.remains
an unresolved
item to be evaluated
under the requirements
of TS 6,9,3
(Unresolved
Item No. 50-528/91-30-01).
No violations or deviations
were identified in the areas
reviewed.
3.
~E
The inspectors
met with the licensee
manaoement
representatives
denoted
in paragraph
1
on August 30,
1991.
The scope of the inspection
and the
findings
as described
in this report were discussed,
gU
I