ML17313A874

Advises of Planned Insp Effort Resulting from Palo Verde PPR Review Which Was Completed on 990211.Overall,performance of Plant,Units 1,2 & 3 Was Acceptable

ML17313A874
Person / Time
Site:	Palo Verde
Issue date:	03/19/1999
From:	Harrell P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
NUDOCS 9904060177
Download: ML17313A874 (36)

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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Iv 611 RYAN PLAZADRIVE, SUITE 400 ARLINGTON,TEXAS 76011-8064 eR l9 1999 James M. Levine, Senior Vice President, Nuclear Arizona Public Service Company P.O. Box 53999 Phoenix, Arizona 85072-3999

SUBJECT:

PLANT PERFORMANCE REVIEW (PPR) - PALO VERDE

Dear Mr; Levine:

On February 11, 1999, the NRC staff completed a PPR of Palo Verde. The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of safety performance.

The results are used by NRC management to facilitate planning and allocation of inspection resources.

PPRs provide NRC management with a current summary of licensee performance and serve as inputs to the NRC's senior management meeting (SMM) reviews.

PPRs examine information since the last assessment of licensee performance to evaluate long-term trends, but emphasize the last 6 months to ensure that the assessments reflect current performance.

The PPR for Palo Verde involved the participation of all technical divisions in evaluating inspection results and safety performance information for the period March 8, 1998, through January 25, 1999. The NRC's most recent summary of licensee performance was provided in a letter of April 8, 1998, and was discussed in a public meeting with you on April 28, 1998.

As discussed in the NRC's Administrative Letter 98-07 of October 2, 1998, the PPR provides an assessment of licensee performance during an interim in which the NRC has suspended its Systematic Assessment of Licensee Performance (SALP) program.

The NRC suspended its SALP program to complete a review of its processes for assessing performance at nuclear power plants. At the end of the review period, the NRC willdecide whether to resume the SALP program or terminate it in favor of an improved process.

Unit 1 was at 100 percent power at the start of the current period of detailed focus (March 8, 1998).

On August 31, 1998, a power transient caused by a failed nonsafety-related moisture separator reheater pressure switch resulted in a power decrease to approximately 93 percent power.

On September 1, the unit was returned to 100 percent power after the failed pressure switch was replaced and remained there for the duration of this assessment period.

Unit 2 was at 100 percent power for the entire focus period.

Unit 3 was at 100 percent power at the start of this period. On July 1, 1998, power was reduced to approximately 75 percent to comply with Technical Specification requirements for

= inoperable core protection calculators.

The unit returned to 100 pe'rcent power on July 2 and remained at that power level until August 29 for a coastdown for a refueling outage.

On September 19, the unit was shut down for the seventh refueling outage.

The unit was taken to Mode 1 on October 25, 1998, and reached 100 percent power on October 29.

It operated there 99040bOf77 9903f9 PDR ADOCK 05000528 6

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Arizona Public Service Company until November 7, when the unit was shut down to repair the Reactor Coolant Pump 18 oil lift pump. The unit was restarted on November 8 and was returned to 100 percent power on November 9, where it was operated for the duration of this assessment period.

Overall, performance at all three Palo Verde units was acceptable.

Operations exhibited a conservative approach in planning and implementing refueling outage activities.

Both routine and transient operations were properly conducted.

However, tag outs and control of plant configuration had multiple examples of errors attributable to inattention to details by the operations staff. Maintenance was effective but there was an increase in personnel performance issues related to procedure adherence, and concerns were identified with the welding program.

The material condition of plant equipment did not result in any significant challenges to plant operations.

The engineering staff continued to effectively support operations and maintenance activities. The radiation protection program was effective, with only occasional problems.

The emergency response organization exhibited implementation concerns related to organization and performance during a site exercise.

Operations personnel performance during the acid tank rupture was marked by poor implementation of the emergency response plan by shift management, as evidenced by the untimely (44 minutes) declaration of a Notice of Unusual Event.

A conservative approach was noted in planning and implementing refueling activities and in conducting day-to-day plant operations.

Operator oversight and direction of the draining of the Unit 3 reactor coolant system to the midloop condition to remove a piece of foreign material that had become trapped during reinstallation of the steam generator manway cover were excellent.

The Unit 3 reactor shutdown for a refueling outage was well planned and conducted in accordance with procedures.

During transient conditions, the operations staff also performed well. Unit 1 control room personnel responded to the letdown backpressure oscillation and leak event appropriately.

A corrosion-induced failure of a nonsafety-related pressure switch in the secondary plant caused Unit 1 to experience a power transient (from 100 to 93 percent power),

and operator response to that transient was good. Tag outs and the control of plant configuration, however, had multiple examples of problems, many of which were attributable to personnel errors and/or a lack of attention to details.

Isolation of all Unit 3 high pressure safety injection system flow transmitters caused both trains of high pressure safety injection to become inoperable.

The operations staff should have known of existence of a problem with the inoperable high pressure safety injection check valves and initiated corrective action to address the situation. Two opportunities to identify and correct this problem were available following two safety injection tank level decrease events.

It was determined that continuing the core inspection program would be sufficient to monitor this area, but attention will be placed on configuration control issues.

Maintenance was performed in an effective manner during this assessment period.

Preoutage containment walkdowns and zone inspections of the Unit 3 auxiliary building components resulted in the early identification of potential problems that would result from boric acid corrosion.

Electrical maintenance personnel p'erformed good troubleshooting activities on Unit 1 Startup Transformer NAN-X02. There was, however, an increase in personnel performance issues related to procedure adherence.

The inadequate reinstallation of a vibration probe flange on Unit 1 Main Feedwater Pump A during the Unit 1 outage which allowed oil to leak onto the pump high pressure journal bearing is an example of such problems.

The surveillance testing program was well implemented.

The tracking of Unit 1

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Arizona Public Service Company interval-based surveillance tests effectively scheduled tests, which prevented exceeding the expiration date.

The material condition of plant equipment was good. A proactive approach for the prevention of material condition deficiencies caused by boric acid corrosion was implemented by the licensee.

It was determined that continuing the core inspection program would be sufficient to monitor this area.

'Engineering support to operations and maintenance was effective. Engineering evaluations were generally good, with some exceptions.

There were two examples of inadequ'ate corrective actions in the development of testing and maintenance procedures following operating experience assessments of NRC Information Notices 88-70 and 89-62.

First, there was a failure to develop adequate testing procedures to identify excessive check valve reverse flow of the high pressure safety injection check valves.

Second, the initial safety evaluation completed for correction of the pinhole leak in the service water supply line to the water-to-air aftercooler of Unit 1 Emergency Diesel Generator B was not fullycomplete.

It was noted that the licensee had developed comprehensive plans to address operational and equipment problems resulting from the inability of some components and computer software to correctly interpret'some dates that occur before and after the year 2000.

In addition to the core inspection program, a safety initiative inspection will, as a part of a national sample, review your response to Generic Letter 96-01.

The radiation protection and security programs were effectively implemented.

High quality pre-job briefings on radiological hazards and dose reduction techniques were provided to radiation workers.

Radiation protection technicians provided good oversight of work activities.

Implementation of radiological controls in the Unit 3 refueling outage was characterized by excellent radiation protection controls and effective radiation work practices.

The implementation of the security plan during a bomb threat was excellent.

The emergency response organization exhibited some implementation problems related to organization and performance during a site exercise.

Corrective actions for improvement of the emergency plan exercise scenario development process in response to an exercise weakness were not fully effective. The scenario was created without sufficient information for operators to promptly recognize and declare the desired emergency classification.

Relocation of the Operations Support Center to an alternate facilityduring the annual emergency preparedness exercise was not well organized, which extended the amount of time taken to attempt the relocation.

Because of this, an opportunity to demonstrate emergency response capabilities from the relocated Operations Support Center was missed.

Operations personnel performance during an actual event, the acid tank rupture, was marked by poor response.

An untimely initial declaration (44 minutes) of a Notification of Unusual Event was made in response to rupture of the Unit 1 sulfuric acid tank. The shift manager left the control room to personally assess the scene instead of implemeriting his emergency response responsibilities.

It was determined that continuing the core inspection program was sufficient to address this area.

Enclosure 1 contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that were considered during this PPR process to arrive at an integrated view of licensee performance trends.

The PIM includes items summarized from inspection reports or other docketed correspondence between the NRC and Arizona Public Service Company.

The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately.

Rather, the NRC only documents issues that the NRC believes warrant management attention or represent noteworthy aspects of performance.

In addition,

Arizona Public Service Company the PPR may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.

This material will be placed in the PDR as part of the normal issuance of NRC inspection reports and other correspondence. provides definitions for some of the information listed in the PIM.

This letter advises you of our planned inspection effort resulting from the Palo Verde PPR review.

It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite.. details our inspection plan for the next 8 months.

Also included in the plan are NRC noninspection activities. The rationale or basis for each inspection outside the core inspection program has been provided in this letter so that you are aware of the reason for emphasis in these program areas.

Resident inspections are not listed due to their ongoing and continuous nature.

Because of the anticipated changes to the inspection program and other initiatives, this inspection schedule is subject to revision. Any changes to the schedule listed will be promptly discussed with your staff. Ifyou have any questions, please contact me at (817) 860-8250.

Sincer y,

~

arrell, Chief Pr 'ect Branch D Divi ion of Reactor Projects Docket Nos.:

50-528 50-529 50-530 License Nos.: NPF-41 NPF-51 NPF-74

Enclosures:

1. Plant Issues Matrix

2. General Description of PIM Table Labels

3. Inspection Plan cc w/enclosures:

Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, Arizona 85007

i

Arizona Public Service Company Douglas K. Porter, Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800

Rosemead, California 91770 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, Arizona 85003 Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, Arizona 85040 Angela K. Krainik, Manager Nuclear Licensing Arizona Public Service Company P.O. Box 52034 Phoenix, Arizona 85072-2034 John C. Horne, Vice President Power Supply El Paso Electric Company 2025 N. Third Street, Suite 220 Phoenix, Arizona 85004 Terry Bassham, Esq.

General Counsel El Paso Electric Company 123 W. Mills El Paso, Texas 79901 Mr. John W. Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, California 90051-0100 Mr. David Summers Public Service Company of New Mexico 414 Silver SW, ff1206 Albuquerque, New Mexico 87102

Arizona Public Service Company Mr. Brian Katz Southern California Edison Company 14300 Mesa Road, Drop D41-SONGS San Clemente, California 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, Arizona 85251 Harry E. Border Division of Emergency Management State of Arizona 5636 East McDowell Road Phoenix, AZ 85008

Arizona Public Service Company t

bcc to DCD (IE40) NR l 9 !999.

Resident Inspector DRS'Branch Chiefs (3 copies)

MIS System RIV File.

Chief, NRR/DISP/PIPB Chief, OEDO/ROPMS B. Henderson, PAO Records Center, INPO C. Gordon ment Section, OEDO bcc distrib. by RIV:

Regional Administrator DRP Director DRS Director Branch Chief (DRP/D)

Senior Project Inspector (DRP/D)

Branch Chief (DRP/TSS)

T. Boyce, NRR/DISP/PIPB C. Hackney, RSLO W. D. Travers, EDO (MS: 16E15)

Associate Dir. for Projects, NRR Associate Dir. for Insp., and Tech. Assmt, NRR PPR Program Manager, NRR/ILPB (2 copies)

Chief, Inspection Program Branch, NRR Chief, Regional Operations and Program Manage W. Bateman, NRR Project Director (MS: 13E16)

M. Fields, NRR Project Manager (MS: 13E16)

DOCUMENT NAME: S:tDRPtDRPDIR>PPR<PV To receive co of document, Indicate in box: "C" = Co without enclosures "E" = Co viith enclosures "N" = No co C:DRP/D PHHarr I

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/99 D:DRP D:DRS KEBrockman 3/'99 ATHo I

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PLANT ISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE CODE 12/16/98 STR IR 98-301 NRC OPS 1C 12/16/98 POS IR 98-301 NRC OPS 1C ITEM The licensee developed an innovative examination schedule, which allowed administration of the examination with one set of materials, and submitted a high quality examination, which was assembled to facilitate administration.

Effective examination security was maintained.

The licensee's development of a written security plan and conduct of daily security briefings were notable.

12/1 6/98 STR IR 98-301 NRC

OPS, 1A 1B 12/16/98 POS IR 98-301 NRC OPS 1C.

11/14/98 NCV IR 98.08 LIC OPS 3A 11/14/98 NCV IR 98-08 LlC OPS 1A 11/14/98 POS IR 98-08 NRC OPS 1A 09/28/98 POS IR 98-07 NRC OPS 1A 3A 09/22/98 NEG IR 98.07 NRC OPS 1B 1C Allsix applicants for senior operator and eleven applicants for reactor operator licenses passed the licensing examinations and were issued the appropriate licenses.

Strong applicant performance with good communication techniques was observed during the operating test.

The simulation facilities and simulation facilitystaff supported the examinations very well.

A weakness in attention to detail by an auxiliary operator while establishing a clearance associated with the fuel pool cleanup pump resulted in a 5-inch, inadvertent draindown of the spent fuel pooL The inspectors considered this an isolated human error and, as a result, a noncited violation of TS 5.4.1 was identified.

Failure to adequately perform a verification of containment integrity resulted in movement of fuel for 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> without containment closure. A noncited violation of Technical Specification 3.9.3 was identified. The refueling team successfully performed the core reload in accordance with plant procedures.

Operator oversight and direction of the draining of the Unit 3 reactor coo'lant system to the midloop condition were excellent.

IVIIdloopoperation was conducted to remove a piece of foreign W material that had become trapped during reinstallation of the manway cover following steam generator tube inspections.

This was a conservative management decision, since an engineering evaluation indicated that the material did not interfere with the sealing of the gasket.

Observation of core offload activities associated with the Unit 3 refueling outage indicated that refueling personnel consistently used good communications and demonstrated a safety-conscious approach to performing refueling operations The control room staff responded in a prompt manner to the loss of a nonsafety-related load center in Unit 3. The operations crew exhibited good oversight of activities during the response by appropriately prioritizing the critical plant parameters in order of safety significance.

However, recognition that the safety-related battery chargers had been lost at the onset of the event was not accomplished in a timely manner.

Once discovered, corrective actions were accomplished to restore the battery chargers

i

PLANTISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE CODE ITEM 09/21/98 POS 09/18/98 POS IR 98-07 NRC OPS 1A IR 98-07 NRC OPS 1A 3A Operator oversight and direction of the evolution to drain Unit 3 to the midloop condition, and decisions to take conservative actions during the evolution, were excellent.

The Unit 3 reactor shutdown tor the seventh refueling outage was well planned and conducted in accordance with procedures.

Supervisory oversight and direction of the operating crew and operator performance during the shutdown were excellent 09/10/98 NEG IR 98-07 NRC OPS 1A 3B 08/31/98 POS IR 98-07 NRC OPS 1B 08/22/98 NEG IR 98-06 LIC OPS 3A 08/22/98 VIO IR 98-06 LIC OPS 3A An unclear work plan for preparing the acid system for maintenance, and failure of auxiliary operators to followthe work plan for establishing a vent path for the acid tank, contributed to the rupture of the tank. The recovery plan following the incident was prompt and appropriate Corrosion induced failure ot a nonsafety-related pressure switch in the secondary plant caused Unit 1 to experience a power transient.

Operator response to the transient was good Operators who reviewed the work associated with the Train B high pressure safety injection motor-operated valve testing, focused on the containment isolation requirements and did not adequately consider nor recognize the impact ot isolating the flowtransmitters on system operability. Following a Train A flow alarm, an attentive senior reactor operator trainee recognized the need to enter Technical Specification 3.0.3. Once the operators recognized that the plant was in Technical Specification 3.0.3, they took prompt and appropriate actions.

Isolation ot all Unit 3 high pressure safety injection system flowtransmitters caused both trains of high pressure safety injection to become inoperable, which required entry into Technical Specification 3.0.3.

However, the operators did not implement the required actions because they were not aware of the unit being in this condition for approximately 5ih hours after actual entry.

The failure to initiate actions within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit in a mode in which the specification does not apply is a violation of Technical Specification 3.0.3.

08/22/98 NEG IR 98-06 NRC OPS

. 3A The failure to conduct inspections while performing plant tours, as described in administrative procedures, was identified as a weakness of the operations staff to implement their assigned responsibilities.

Specifically, auxiliary operators tailed to monitor the operational status of Low Pressure Safety Injection Pump Afor four 7-day periods, during an 81 day span, because the pump room was posted as a locked high radiation area.

Operations management took prompt and effective corrective actions once the problem was identified.

08/22/98 NEG IR 98.06 NRC OPS 3A A weakness in attention to detail by an auxiliary operator while restoring a clearance resulted in the inadvertent start of Charging Pump E in Unit 1. Quick and proper actions by the control room operators to diagnose the perturbation and realign the chemical and volume control system minimized the eftect of the inadvertent start on the unit.

PLANT ISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE CODE ITEM 07/21/98 EEI IR 98-14 SELF OPS VIO EA 98-382 SL III LER 98-006 08/06/98 POS IR 98-15 NRC OPS Control room personnel responded to the letdown back pressure oscillation and leak event appropriately.

Appropriate evaluations associated with the immediate consequences of the event were performed by licensee engineers.

1A 2A 2B Two examples of an apparent violation of Technical Specification 3.5.2, which required an operable high-pressure safety injection system flowpath. 1) The Unit 1, Train "B" high. pressure safety injection system flowpath was inoperable for approximately 6 years because of an incorrectly assembled check valve. 2) The Unit 2, Train "A"high.pressure safety injection system fiowpath was inoperable for approximately 5 years because of an incorrectly assembled check valve.

07/21/98 EEI IR 98-14 NRC OPS VIO EA 98-382 SL III LER 98-06 This EEI was issued as a SL IIIviolation with a total CP of $50,00 for all violations related to this inspection report.

See next item.

1A 2A 3A Three examples of an apparent violation of Technical Specification 3.0.3 were identified.

One example of not initiating actions, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, to place Unit 1 in a mode in which Technical Specification 3.5.2 did not apply when the Train "A"high-pressure safety injection system was declared inoperable because of a problem with a check vaive.

07/21/98 EEI LER IR 98-14 NRC

'OPS 1C EA 98-382 98-06 Two examples of performing online maintenance on the Unit 1 Train "A and Unit 2 Train "B"high-pressure safety injection system systems without isolation from the opposite train,.in excess of 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, while the associated high-pressure safety injection pump discharge check valves were inoperable.

This EEI was combined with the item above as part of the SL III violation.

Two.examples of an apparent violation of Technical Specification 6.8.1, which required that abnormal conditions be recorded in the control room logs. Abnormal conditions were not recorded in the Unit 2 control room logs when an unexpected safety injection tank level decrease occurred on October 10, and 28, 1997.

This EEI was not cited because corrective actions way already underway at the time the issue was discovered.

3

PLANT ISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 07/01I98 POS IR 98.05 NRC OPS 1B 06/29/98 VIO IR 98-05 NRC OPS 1A SL IV 05/30/98 POS IR 98-04 NRC OPS 3A QS/02/98 STR IR 98-Q3 NRC OPS 1A 05/02/98 STR IR 98-03 NRC OPS 1A 05/02/98 POS IR 98.03 NRC OPS 2B DATE TYPE SOURCE ID SFA TEMPLATE CODE 07/21/98 NEG IR 98-14 NRC OPS 5A ITEM The licensee's event investigation report was objective and provided a candid selt-assessment of its performance; however, it did not evaluate inspector-identified issues in the areas of operations or online maintenance.

These issues included: the failure to record in the control room logs the October 1Q and 28, 1997, unexpected safety injection tank level decrease events; and, the Impac~

on system operability of online maintenance on one train ot the high-pressure safety injection system when the opposite train had an inoperable pump discharge check valve.

Effective licensee decision making was demonstrated by the eva'iuation performed when uncertainty was identified in the ability to test trip functions associated with the tour core protection calculators channels ot local power density. Operations department performance was good as demonstrated by use of three-way communications during power changes, management oversight and direction, and development of an action plan to address operability issues The lock was missing on a normally-locked valve in the Unit 1 chemical and volume control system and was not documented, as required by procedure.

The failure to document the removal of a locking device resulted in a loss of configuration control and'is a violation of Technical Specification 6.8.1.a. This is a repeat violation from a June 1997 inspection Auxiliaryoperators conducted thorough checks of plant equipment with a good questioning attitude and attention to detail, as demonstrated by identification of a small oil leak on an emergency diesel generator and a high spray pond pump discharge pressure that indicated line blockage.

On March 17, Unit 1 was drained to the midloop condition by a crew dedicated to midloop operations.

Operator oversight and direction of the evolution and decisions to take conservative ~

actions during the evolution were excellent.

Licensee activities relaled to midloop operation demonstrated a strong safety tocus The licensee demonstrated good communications and a formal safety-conscience approach when performing refueling operations.

Operations exercised good judgement by suspending core alterations and movement of irradiated tuel in containment while a containment integrity issue was being resolved Observed portions ot the Unit 2 auxiliary feedwater system were consistent with the Updated Final Safety Analysis Report description, to the piping and instrumentation diagrams and procedure requirements.

The material condition of the system was good

PLANT ISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 05/02/98 P OS IR 98-03 NRC OPS 2B 05/02/98 POS IR 98-03 NRC OPS 2B DATE TYPE SOURCE ID SFA TEMPLATE CODE

~ ITEM Maintenance of the control room essential filtration system was very good as evidenced by the excellent material condition of the components.

The licensee's response to questions concerning control room stay times with the system operated in the isolation mode was good.

The observed as-built configuration of the Unit 3, "A"train of the containment spray system conformed to piping and instrumentation drawings. The licensee's analysis and design modification performed on the containment spray system, in response to Generic Letter 95-07 concerns, was well prepared and complete. The associated 10 CAR 50.59 evaluation was thorough. The material condition of the containment spray system including, circuit breakers, was good. The licensee maintained the containment spray system at a very high level of reliability.

The system engineer was very knowledgeable of the containment spray system 05/02/98 NCV IR 98-03 LIC OPS 1A A weakness in attention to detail by two licensed operators resulted in improper danger tagging of electrical disconnect switches.

This was an isolated situation and a non-cited violation of the clearance procedure 04/20/98 NEG IR 98-04 LIC OPS 3A During the Unit 1 startup, non-conservative decision making by the control room supervisor caused a conservatively set limitfor the power ascension ramp rate to be exceeded.

Other contributors to the, event were weakness in communications between the licensed operators and failure to include the reactor engineer in the pre-job brief for power ascension

PLANT ISSUES MATRIX PALO VERDE NUCLEAR'GENERATINGSTATION ENCLOSURE i DATE TYPE SOURCE ID SFA TEMPLATE CODE 11/14/98 POS IR 98-08 NRC MAINT 2A 10/03/98 POS IR 98-07 NRC MAINT 3A 08/22/98 NEG IR 98-06 NRC MAINT 3A 08/22/98 POS IR 98-06 NRC MAINT 3A 08/06/98 POS IR 98-15 NRC MAINT, 3A ITEM Material condition of all three units was good.

A proactive approach for the prevention of material condition deficiencies caused by boric acid corrosion was implemented by the licensee.

Pre-outage containment walkdowns and zone inspections of auxiliary building components resulted in the early identification of potential problems that would result from boric acid corrosion A weakness in attention to detail by an auxiliary operator while restoring a clearance resulted in the inadvertent start of Charging Pump E in Unit 1. Quick and proper actions by the control room operators to diagnose Ihe perturbation and realign the chemical and volume control system minimized the effect of the inadvertent start on the unit.

Receipt/inspection of new fuel was accomplished efficiently by knowledgeable personnel who used and adhered to approved procedures.

Maintenance personnel appropriately replaced the damaged letdown piping and pipe supports.

A lack of an adequate valve lineup initiallyprevented venting of the piping that resulted in a defect of the pipe weld and required replacing the pipe a second time.

PLANT ISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE CODE ITEM 07/21/98 EEI IR 98-14 NRC MAINT 3A 4C 5A VIO EA 98-382 SL III SELF.

LER 98-06 Five examples of an apparent violation of 10 CAR Part 50, Appendix B, Criterion XVIwere identified:

Two examples of a failure to identity and correct a condition involving excessive reverse flow through a high-pressure safety injection pump discharge check valve following two safety injection~

tank level decrease events on October 10 and 28, 1997.

Two examples ol inadequate corrective actions in the development of testing and maintenance procedures following operating experience assessments of NRC Information Notices 88-70 and 89-62. These actions failed to develop adequate testing procedures to identify excessive check valve reverse flowand adequate maintenance procedures for correct assembly of Borg-Warner check valves.

One example of a missed opportunity to correct an inoperable condition of a high-pressure safety injection pump discharge check valve when a personnel error was made during maintenance, resulting in the valve being reassembled incorrectly. This incorrect assembly resulted in a failure to correct excessive reverse leakage.

07/11/98 POS IR 98-05 NRC MAINT 2B 07/03/98 POS IR 98-05 NRC MAINT 3A 06/09/98 POS IR 98-05 NRC MAINT 1B This EEI was issued as a SL IIIviolation with a total CP of $50,00 for all violations related to this inspection report.

Performance of surveillance tests during the Unit 1 outage was good, as determined by a review of 20 surveillance test packages.

The tracking of interval-based surveillance tests effectively scheduled tests, which prevented exceeding the expiration date, as determined by a review of the~

surveillance tracking database Electrical maintenance performed good troubleshooting activities on Startup Transformer NAN-X02. During the restoration of the startup transformer, good communications, and management oversight were noted. Work control tagging was properly administered throughout all phases of the troubleshooting activities Operations personnel conducted effective prejob briefs and demonstrated good communication practices during the testing of the Unit 2 steam-driven auxiliary feedwater pump. Auxiliary operators demonstrated good attention to detail during the test as demonstrated by the identification of minor material deficiencies and errors in procedure drawings 7

PLANT ISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE CODE ITEM 05/30/98 NCV 05/02/98 VIO IR 98-04 LIC MAINT 3A IR 98.03 SELF MAINT 3A Weakness in attention to detail by instrumentation and control technicians res'ulted in a failure to conduct required maintenance retests.

On three separate occasions, retests were not performed as specified by maintenance procedures A violation was identified by the licensee for failure to comply with procedure prerequisite steps that required action to correct a low level in the fuel transfer canal prior to relocating a spent fuel assembly within the spent fuel pool. The failure to raise fuel transfer canal level as required resulted in unexpectedly high radiation levels in one location inside the fuel buitding 05/02/98 POS IR 98-03 NRC MAINT 2A 05/02/98 NEG IR 98-04 LIC MAINT

~

2A 3A.

05/02/98 POS IR 98-03 NRC MAINT 4B 05/02/98 VIO IR 98-03 NRC MAINT 3A Observable material condition of the three units was good. Material condition of the interior of components disassembled for the Unit 1 outage was also good. Material condition of equipment in the Unit 1 containment was good Inadequate reinstallation of a vibration probe flange on Unit 1 Main Feedwater Pump A during the Unit 1 outage allowed oil to leak onto the pump high pressure journal bearing. The oil ignited and resulted in a small fire that was extinguished quickly. Subsequent corrective actions for the event were comprehensive, effective, and timely.

The permanent repair of a leak in the Unit 1 Steam Generator 2 downcomer sampling line was consistent with the system design requirements.

By seal welding the threaded fitting at the connection1o the steam generator nozzle, the licensee had taken additional conservative

measures, beyond the design requirements, to ensure system leak tightness Engineering personnel performed boroscope inspections of the Unit 1 "A"Emergency Diesel Generator cylinder liners prior to obtaining authorization from maintenance personnel to start the ~

work, a violation of TS 6.8.1 and the Conduct of Maintenance procedure

PLANTISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 11/14/98 NEG IR 98-08 NRC ENG 4B 10/03/98 NEG IR 98-07 NRC ENG 4A 3A 08/06/98 POS IR 98-15 NRC ENG 4A 08/06/98 NCV IR 98-15 LIC ENG 4A 07/21/98 URI IR 98-14 NRC ENG 4A 4C 07/11/98 POS IR 98-05 NRC ENG 5A 05/06/98 POS IR 98-04 NRC ENG 4B 05/02/98 POS IR 98-03 NRC ENG 4B DATE TYPE SOURCE

'D SFA TEMPLATE CODE 11/14/98 NEG IR 98.08 NRC ENG 2B ITEM The engineering disposition of foreign material left in the Unit 3 reactor vessel was thorough and reasonable.

Better planning of the retrieval operation would have allowed recovery of the material.

In general, the licensee's response to correct the pinhole leak in the service water supply line to the water-to-air aftercooler of Unit 1 Emergency Diesel Generator B was adequate.

However, the initial safety evaluation, to provide a conditional release from applying the epoxy coating to the pipe interior until the next refueling outage, did not adequately consider the affects of the damaged epoxy coating on other system components should the coating not adhere to the pipe.

The initial documented evaluation of an information notice did not fullyaddress the issue of the refueling water tank level instrumentation being affected by the fuel building ventilation system.

However, instrument uncertainty appropriately accounted for the maximum tevel error that the refueling water tank would experience due to ventilation system operation Licensee engineers performed comprehensive evaluations of numerous facets of the event to determine the equipment root cause of failure.

The nonrepetitive, licensee-identified, low-safety significant, failure to install the Updated Final Safety Analysis Report, Chapter 15.6.2, described letdown flow hi/lo alarm in all three Palo Verde units was identified as a noncited violation pursuant to Section VII.B.1 of the NRC Enforcement The licensee did not update design documents when it implemented a design change to a high-pressure safety injection pump discharge check valve. This issue is unresolved pending NRC review of the licensee's condition report evaluation for this issue and further review of the adequacy of the licensee's design control process.

Licensee actions to identify deficiencies and initiate corrective actions associated with a plant modification, which installed flow meters in the spent fuel pool cooling system were good. The licensee identified that incorrect materia'I had been used to install the flowmeters; however, the use-as-is evaluation provided appropriate justification based on testing and material type Engineering support for the Furmanite repair to the regenerative heat exchanger shell side vent was good.

Licensee plans to address operational and equipment problems resulting from the inability of some components and computer software to correctly interpret some dates that occur before and after the year 2000 were excellent

PLANT ISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE CODE ITEM 05/02/98 POS IR 98.03 03/07/98 NCV IR 98-02 NRC ENG 4B LIC ENG 4A The licensee's 10 CAR 50.59 screening and evaluation for the modification to add an inspection port to Unit 1, Steam Generator 1 was thorough, comprehensive, and clear The licensee had not adequately maintained design control for startup transformer voltage in degraded voltage sceanrios.

The licensee event report which reported this condition was not se)f-~

critical in that it did not report or discuss the loss of design control as a root cause.

A noncited violation [in accordance with Section VII.B.1 of the NRC Enforcement Policy] was identified for failure to maintain adequate design control.

11/29/97 STR IR 97-17 NRC ENG 4B Engineering evaluation of a failed Unit 2 reactor coolant pump lower journal bearing and the support of maintenance organization repair efforts was excellent.

11/07/97 NCV IR 97-25 LIC ENG 4A One noncited violation Iin accordance with Section VII.B.1 of the NRC Enforcement Policy] was identified for the inability of the auxiliary feedwater system to automatically provide feedwater to the steam generators upon an auxiliary feedwater actuation signal under certain accident conditions.

-11/07/97 VIO SL IV IR 97-25 NRC ENG 4C One violation [of 10 CAR Part 50, Appendix B, Criterion V] was identified for failure to have adequate acceptance criteria for the inspection of the reactor coolant pump motor lubricating oil collection system flexible covers.

10/18/97 STR IR 97-1 6 NRC ENG 4A 4B Engineering performed an accurate calculation and generated a good temporary procedure to verify (by testing) the adequacy of the shutdown cooling system to cool the fuel in the reactor vessel and supplement the spent fuel pool cooling system, as required by the Updated Final Safety Analysis Report. Although the calculations indicated performance of the test was unnecessary, the decision to verify the calculations through testing was a good example of conservative plant operations.

10

PLANTISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE1 11/20/98 VIO IR 98-13 NRC PS 2B SL IV 11/20/98 POS IR 98-13 NRC PS 2B 11/20/98 STR IR 98-13 NRC PS 2B 11/20/98 POS IR 98-13 NRC PS 2B DATE TYPE SOURCE ID SFA TEMPLATE CODE 11/20/98 POS IR 98-13 NRC PS 2B 11/20/98 POS IR 98-13 NRC PS 2B ITEM A very good program for searching personnel, packages, and vehicles was maintained A proper protected area barrier was in place Changes to security plans were reported within the required time frame. Revision 40 to the physical security plan was a violation in that changes were not made in accordance with 10 CAR 50.54(p).

Implementing procedures met the performance requirements in the physical security plan A very good security event reporting program was in place. The security staff was correctly reporting security events.

The security field reports were accurate and neat The licensee effectively implemented the safeguards contingency plan in response to a bomb threat.

Senior management support for the security organization was very good. The security program was implemented by a well qualified and highly professional staft 11/20/98 POS IR 98-13 NRC PS 2B Audits of the security, access authorization, and fitness-for-duty programs were effective, thorough, and intrusive 11/14/98 POS IR 98-08 NRC PS 'A 09/10/98 NEG IR 98-07 NRC PS 1B 3A 08/24/98 STR IR 98-16 NRC PS 3A Implementation ot radiological controls in the Unit 3 refueling outage was characterized by

'excellent radiation protection controls and effective radiation work practices.

Source term reduction eftorts were successful in reducing overall radiation exposure.

An untimely initial declaration (44 minutes) of a Notification of Unusual Event was made in response to rupture ot the Unit 1 sulturic acid day tank because the shift manager left the control room to personally assess the scene instead of implementing his emergency response responsibilities Radiation exposure controls were good. Radiological areas were posted properly and high radiation areas were controlled effectively. High quality pre-job briefings on radiological hazards and dose reduction techniques were provided to radiation workers.

Radiation protection technicians provided good oversight of work activities. Radiation survey information was current, and a good calibration program was maintained for radiation protection instruments.

Licensee controls worked eftectively to keep radioactive material inside the radiological contro!Ied area.

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PLANTISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 08/22/98 NEG IR 98-06 LIC PS 3A 07/11/98 POS IR 98-05 NRC PS 3A 06/29/98 POS IR 98-05 NRC PS 1C 05/27/98 NEG IR 98-04 NRC PS 5C 1C 05/27/98 NEG IR 98.04 NRC PS 1C 05/27/98 POS IR 98-04 NRC PS 1C DATE TYPE SOURCE ID SFA TEMPLATE CODE 08/24/98 STR IR 98-16 NRC PS 3A ITEM A good audit of the radiation protection program was performed by the Nuclear Assurance Division. Theaudit teamconsistedofmembersthatwerewellqualified.

Thescopeanddepthof review were appropriate, and the audit findings demonstrated that the audit findings demonstrated that the audit was selt-critical.

Failure to adhere to radiation exposure permit requirements, poor communications, and lack of a questioning attitude by radiation protection technicians resulted in the release of airborne radioactive material inside the Unit 1 radwaste building truck bay. This resulted in widespread contamination of the truck bay. Four workers were also contaminated, one of which was assigned a minor uptake. The failure to followradiation exposure permit requirements is a noncited violation of Technical Specification 6.8.1. Radiation protection management's initial corrective actions and recovery plan were effective. Planned corrective actions appeared to be comprehensive to prevent recurrence.

Good radiological practices were followed during performance of surveillances to measure chemistry and specific activity of the reactor coolant system.

The chemistry technician was knowledgeable of the procedures and of the usage of the test instrumentation Radiological protection postings of observed radiation, high radiation, and locked high radiation areas were accurate for existing conditions.

Radiological housekeeping practices in observed contaminated areas were adequate.

Decontamination activities and subsequent surveys of the letdown heat exchanger valve gallery aftera letdown line break in the room were satisfactory Corrective actions for improvement of the emergency plan exercise scenario development process in response to an exercise weakness were not fullyeffective in that a scenario was created which did not provide sufficient information for operators to promptly recognize and declare the desired Emergency Action Level.

The Emergency Response Organization critique process was effective in identifying areas in need of corrective action. -However, the severity of identified weaknesses was not accurately reflected in the drill report.

The training program for the emergency response organization was effectively implemented, as demonstrated from the 50 records reviewed by the inspectors.

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PLANT ISSUES MATRIX PALO VERDE NUCLEAR GENERATING STATION ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE CODE 05/27/98 NEG IR 98-04 NRC PS 1C 05/27/98 POS IR 98-04 NRC PS 1C 05/06/98 POS IR 98-04 NRC PS 3A IT.EM Relocation of the Operations Support Center to an alternate facilityduring the annual emergency preparedness exercise was disorganized, which extended the amount of time taken to attempt the relocation.

Because ot this, an opportunity to demonstrate operations from the relocated OSC was missed.

Performance of the Technical Support Center staff during the annual emergency preparedness exercise was good. The staft demonstrated effective communications, with trequent and informative briefings provided by the emergency coordinator.

Good access control and accountability were established and maintained.

Radiological planning for the Furmanite repair ot the regenerative heat exchanger shell side vent valve was good. The as-low-as-reasonably-achievable (ALARA)review reduced the area dose rate from 500 to 75 mRem/hr and the total exposure for the job did not exceed 592 mRem.

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ENCLOSURE 2

/)arr OiKNI)RAI.DI <iCRIPTION OF Plhl TADI.I'.I.ADKI/8 Actual date of an cvcnl or significant iv>>sc for th<>sc I!en>a that have a clear dale ofoccurrence. Ihe date thc source of the inforn>ation was issued (such as the I.KR date). or, for inspection rcport>> thc Ia>t date of thc in<p<clion period.

Fypr

'llie categorization of lhc issue-sce lhe Type Ilcm Code table.

SF>l Sourrrs SAI.I'unctional Area Codes: OI'S f<>r Operations; MAINTD>r h'laintenance; ENG for Engineering: and PS for.Plant Support.

'I'he document that cnnlains lhc Roue information: IR for NRC Inspection Report or DER for l.iccnsce Event Rcport.

/ssur /)rsrnplion Idcnlillcation of >> ho discovered issue: N for NRC; I. for I.icensee; or S for Self Identilying (events).

Details of lhc i<<suc from thc I,KR text or from the IR Executive Summaries.

('adrs Template Codes - sec table.

KD Strength

)Veakncvs Kl'.I a VIO TYI'KITEM CODIS Knforccmcnt Action l.clter with CivilPenally Knforcemcnt Discretion - No CivilPenalty O>crall Strong I.icen<ce Pcrfnrmance (Derail )Yeuk I.iccnsec Performance Escalated Knforccmenl item - iYaiting Final NRC Action Violation l.cvcl I. H. HI.or IV Non.Cited Violation TEMPIATECODES Operational Performance: A - Normal Operations; 8-Operations During Transients; and C-I'rograms and Processes Material Condition: *- Equipment Condition or 8 - Programs and Processes Human Performance: A - iVorkPerformance; 8-Kno>>tedge. Skills. and Abilities/Training: C- )York Fn> ironment Engineering(Designs A - Design; 8 - Engineering Support; C - Programs and Processes Problem Identification and Resolutiont A - IdentiYication; 8-Analysis; and C-Resolution DFV I'<nili>e Negusl>

e URI av l.iccnsing MI!IC Deviation from I.iccnsec Commitment lo NRC Indi>idual G<xxl Inspection Finding Individual Pi>or Inspection Finding l.iccnscc K>cnl Report lo the NRC Un'>i>cd Item from Inspection Report IScenting Issue from NRR hlisceliancous - Emergency Prcparcdness lqnding (FP),

Declared Emergency. Nonconformance Issue, etc.

worm a

~ 1 EEls are apparent violations of NRC requirements that are beiiig comidered for escalated enforcemcnt action in accordance <<ith the General Statement ofPolicy and Procedure for NRC Enforcement Action (Enforcenicnt I'<jticy),

NUREG.I6OL Ho<<ever, the NRC has not reached its final enforcement decision on the Issues identitied by the KKIs and the pthl entries may be rnoditied <<hen the final dccisdions are made. Itefore the NRC makes its enforcement decidon, the licemce villbe pro> idcd <<ith an opportunity to either (I)respond to the apparent

<ida <ion or (2) rcque>t a prcdcciuonal cnforccment conference.

URls arc un esot>cd iten>> about <<hich more information is rcquircd to deternune <<br<her the issue in quc><ion is an

~p a c i e"x a deiiation, a nonconformance, or a viotatio<x Ito>>ever, the NRC has not reached its final conc)I>don< on thc Is~ and the PISI en<rie may be modilicd <<hrn the C>nal con<(usta<>> are mack.

PALO VERDE NUCLEAR GENERATING STATION INSPECTION PLAN IP - Inspection Procedure Tl - Temporary Instruction Core Inspection - Minimum NRC Inspection Program (mandatory all plants)

INSPECTION IP 82301 IP 81700 IP 83750 IP 73753 IP 84750 IP 86750 TITLE/

PROGRAM AREA Emer enc Plannin Exercise Securit Pro ram Radiation Protection Pro ram Inservice Ins ectionPro ram Environmental Protection Pro ram Trans ortationPro ram NUMBER OF PLANNED INSPECTORS INSPECTION DATES 03/08-11/99 03/22-26/99 04/05-09/99 04/12-16/99 05/03-07/99 05/10-14/99 TYPE OF INSPECTION COMMENTS Core Ins ection Core Ins ection Core lns ection Core Ins ection Core Ins ection Core Ins ection IP 81700 IP 93809 TI 2515/139 IP 83750 IP 37001 IP 64704 NA IP 40500 Securit Pro ram Safet S stemEn ineerin Ins ection Generic Letter 96-01 Followu Radiation Protection Pro ram 50.59 Program Review Fire Protection Pro ram Senior Reactor 0 erator Examinations Review of Corrective Action Program 2

06/07-11/99 06/1 4-18/99 07/26-30/99 08/02-06/99 08/30-09/03/99 08/30-09/03/99 12/06-10/99 Core Ins ection Core Ins ection Generic Safet Initiative Core Ins ection Core Inspection Core Inspection

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