ML17306A424
| ML17306A424 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/13/1992 |
| From: | Narbut P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17306A422 | List: |
| References | |
| 50-528-91-44, 50-529-91-44, 50-530-91-44, NUDOCS 9202040254 | |
| Download: ML17306A424 (28) | |
See also: IR 05000528/1991044
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-528/91-44,
50-529/91-44,
and 50-530/91-44
Docket Nos.
50-528,
50-529,
50-530
License
Nos.
Licensee:
Arizona Public Service
Company
P.
0.
Box 53999
Station
9012
Phoenix,
Arizona 85072-3999
Facility Name:
Palo Verde Nuclear Generation Station
(PVNGS) Units 1, 2,
and
3
Inspection at:
Palo Verde Site, Mintersburg, Arizona
Inspection
Conducted:
November 4 through December
17, 1991
Inspector
C.
A. Clark, Reactor Inspector
Approved by:
I
lg
ar u,
c 1ng
se;
ng>neersng
ec
son
a
e
>gne
Ins ection
Summar
Ins ection Durin
the Period of November
4 throu
h December
17
1991
(Re ort
os.
an
Areas Ins ected:
An unannounced
routine inspection
by one regional
based
snspec
or.
reas
inspected
included:
Unit 2 Inservice Inspect)on (ISI)
activities, effectiveness
of licensee
s maintenance activities,
a review of
available Inservice Testing (IST) activities,
and followup of licensee
actions
on previously identified items.
Inspection procedures
62700,
73753,
73755,
73756,
and 92701 were
used
as guidance for the inspection.
Results:
General
Conclusions
and
S ecific Findin s:
It appeared that nonconforming conditions were not being noted by
maintenance
or inspection personnel,
specifically Limitorque limit switch
cover plate fasteners
were observed to be missing,
loose or of incorrect
material.
A lack of formal document control was noted in the review of the ISI
program.
The Unit 2 Inservice Inspection
Program
Summary Manual,
Program
No:
ISI-2, was issued
September
19,
1986.
While the working copy
9202040254
9201l6
ADOCK 0500052S
8
of the program
has
been
marked
up and maintained
up to date
by the
Component
8 Specialty Engineering
Group, there
has
been
no formal
revision issued for the master ISI program
summary since the 1986 issue.
Si nificant Safet
Matters:
None
Summar
of Violation:
0 en Items
Summar
One violation was identified.
The violation
concerned
the failure of maintenance
personnel
to
follow procedures
on Limitorque valves operators.
One enforcement
item, two follow-up items,
and
NRC Information Notice 91-56 were closed during this
inspection.
0,
Persons
Contacted
Arizona Public Service
Com an
DETAILS
2.
"J. Baxter,
Compliance
Engineer
"T. Bradish
Compliance
Manager
C. Brown, fSI Engineer
S.
Coppock,
Component
Engineering Supervisor
- M. Corcoran,
ISI/IST Engineer
- E. Dotson,
Engineering Director
"R. Flood, Unit 2 Plant Manager
"R. Fullmer, Manager, Quality Assurance
and Monitoring
"D. Hansen,
ISI/IST Supervisor
"P.
Hughes,
Site Radiation Protection
Manager
- S. Kanter,
Mgmt. Services
Senior Coordinator
M. Kerwin, Maintenance
Support Manager
- D. Mauldin, Site Maintenance
8 Modifications Director
"C. McClain. Technical Training Manager
- R. Rouse,
Compliance Supervisor
T. Stewart,
Employee Concerns
Supervisor
M. Mebster,
Manager,
Component
and Specialty Engineering
D. Mittas, Technical Quality Engineering Supervisor
Others
J.
Draper,
Southern California Edison Site Representative
The inspector also held discussions
with other licensee
and contractor
personnel
during the course of the inspection.
- Denotes those attending the exit interview on December
6, 1991.
Maintenance
Pro
ram Im lementation
(62700
The inspector
examined several
maintenance
procedures
and observed
maintenance activities and plant equipment configurations.
This examination
was performed to determine:
If the maintenance
program was being implemented in accordance
with
regulatory requirements.
The effectiveness
of the maintenance
program
on important plant
equipment.
The ability of the maintenance staff to conduct
an effective
maintenance
program.
This review identified several
examples of weakness
in maintenance
activities.
As an example,
Licensee
Nuclear Administrative and Technical
Manual
Procedure
30 DP-9MP01, Revision
No. 4, Procedure
Change Notice No.
1, "Conduct of Maintenance,"
section 3.5. 13 stated in part:
I
"Personnel
doing maintenance
shall not alter,
change
or modify plant
equipment,
.
.
~ without an approved
work document authorizing
and
specifying such changes."
"Plant equipment shall
be restored to proper design configuration
including all fasteners
in place,
panels
closed,
etc.
An
appropriate
engineering evaluation
and resolution shall
be
accomplished
whenever proper restoration is not possible."
It appears
the licensee
instructions identified above were not always
followed during motor operated
valve maintenance
work.
An NRC
inspector's
sampling review of various motor operator
valve
(MOV)
configurations in all three units identified the following examples of
nonconformance
conditions listed below by unit:
Unit 1-
Unit 2-
Unit 3-
Valve 1JCHB-HV-0255, seal
injection/containment isolation,
was missing
a nut from a stud installed at the limit
switch cover plate flange joint.
A Material
Noncomformance
Report
(MNCR) No.
91-CH1031 was issued to
document this condition and replace the missing nut.
The
fact that this Unit 1 valve was found with the nonconforming
equipment configuration is an example of an apparent
violation (91-44-01).
The following valves are additional
examples
of this apparent violation.
Valve 2JSGA-UV-0138,
steam supply to auxiliary feed
pump
turbine was missing
a bolt on the limit switch cover plate
flange joint.
An MNCR 91-SG2052
was issued to document
this condition and replace
the missing bolt.
Valve 2JCHE-HV-0536, refueling water tank
(RWT) gravity
feed to charging
pumps
was missing
a lock washer
and bolt
on the limit switch cover plate flange joint.
An MNCR No.
91-CH2033
was issued to document this condition and
replace
the missing bolt and lock washer.
Valve 3JSIA-UV-617, high pressure
safety injection (HPSI)
was missing
a nut from a stud on the limit switch cover
plate flange joint.
An MNCR No. 91-S1 3137 was issued to
document this condition and replace the missing nut.
Valve 3JSIB-HV-609,
had
a loose nut on a stud installed at
the limit switch cover plate flange joint.
Work Request
No. 808713 was issued to tighten the nut.
Valve 3JSIA-HV-684,
had
a socket
cap screw backed out 3/4
inch from the limit switch cover plate flange joint.
Mork
request
No. 808714
was issued to tighten the cap screw.
Valve 3JSIA-HV-306, shutdown cooling heat exchanger
bypass,
had two bolts installed which were not marked
with grade
5 markings.
The bolts were installed in the
limit switch cover plate flange joint.
Limitorque Vendor
Technical
Document
Number VTD-L200-0025, stated in
art, "Limitorque uses
commercial
grade
5 or better
~
~
ardware
on all operators.
All external
hardware is
cadmium plated for corrosion resistance."
This condition
was documented
in Condition Report/Disposition
Request
(CRDR) 9-1-0282,
and the subject bolts were replaced with
bolts of the correct material.
The fact that Unit 3 was
found with the two installed nonconforming bolts
identified above,
which were not grade 5, nor cadmium
plated,
and did not appear to have
an approved
work/engineering
document authorizing their installation
is an example of a loss of configuration control...
All the valves found with these
nonconforming fastener
configurations
had various past maintenance activities
performed,
where the subject limit switch cover plates
and
associated
fasteners
were removed.
As an example,
valve
2JSGA-UV-0138 had its limit switch cover removed per work order
No. 00512588,
August 29,
1991 to assist
engineering in a
walkdown to verify wirinq.
On November
6, 1991, the
NRC
inspector identified a missing cover plate bolt.
At the exit interview the inspector
noted that the approved
equipment configuration should
be maintained and/or restored.
This includes
equipment fasteners
which should
be reinstalled
or replaced with fasteners
of an approved material
and
configuration.
Maintenance
personnel
should verify external
fasteners
are installed correctly or initiate an
MNCR to
correctly identify the nonconforming condition so that it can
be corrected.
To address
these
NRC identified maintenance
program weaknesses,
the licensee
issued
CRDR 9-1-0282 to determine
the root cause
for failure to restore
the
MOV limit switch covers properly and
the incorrect fastener material substitution.
The licensee's
assessment
of root cause
and corrective action
will be reviewed with their response
to the violation.
3.
Inservice Ins ection-Observation
of Mork and Work Activities (73753)
Samples of Unit 2 Inservice Inspection (ISI) work activities in progress
were reviewed to ascertain
that repair and replacement of components
were
being performed in accordance
with applicable
requirements.
The licensee
was conducting the Unit 2, cycle 4, third refuelinq outage of the second
period of the first ten year ISI interval.
The Unst 2 ISI Program
Summary Manual
(Program
No. ISI-2) Revision
No.
0 was issued
September
19, 1986,
and is based
on the requirements
of ASME Code
Section XI, 1980
Ed)tion through
and including the Minter 1981 Agenda.
fn addition,
and
in accordance
with 10 CFR 50.55a,
the extent of class
2 piping welds for
the
PVNGs Safety Injection System
was determined in accordance
with the
1974 Edition, through
and including the
Summer
1975 addenda,
of ASME Section
XI.
During this review, the inspector
noted that licensee
procedure
Ol, Revision
No. 1,
PCN No. 02,
"ASME Section
XI Inservice Inspection",
Section
3. 2.5. 1 stated
in part,
"Component
8 Specialty Engineering shall
maintain
a copy of the ISI program
summary to document these
new
requirements,
as built conditions,
and other changes
noted during
implementation of the ISI program.
All changes
shall
be initialed and
dated
by the engineer
and shall
be included in the next revision to the
ISI program summary."
The inspector performed
a cursory review of the
working copy of the Unit 2 ISI program maintained
by the ISI group and
noticed that there
had been several
changes
recorded in the document
without the issue of any formal revisions.
The ISI group identified that
they had been working on a revision No.
1 to the Unit 2 ISI program that
should
be issued in the near future.
The inspector
reviewed all the available qualifications
and certification
records for the ISI examiners
and the equipment certifications presented
by the licensee.
The reviewed documentation
appeared
acceptable.
The
non-destructive
examination activities for ISI zones 48-28, 48-29, 53-7,
53-8, 53-9, 53-10, 70-44, 70-46, 70-61,
and 70-103 were observed
and they
appeared to have
been performed in an acceptable
manner.
The ISI
examinations
observed
during inspection
were performed
by the licensee
staff and contractor personnel
supplied
by Lambert, MacGill and Thomas,
Inc.
No violations or deviations
were identified.
The inspector will follow
up the licensee's
action regarding
a formal change to their ISI plan in
the course of future scheduled
inspections.
Inservice Ins ection - Data Review and Evaluation (73755)
The inspector
reviewed all available
ISI data generated
during this
outage
and presented
by the licensee for review to ascertain that the
required data
was recorded,
reviewed
and evaluated
in accordance
with
previously established
requirements
and acceptance
criteria.
The
licensee's
disposition of all available
adverse findings presented
for
review by the licensee
were also reviewed to ascertain that the
dispositions
were consistent with regulatory requirements.
A November 29,
1991 licensee letter No.
323-00087-MAF identified the
following number of tubes
were plugged in the Unit 2 steam generators
this outage:
No.
1 (021) - 15 tubes plugged,
and ll of these
tubes
were staked with a cable.
No.
2 (822)
26 tubes
plugged
and 10 of these
tubes
were staked with a cable.
The results of the steam generator
tube inspections identified loose
parts in both steam generators.
The licensee is evaluating this data
and the
NRC is reviewing this evaluation.
No violations or deviations
were identified.
t
e'nservice
Testin
of Pum
s and Valves (73756)
A review of the few pump and valve surveillance
procedures
and activities
scheduled
in the Inservice Testing (IST) area
was performed to determine
whether
IST regulatory requirements
and licensee
commitments
were being
met.
For various reasons,
there were
no Section
XI surveillances
performed/completed
at the times the inspector
was available to observe
the IST.
There were
no concerns identified with the actual
scheduled
surveillance
procedures
reviewed
and the initial surveillance
preparations
observed.
A review of completed Unit 2 IST surveillance
data identified that
a
November 3, 1991 local leak rate test (LLRT), of butterfly valves
NCA-UV-402 and NCB-UV-403 at penetration
34, the nuclear cooling water
return line,
had failed.
Condition Report/Disposition
Request
(CRDR)
2-1-0183 identified the as-found
leakage
as 61,400 standard
cubic
centimeters
per minute
(SCCM) for valve NCA-UV-402 and 56,400
SCCM for
valve NCA-UV-403, while the allowable leakage
rate for each valve was
2500
SCCM.
The
CRDR did not identify that the actual
required
hydro test
ressure
of 51.5 to 52 psig could not be reached
during the initial LLRT.
he actual initial test
hydro pressure
reached
was
10 to 15 psig.
When
the Component
8 Special
Engineering
Group reviewed the
CRDR and test
data,
they requested
a second
LLRT at full hydro pressure,
and the
as-found
leakage
was identified as 150,000
SCCM for valve NCA-UV-402 and
112,216
SCCM for valve NCA-UV-403.
As of December 6, 1991, the
CRDR had
not been revised to document the actual initial hydro pressure
or the
latest
as found
LLRT test data.
This high as-found
LLRT leakage for penetration
34 may affect the length
of the Unit 2 reactor containment building integrated
leak rate test
scheduled for December of 1991,
and could affect the acceptance
of the
ILRT.
The licensee identified that they are following this concern via CRDR
2-1-0183,
and
have assigned
a special
task group to determine
the root
cause of the valve failures.
It appears
that the only maintenance
activity performed
on these
valves,
since the previous
ILRT, were checks
of the valve torques
switch settings
using the Motor Operated
Valve
Analysis and Testing
System
(MOVATS).
The licensee
actions
taken with CRDR 2-1-0183
and the next Unit 2 ILRT
will be the subject of a future
NRC inspection.
No violations or deviations
were identified.
Ins ection of Previousl
Identified Follow-u
Items (92701)
A.
(Closed)
Follow-u
Item No. 50-528/89-16-02
Inflow Method
or
oca
ea
a
e
es
o
se
as
m
ie
An NRC inspector identified that the methodology for local leak rate
testing
(LLRT) may not have
been conservative.
The licensee's
final
Final Safety Analysis Report
(FSAR) appeared
to implicitly allow only
the inflow test method.
However,
a majority of the
LLRT performed
by
the licensee primarily used the outflow test method.
To address
this concern,
the licensee
contracted for BCP Technical
Services,
Inc. to perform an independent
review of their testing
methodology.
The results of this review were issued in a report
dated
May, 1990.
The licensee
s review identified the following:
The outflow test method
had numerous
advantages
over the inflow
test method,
but it did require
a more extensive evaluation of
piping configuration during test procedure preparation
to
ensure that all possible flow paths
were accounted for.
In addition, the test procedures
for isolating flow paths
should follow specific criteria to provide assurance
that
outflow testing
was being performed in a consistent
and
conservative
manner.
Recommended
changes
to existing licensee's
LLRT procedures
were
provided.
The licensee
evaluated
the results of the review and in the early
part of 1991 revised the
LLRT procedures
for all three units to
include applicable
review comments.
The
new procedures still
performed
LLRT per both the inflow and outflow testing methods.
Later in 1991, during the performance of LLRT the licensee
identified the following concerns:
The use of both inflow and outflow testing methods
appeared
to
have generated
some confusion
and delays during
As the various systems
experience
increased
operating time,
radiation levels
and contamination levels,
and the use of the
outflow test method required additional radiological controls.
To address
these
new concerns
the licensee
made
a management
decision to change all
LLRT outflow tests to inflow tests.
The Unit
2
LLRT procedure
was revised
September
19, 1991 for the next outage,
and the
LLRT procedures for Units 1 and
3 were scheduled
to be
revised prior to the next
LLRT for those units.
The inspector
performed
a brief review of licensee
procedure
'Containment
Leakage
Type "B" and "C" testing," Revision
2 and it
appeared that all outflow tests
had been
changed to inflow tests.
Based
on the information above, it appeared
the licensee
had
addressed
this concern satisfactorily.
This item is closed.
(Closed)
Enforcement Item No. 50-528/91-05-01
ann enance
s
o
er orm
ro rsa
e
)
no fs In a Work Order
This noncited violation identified that during Unit 1 pressurizer
code safety valve work, the licensee
had entered late entry
sign-offs in work orders incorrectly.
The late entry sign-offs were
not performed in accordance
with section 3.8. 10 of licensee
procedures
30 DP-9MP01,
"Conduct of Maintenance."
During this
inspection,
the inspector
reviewed documentation that indicated
applicable
licensee
personnel
had received additional instructions
on
procedure
30-DP-9MPOl.
It appeared
the licensee
had addressed
this
concern satisfactorily.
This item is closed.
(Closed)
Follow-u
Item No. 50-528/91-05-02.
ann
enance
roce ures
i
e
m rove
n
rea
o
e a)
e
oo
>s
s
ee
ac
rom
rev>ous
Job
This item identified that work orders
and procedures
issued for
repetitive maintenance
work in radiation areas
did not contain
detailed tool lists.
As an example, it was identified that
repetitive work was being performed
on the Unit I Pressurizer
Code
Safety Valves per licensee
procedure
31 HT-9RCll, "Pressurizer
Code
Safety Valve Removal
and Installation,"
and it did not contain
a
detailed tool list.
The licensee
agreed that for maintenance
personnel
to maintain their radiation exposure
as low as reasonable
achievable
(ALARA) for repetitive work in high radiation areas,
such
as the pressurizer,
the addition of detailed tool lists to the work
procedures
would be an aid.
The licensee identified that they were
proceeding with the improvement of procedure tool lists through the
development of Hodel
Work Instructions
and increased
emphasis
on
previous work feedback per the completion of Mork Enhancement
forms
normally included in the applicable
work procedures.
During this inspection,
the licensee identified that they had added
a detailed tool list to procedure
31 HT-9RC11 for Pressurizer
Code
Safety Valve work and additional procedures
would be reviewed to
address
ALARA concerns for tool lists upon feedback
from
implementing organizations.
The
NRC inspector
reviewed the latest
issue of procedure
31HT-9RCll, revision no. 3, procedure
change
notice
No. 4,
and identified the following procedure
weaknesses:
Section 2.2,
"H L TE and special tools," referenced
Appendix A,
page
18 of the procedure.
While Appendix A, "Recommended tools
and material," did identify some very useful additional
information, it did not identify any regular wrenches,
nut
sockets,
crowfoot attachments,
and/or drive extensions
that
would be required to disassemble
and reassemble
the inlet and
outlet flanges.
These
two flanges
have different size
fasteners.
Mhile the procedure
did identify the inlet and outlet flange
fasteners
stud sizes, it did not identify the sizes of the
applicable nuts.
One of the major reasons
for increased
time and radiation exposure
for work in hsgh radiation work areas is'ersonnel
entering the work
area without the proper tools (such
as wrenches,
nut sockets,
socket
drive extensions,
crowfoot attachments,
etc.).
Since these specific
valve flange fasteners
should not change
each time the valves are
worked, it appears
that for ALARA reasons
this procedure
could
t
identify the applicable size of wrenches,
sockets
(regular,
deep,
thin wall, etc.) drive extensions,
crowfoot attachments,
etc.
required to perform the applicable
work.
Follow-up discussions
during this inspection with the maintenance
department identified that the department
did not consider it
necessary
to identify the additional tools identified above,
in
their procedure tool list, since the Central
Maintenance
Group had
staged
a special
tool box for all the tools required to remove
and
install code pressurizer
safety .valves.
When the
NRC inspector
requested
a copy of the list of tools staged in this special tool
box,
he was told a list did not exist.
It appeared
that without
some type of tool list, it would be hard for Central
Maintenance to
verify the special tool box was staged correctly with all the tools
required to perform the valve work.
The licensee
stated they would
review the subject of tool lists for prestaged
special tool boxes.
It appeared
the licensee
had initiated actions to address this
concern.
This item is closed.
D.
(Closed
o en
sa
a >oac
sve
ea
a
e
o
an
Vented to Atmos here
This
NRC Information Notice identified that there could be potential
problems resulting from the leakage of isolation valves in the
emergency
core cooling system
(ECCS) recirculation lines to the
safety injection water and refueling storage tank (SIRMT), which
could be vented to atmosphere.
The
NRC inspector
reviewed the licensee
actions taken to address
this concern
and identified the following:
The licensee
had issued Condition Report/Disposition
Request
(CRDR)9-1-0123 to evaluate
these potential
problems.
At Palo
Verde the tank similar to the SIRE is identified as the
refueling water tank (RMT), and the tank is vented to the fuel
building.
A review of CRDR 9-1-0123
as of November 4, 1991,
identified that it appeared
the licensee
had implemented
appropriate
actions to address this concern.
At Palo Verde the licensee identified three potential
paths for
recirculation water to end
up in the
RMT.
The path with the
more dramatic impact was identified as failure of the
RMT check
valve.
The additional
two paths all had two valve protection
and
a single valve failure would not have the
same
impact that
a failed check valve would have prior to the
RMT isolation
valve closing.
The licensee
was performing calculations to determine
a
quantity of valve leakages
through the recirculation lines that
would not result in a radiation exposure
dose
exceeding
the
NRC
limits.
These calculations
were scheduled
to be completed
December
31,
1991.
Preliminary calculations
appear to indicate
I
)
a system
leakage to the
RWT of 70 to 90 gallons
per minute
(GPM) would not exceed
the
10 CFR 100 radiation exposure
limits.
The licensee
is reviewing a proposed
system 85/90 psig
pressure test that would measure
leakage
past the system
boundary valves, with an acceptable
leakage identified as
10 to
20
GPM.
It appeared
that the actions
taken to date
and proposed at this
time will address this concern satisfactorily.
This item is closed.
E.
ualit
Assurance
A review of the application of equality Assurance
(gA) control in
specific areas
was performed.
The findings of this review are
identified below under the individual area.
Review of Im ortant to Safet
ITS) Work
The inspector
examined the equality Assurance
provisions applied
to maintenance activities
on "important to safety" equipment.
The terminology of important to safety (ITS) equipment for Palo
Verde equality Classification
System
has
been revised.
The
previous
term or designator of ITS has
been revised to Oua1ity.
Augmented
(gAG).
Section 4. 1. 10 of procedure
AC-OCC06 defines
gAG as "items that
do not perform
a safety related function,
'but which as
a result of regulatory management
directive,
require the application of certain quality assurance
program
elements."
Since there
was
no actual
work being performed
on ITS/gAG
equipment during the inspector
s visit to the site,
the
inspector performed the following:
Reviewed applicable licensee's
documents
such
as
procedures
81AC-OCC06, "Classification of Structures,
Systems,
and Components",
Revision 2, and 30DP-9MPOl,
"Conduct of Maintenance,"
Revision 4, to identify the latest
licensee
instructions
issued for the performance of work on
ITS/gAG equipment.
Reviewed approximately eighty recently completed maintenance
work order
(WO) packages,
to verify the adequacy'of
the
gA
provisions.
The
WO packages
were randomly selected
from the
packages
being processed
through the maintenance
department
review circuit.
Reviewed five completed
WO's selected
from historical
files for work performed
on ITS/gAG equipment in 1987
through 1991.
These
WO's were reviewed to determine the
adequacy of the
gA provisions.
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10
Reviewed available licensee
equality Audits 8 Monitorin~
Department reports to identify the results of licensee
s
reviews of the maintenance
and
gA inspection activities
associated
with ITS/gAG equipment.
Interviewed various licensee
personnel
involved in work or
reviewing work activities associated
with ITS/gAG
equipment,
to determine
what gA controls were followed
during maintenance
work.
The reviews of the completed work orders
and
MO packages
identified that all these
documents
appeared
to conta>n
appropriate quality control
(gC) holdpoints.
Discussions
with licensee
personnel
and review of available
documentation
did identify that there
had been deficiencies identified
with implementation of the gA controls in maintenance
activities associated
with ITS/gAG equipment areas,
such
as
the Emergency Lighting System.
Following the identification
of the Emergency Lighting System deficiencies,
the licensee
organized
a task force to evaluate
the implementation of the
quality assurance
program to other non-safety related areas.
The task force was still reviewing information and pursuing
resolution to questions
in the non-safety related
areas
during this inspection.
Review of Com onent Classification
To review the accuracy of component classification,
design
and
as-built configuration, the inspector
performed the following:
Reviewed licensee
procedures
81 AC-OCC06, "Classification of
Structures,
Systems,
and Components,"
Revision
2 and
"Component Classiciation Evaluation," Revision 0.
Reviewed the latest licensee
information on concerns identified
in Corrective Action Requests
(CARs) No.
CA87-0109 and
No.90-010,
and other associated
licensee
documentation.
Reviewed
component classification evaluation
(CCE) packages
selected
from historical files.
These
packages
were prepared
by Tenera Corporation under
a contract to address
known
classification
problems at
Interviewed various licensee
personnel
involved in the review of
component classification problems at Palo Verde.
As a result of the above reviews
and interviews, the inspector
identified the following information:
The Station Information Management
System
(SIMS) had been
used
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11
in ways that were not originally contemplated.
A portion of
SIHS was
used
as
a controlled data
base
even though it was not
originally intended to be
a controlled data base.
Since
SIHS
did not have
an overall data control
and assurance
process
when
some of the data
was originally placed into it, SIHS contained
significant amounts of inaccurate
and unverified data.
When the Engineering
Department,
Material Control Department,
and Tenera initiated a Material
and Equipment Configuration
Project
(MECP) in 1988, this project used
SIMS data to generate
Component Classification Evaluation
(CCE) packages.
Whs le this
project
knew the data in SINS was not completely accurate, it
was the main source of available information at the time.
There
was
no documentation that identified to what extent
Tenera
had identified that they were using
known inaccurate
documents,
to verify the adequacy of the design
and.,as built
configuration of the plants during preparation of the
CCE
packages.
As a result of Corrective Action Requests
(CARs) No.
CA87-109
and
No.90-010, the licensee identified that administrative
controls
had not been sufficient to ensure
design output
information was being incorporated correctly into plant
configuration documents.
The licensee
issued
new procedures
and implemented organizational
changes
to address this concern.
The licensee
has already reviewed approximately 47,000 data
entry files to update the
SIMS data base.
There appeared
to have
been
no significant safety problems
identified in safety related
areas.
After reviewing the above information, the inspector could
substantiate
that Tenera
had
used
"known" inaccurate
documents to
verify the adequacy of the design
and as-built configuration, since
they were directed to use the SINS data base.
It appeared that the licensee
had identified this concern
and taken
appropriate
actions to address
the appropriate
actions to address
the identified inaccurate
SINS data, correct
CCE packages,
and
no
further
NRC actions
were required at this time.
Reactor Protection
S stem
ualit
Provisions
The inspector
examined the quality provisions applied to the
Reactor Protection
System
(RPS).
There
was
no actual
work being
erformed
on
RPS equipment during the inspector
s visits to the site.
he inspector took the following actions:
Reviewed Palo Verde Nuclear Generating Station
(PVNGS) updated
Final Safety Analysis Report
(FSAR), table 3.2-1,
"equality
Classification of Structures,
System,
and Components"
and
section 7.2, to identify the latest
FSAR gA requirements.
Table 3.2.-1 identified that portions of the
RPS were quality
assurance
class
g.
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12
Reviewed licensee
procedures
81AC-OCC06, "Classification of
Structures,
Systems,
and Components",
Revision
2 and
"Component Classification Evaluation," Revision 0, to identify
the latest licensee
issued
gA instructions.
Performed
a brief review of six recently completed
maintenance
WO packages
to verify the adequacy of the
gA
instructions
issued.
Interviewed various licensee
personnel
involved in
RPS work or
reviewing work activities, to determine
what
QA controls were
followed during work.
As a result of the above reviews
and interviews, the inspector
identified the following information:
The work orders
and work order packages
reviewed,
appeared
to indicate proper
gA requirements
were followed for the
applicable
RPS work performed.
There were
no examples identified where proper
gA controls
had not been followed for work on safety related
equipment.
No violations or deviations
were identified. It appeared
to the inspector
that the licensee
has
had historical
problems with important to safety
(quality augmented)
equipment classification
and control.
However,
it appears
that the licensee is currently addressing
these
problem areas.
7.
~Eit N ti
The inspector
met with the licensee
management
representatives
denoted
in paragraph
1,
on December
6, 1991.
The scope of the inspection
and the
inspector
s findings
up to the time of the meeting were discussed.
At
this meeting the inspector identified that additional information would
be reviewed in order to complete the inspection.
Additional dialogue
with the licensee
and review, in the Region, of pertinent
documents
necessary
to complete the inspection
were concluded
on December
17, 1991,
and the findings included in paragraphs
2 and
6 of this report.
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