ML20056E369
| ML20056E369 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/29/1993 |
| From: | Ang W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20056E367 | List: |
| References | |
| 50-528-93-24, 50-529-93-24, 50-530-93-24, NUDOCS 9308230249 | |
| Download: ML20056E369 (33) | |
See also: IR 05000528/1993024
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U.S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos:
50-528/93-24, 50-529/93-24, and 50-530/93-24
Docket Nos:
50-528, 50-529, and 50-530
License Nos:
Licensee:
Arizona Public Service Company
P. O. Box 53999, Station 9082
Phoenix, Arizona 85072-3999
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Facility Name:
Palo Verde Nuclear Generating Station
Units 1, 2, and 3
Inspection at:
Palo Verde Nuclear Generating Station
Units 1, 2, and 3
Wintersburg, Arizona
Inspection Dates:
Weeks of, May 24, Jcne 7, and June 28, 1993
Inspectors:
M. Royack, Reactor Inspector
W. Wagner, Reactor Inspector
D. Acker, Reactor Inspector
7-2/.91
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Approved by:
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W. P. Ang, Engineering Section Chief
Date Signed
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Inspection Summary:
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An announced routine inspection was conducted at the Palo Verde Nuclear
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Generating Station during the weeks of May 24, June 7, and June 28, 1993
(NRC Inspection Report Nos. 50-528/93-24, 50-529/93-24, and 50-530/93-
24).
Areas Inspected:
This routine announced engineering inspection reviewed: your corrective
actions for previously identified NRC inspector followup and enforcement
items, onsite follow-up of licensee event reports, and erosion corrosion
piping weld overlay repairs and program. NRC Inspection Procedures
92700, 92701, 92702, and 49001 were used as guidance for this
inspection.
9308230249 930730
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Conclusion:
Emeroency Lichtina
Follow-up inspection of previously identified items indicates that
management and engincering corrective actions resulted in increased
availability of the emergency lighting systems (from below 60% to
above 90%).
The licensee had revised their quality assurance (QA) program to
include all provisions of the fire protec. tion program described in
the Final Safety Analysis Report (FSAR).
Erosion Corrosion
The licensee had performed weld overlay analysis and repair of
piping in accordance with licensee erosion corrosion and welding
procedures.
The licensee had performed erosion corrosion non destructive
examination (NDE) ultrasonic test (UT) thickness inspections in
accordance with their procedures. However, licensee erosion
corrosion procedures did not provide guidance to HDE UT thickness
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inspectors for documenting piping flaws or anomalies observed
during the inspections.
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Licensee Event Reports and Open Items
Closed
The licensee had taken adequate corrective actions for closure of:
licensee event reports fLER) 50-528/84-01-LO, 50-528/92-015-LO, 50-
528/89-17-LO, and 50-528/92-10-LO; unresolved item 50-
528/529/530/92-43-05; NRC Notices of Violation 50-528/529/530/93-
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09-01, 50-528/529/530/90-25-01, 50-528/529/530/92-14-03; and
inspector follow-up item 50-528/529/530/91-28-08.
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Open
No new violations, deviations or open items were identified.
Strenoths and Weaknesses:
Strenaths:
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Management and engineering attention and involvement in
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correcting previously identified emergency lighting problems
was evident in the increased availability of the emergency
lighting system.
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Weaknesses:
Licensee erosion corrosion procedures did not provide guidance
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to non destructive examination (fide) ultrasonic (UT) thickness
inspectors for documenting potential piping defects observed
while performing thickness examinations.
Safety Issues Manaaement System (SIMS) Item:
No SIMS items were_ reviewed during this inspection.
Sianificant Safety Matters:
No significant safety matters were identified during this inspection.
Summary of Violations or Deviations:
No violations or deviations of NRC requirements were identified during
this inspection.
Open Item Summary:
One enforcement item was updated; and three violations, one unresolved
item, one inspector follow-up item, and four licensee event reports were
closed.
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Details
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Persons Contacted
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The below listed technical and supervisory personnel were among
those contacted:
Arizona Public Service
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- J. Auston, Deputy Chief, Fire Protection Program
- J. Bailey, Assistant Vice President, Engineering and Projects
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- R. Bouquot, Supervisor,. QA Audits
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R. Bernier, Supervisor, Nuclear Regulatory Affairs
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- T. Cannon, Supervisor, Inservice Inspection and Testing
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- C. Clapper, Supervisor, Performance Engineering
- D. Crozier, Fire Department Supervisor
M. Czarnyins, Supervisor, Fire Protection Program
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- D. Elkinton, Acting Supervisor, Quality. fionitoring
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R. Fountain, Supervisor, QA Monitoring
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R. Fullmer, Manager, QA Monitoring
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- *D. Garchow, Manager, Performance Engineering
- F. Garrett, Manager, Fire Protection Program
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- R. Gouge, Director, Plant Support
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- *D. Kanitz, Senior Engineer, Nuclear Regulatory Affairs
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- A. Krainik, Supervisor, Nuclear Engineering Department Mechanical
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- M. Howe, Supervisor, Fire Protection Support Services
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- D. Leech, Supervisor, QA Corrective Actions
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- D. Oakes, Supervisor, Component Condition Monitoring
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- G. Overbeck, Director of Site Technical Support
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- S. Penick, Supervisor, Independent Safety Engineering
, F. Poteet, Senior ISI Engineer, Component Conditioning Monitoring
- M. Powell, Manager, Fire Protection Support Services
- C. Russo, Manager, Quality Control Administration
- D. k' ebb, Technical Advisor, Fire Protection
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Non-APS Representatives
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- J. Drapper, Southern California Edison
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- F. Gowers, El Paso Electric
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- *R. Henry, Salt River Projeci.
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NRC
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- J. Sloan, Senior Resident Inspector, Palo Verde
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- H. Freeman, Resident Inspector, Palo Verde
Denotes personnel in attendance at the exit meeting held on
June 11, 1993.
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Denotes personnel in attendance at the exit meetings held on
July 1, or July 2,1993.
The inspectors also interviewed other licensee personnel during the
inspection.
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2.
Onsite Review of Non-Routine Events (92700)
a.
(Closed) Licensee Event Report (LER) 50-528/84-01-LO * Fire
Barrier Penetration Seals"
LER Backaround
Licensee event report (LER) 528-84-01-LO, reported that on
June 15, 1988 an engineering evaluation report (EER) was
dispositioned identifying that certain fire rated penetration
seals had not been included in Station Manual Procedure 14AC-
OZZ01, Fire System Impairment.
Since the seals had not been
included in procedure 14AC-0ZZOI, the seals had not been
tested as required by Technical Specifications and Final
Safety Analysis Report Section 9.5.1.4.
In an initial
sampling to determine the extent of the problem, the licensee
inspected penetration seals that were identified in the EER
and found eight impaired seals and fourteen unsealed
Licensee Corrective Actions
The licensce performed a 100% inspection of fire barrier
penetrations in Units 1, 2, and 3.
The licensee's inspection
included approximately 10,000 individual equipment
identification points (walls, penetrations, barriers, seals,
etc) for Units 1, 2, and 3.
The licensee's inspection
identified 1,437 instances where inspection acceptance
criteria was not met or the installed configuration
requirements were not clear. The discrepancies were
documented in material non-conformance reports (MNCRs) in
accordance with their inspection procedure. Approximately one
third of the licensee identified discrepancies were evaluated
for reportability. The licensce's reportability review
ccacluded that none of the identified discrepancies would have
adversely affected the ability of the facility to achieve and
maintain safe shutdown in the event of a fire and were not
reportable.
The remainder of the discrepancies were not
evaluated for reportability.
The licensee concluded that since all of the discrepancies
were not evaluated for reportability an LER should be issued
to cover all of the discrepancies. The licensee issued LER
50-529/90-09-L1 and took corrective actions for the
discrepancies.
As immediate corrective action for LER 528/84-01-LO and 50-
529/90-09-L1 the licensee initiated fire watches in all three
units as a compensatory measure for the impaired penetration
seals.
Licensee corrective action to prevent recurrence was to revise
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procedure 14AC-0ZZ01, Fire System Impairment, to include all
fire rated assemblies that were identified.
Including all
fire. rated assemblies in procedure 14AC-0ZZ01 ensured that all
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of the.arsemblies would be included in routine surveillance.
The licensee initiated appropriate documents for rework of all
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the impaii ed and missing penetration seals.
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Previous NRC Followuo Inspections
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NRC inspectors had previously reviewed licensee event reports .
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528/84-01-LO and 50-529/90-09-L1 corrective actions. The
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result of these inspections were documented in NRC Inspection
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Reports 50-528/89-54, 50-528/90-20 for LER 528/84-01-LO, and
50-528/529/530/93-09 for LER 50-529/90-09-LI.
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NRC Inspection Report 50-528/90-20 concluded that LER 528/84-
01-LO would remain open pending the licensees completion of a,
100% inspection of all 10 CFR Part 50 Appendix R fire barrier
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penetration seals. The results of the insp' ction would be -
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compared with design requirements and as-built configurations.
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Seals found not to be in conformance with design document
requirements would be evaluated to determine if a revision to
the design documents or the penetration seal was required.
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NRC Inspection Report 50-528/529/530/93-09 concluded'that the
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licensee had performed a 100% inspection.of 10 CFR Part 50
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Appendix R fire penetration seals, had correctly determined
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that the discrepancies found in the fire barrier and
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penetration seals were not reportable, and that the licensee
was taking actions to correct identified anomalies. The
inspector also concluded that the licensee's corrective -
actions were appropriate to address and repair penetration and;
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seal deficiencies. Since the inspector concluded appropriate
corrective actions were being taken, the inspector closed LER
50-529-90-09-LI.
NRC Inspection of licensee LER Actions
The inspector reviewed licensee procedures 14AC-0FP01, Fire
System Impairments, revision 03.02 and 14DP-0FP02, Fire System
Impairments and Notifications, revision 01.04.
Licensee
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procedures 14AC-0FP01, Fire System Impairments, and 14DP-
0FP02, Fire System Impairments and Notifications, replaced
licensee procedure 14AC-0ZZ01, Fire System Impairment, on
November 1, 1989. The inspector verified that the licensee
had incorporated fire barriers and penetration' seals into
procedure 14AC-0FP01. The inspector also verified that the
licensee had placed fire protection systems,' components,
penetration seals, and barriers on the station information
management system (SIMS). The SIMS data base tracks the
condition and status of fire protection systems, components,
penetrations and seals for Units 1, 2, and 3.
The inspector
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selected fifteen penetration seals to verify that the seals
were included in the SIMS and that the current status of the
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seals ~were complete.
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The inspector found that the fifteen seals selected for review
were included in the SIMS tracking system and that the status
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and condition of the seals were complete. The inspector
visually inspected five of the fifteen seals and confirmed
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that the.r location and condition was as stated in the SIMS
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tracking system.
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Conclusio' n
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The inspector. concluded that the corrective actions as stated
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in LER 50-528/84-01-LO had been completed, and that the
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licensee had updated fire impairment' procedures and SIMS
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program to include fire rated penetration seals.
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This item is closed. No violations or deviations of NRC
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requirements were identified.
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b.
(Closed) Licensee Event Report (LER) 50-528/92-015-l0: Unit 1
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Loss of Turbine Driven Auxiliary Feed Water Pump Due to a Fire
in Fire Zone 74B
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LER Backaround
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On November 18, 1992, the licensee's Appendix R Reconstitution
Project identified that a design basis fire in the main steam
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support structure (Train "B", fire zone 74B), concurrent with
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a loss of off-site power, could result in a loss' of the
essential air cooling unit (ACU) to the redundant train of
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safe shutdown equipment (i.e. Train "A" turbine drive
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auxiliary feedwater (AFW) pump).
Loss of both trains could
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occur due to an unprotected Train A ACU cable in Train B fire
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zone 74B. Thus a single fire could result in the loss of two
trains of safe shutdown equipment and could adversely affect
the ability to achieve and maintain safe shutdown.
The licensee calculated that the loss of the Train."A" room
ACU cooling would allow the room air temperature to rise to
140 degrees Fahrenheit within one hour and thirty minutes.
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This high room air temperature could cause a loss of the Train
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"A" turbine driven AFW pump.
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The cause of this postulated event was the omission of an
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unprotected control circuit cable [E-HA06-AC-IRD(CBL5)] for
the Train "A" essential ACU from the original Appendix R
evaluation.
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The inspector reviewed condition report / disposition request
(CR/DR) number 9-2-0636.1 and noted that it stated the
following:
The design of the ACU contained two parallel start and
run circuits for automatic starting of the associated
ACU. The loss of unprotected control circuit cable E-
HA06-AC-IRD could occur as the result of a fire which
caused a short to ground. Tais cable short could make
the'. Train A ACU inoperable by disabling both of the
parallel start and run circuits via failure of two
associated 2.5 amp fuses.
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The cable was not physically protected with a one hour
fire rated wrap for approximately 18 inches. The cable
was installed in a flexible conduit for these 18 inches.
The licensee issued design change package (DCP) number
1,2,3 FE-HA-046, Revision 0, on December 12, 1990, to
install a separate fuse for this cable in all three
units.
The separate fuse would allow continued operation
of Train A ACU, with a short in cable E-HA06-AC-1RD,
because it would separate the two parallel start and run
circuits and allow the un-faulted circuit to start and
run Train A ACU. At the time of this inspection, this
DCP was scheduled to be implemented in all three units by
the end of 1996, but the licensee identified they were
reviewing this implementation date to see if it could be
moved up.
Fire Zone 74B was equipped with an automatic fire
detection and suppression system. The installed early
warning alarm would allow the on-site Fire Department to
respond while the fire suppression system acted to
minimize the fire damage.
Fire Zone 74B had an open roof
design which would prevent the development of a hot gas
layer in the proximity of the affected circuits and would
aid fire fighting efforts.
Licensee Corrective Actions
The licensee had implemented the following corrective actions
for the noted condition:
Compensatory fire watches for fire zone 74B in all
operating units were initiated. These compensatory fire
watches were scheduled to be maintained in operating
units until electrical protection was provided for cable
E-HA06-AC-1RD.
Revision 6 to the Pre-Fire Strategies Manual for Fire
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Zone 74 B was issued to incorporate actions to replace a
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fuse to restore Train "A" ACU in the event it was
disabled due to a fire in Fire Zone 74B. The inspector
determined that replacing this fuse would restore power
to the undamaged parallel start and run circuit for Train
A ACU, while leaving out another failed fuse would
isolate the fault on cable E-HA06-AC-1RD.
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Revision 03.01 to licensee procedure 14FT-9FP06, " Fire
Equipment Locker and Emergency Equipment Cabinet
Inspection," was issued to ensure 2.5 Amp fuses were
maintained along with a pair of protective gloves in the
Appendix R cabinet in the control rooms. These fuses
will be used as required to restore a Train "A" ACU in .
the event it is disabled due to a fire in Fire Zone 74B.
NRC Inspection of Licensee Actions
Based on discussions with the licensee staff and review of the
above information, the inspector concluded satisfactory
actions had been implemented to resolve any electrical
problems with cable E-HA06-AC-IRD due to a fire in Fire Zone
748 due to:
Interim corrective actions.
Existing fire protection and suppression systems
Commitment to install a design change which will allow
operation of Train A ACU independent of any potential
faults in Fire Zone 74B.
This item is closed.
No violations or deviations of NRC
requirements were identified.
c.
(Closed) Licensee Event Report (LER) 50-528/89-17-LO. "Four
Penetrations in Gap Between Diesel Generator (DG) Buildino and
Control Buildino lack Fire Barrier Separation"
LER Backaround
During an October 23,1993, Unit 3 visual inspection of the
diesel building pipe trenches, four unsealed penetrations into
the seismic gap area between the diesel generator building and
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the control building were discovered by the licensee. The
equivalent penetrations in Units 1 and 2 were also visually
verified to be unsealed.
The LER also identified that there existed a potential for a
flammable or combustible liquid spill-type fire in one diesel
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generator area to migrate from one diesel generator area to
the other. This condition could have caused a loss of both
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emergency diesel generator units.
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licensee Actions
The licensee immediately initiated fire watches in the area,
and initiated a plant change request to seal the four pipe
trench penetrations. The licensee also initiated a design
change package to address the flammable or combustible liquid
spill-type fire in the area.
The pipe trench penetrations would be sealed with three hour
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fire rated seismic gap seals. A curb to contain flammable or -
combustible liquid would be installed at door G-101 (entrance
to train "A" diesel control equipment room), and door G-101
would be replaced with a 72" door. A curb to contain
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flammable or combustible liquid would also be added to the
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entrance of the train "B" control equipment room.
Previous NRC Follow-up Inspections
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NRC Inspection Report 50-528/529/530/93-02 reviewed the status
of I.ER 50-528-89-17-LO. The inspector concluded that the LER
would remain open until the design change package (DCP) (to
install the curbs) was scheduled for implementation.
NRC Inspection of Licensee LER Actions
The inspector reviewed licensee plant change request 89-13-FP-
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062 and site modification packages 1-2-3-SM-FP-013 for the
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installation of three hour fire barrier seals in the seismic
gap area between the diesel generator building and the control
building for Units 1, 2, and 3.
The inspector also visually
inspected one of the penetrations and found that the
installation had been completed. The inspector found that the
licensee had completed the installation of three hour fire
barrier seal packages.
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The inspector reviewed Units 1, 2, and 3 limited design change
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package (LDCP) 1-2-3 LC-ZG-022, Diesel Generator Flooding
Control, for the installation of curbs to prevent flammable or
combustible liquids from migrating from one diesel generator
arer. to the other. The inspector found that the licensee's
design of installation of the curbs and door replacement was
consistent with the conclusions of the licensee's flooding
analysis for that area.
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The modifications to add curbs for the entrances to the train
"A" and "B" diesel generator control equipment rooms and to
change door G-101 to a 72" door were approved for final
engineering and implementation during Plant Modification
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Committee (PMC) meeting 93-2, held on February.23, 1993. The
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modifications were scheduled to be installed as follows: Unit
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during the 2N5 operating cycle by September,1994; and Unit 3,
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by 3N5 operating cycle by September,1995.
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Conclusion
The inspector concluded that.the licensee had installed the
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three hour fire barrier seals in the pipe trench penetrations
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in the seismic gap area between the diesel generator building
and control building for the three units. The licensee had-
funded and approved the installation of curbs to' prevent
migration of flammable or combustible liquids-from one diesel
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generator area to another. The inspector verified that fire
watches were planned to. remain in place until all fire barrier
seals discrepancies had been corrected and the curbs
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installed.
This item is closed. No violations or deviations of HRC
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requirements were identified.
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(Closed) Licensee Event ReDort 50-528/92-010-LO.~" Loss of HVAC
Coolino to Both Trains of Shutdown Ecuipment Due to postulated
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LER Backoround
On May 20, 1992, during an engineering design basis
reconstitution review of 10 CFR 50, Appendix R. fire protection
systems it was determined that a loss of offsite power,
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concurrent with a design basis Appendix R fire in the train
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"B" engineered safety features (ESF) switchgear room, the
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train "B" battery rooms located on the 100 foot elevation of
the control building, or in the entrance to the control
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building on the 100 foot elevation of the corridor building,
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could result'in the loss of essential heating, ventilation,
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and air conditioning ~(HVAC) to the redundant train of safe:
shutdown equipment (i.e., train "A" ESF switch gear' room,
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train "A" battery rooms, and train "A" DC equipment rooms).
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This condition could adversely affect the ability to achieve
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and maintain safe shutdown in the event of a fire since train
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"A" safe shutdown equipment may become inoperable due to
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excessive high temperatures.
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Licensee Actions
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Immediate
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The licensee established hourly fire watches _in the train "A"
engineered safety features (ESF) switchgear room and the
corridor building in accordance with procedure 14AC-0FP01,
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Fire System Impairment. A continuous fire watch had been
previously established in the train "B" ESF switchgear room.
Permanent
The licensee issued a plant change request (PCR) to
reconfigure the existing fire protection detection and
suppression system (fire panels and associated wiring) located
in the 100 foot elevation of the control building and the
corridor building such that train "A" and train "B" associated
fire protection detection and suppression equipment and
control wiring would remain in their respective fire areas.
That is, train "A" fire detection and suppression equipment
control would be in a local fire protection panel in a
stairwell near the train "A" switchgear room, and train "B"
fire detection and suppression equipent control would be
located in a fire protection panel in the corridor of the 100
foot elevation. The licensee stated that locating the fire
protection panels in these areas would provide the separation
required to ensure that a fire in one train of ESF equipment
does not affect the operation of the redundant train. The
licensee issued PCR-92-13-FP-001 to perform these
modifications.
Previous NRC Follow-up Inspections
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NRC Inspection Report 50-528/529/530/93-02 documented a review
of the status of LER 528-92-10-LO. The inspector concluded
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that the LER would remain open until the licensee established
an action plan and schedule for implementation of the design
change package (DCP) included with the PCR.
NRC Inspection of licensee LER Actions
The inspector observed a Mrmanent fire watch in the Unit 3
train "B"
switchgear ror
and observed an hourly fire watch in
the train "A"
switchget
com. The licensee confirmed that
the fire watches would rs >=in in effect in accordance with
procedure 14AC-0FP01, Fire s/ stem Impairment, until plant
modifications were completed.
The inspector reviewed licensee Plant Modification Committee
(PMC) meeting minutes for PMC meeting 93-5, held on May 25,
1993. The inspector confirmed that the licensee's PMC had
approved the PCR-92-13-FP-001, Reconfigure Control Building
Fire Protection / Detection System, associated design change
packages, provided funding for the modification, and set the
schedule for completion for the three units. The schedule for
completion of the modification was: Unit 1, operating cycle
IN6, by September 1996; Unit 2, operating cycle 2N6, by
February,1996; and Unit 3, operating cycle 3NS, by September
1995.
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Conclusion
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The inspector concluded that the licensee had established a
schedule, approved funding, and approved the action plan for
PCR 92-13-FP-001, and that fire watches had been ~ established
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in the train
"A" and train "B" ESF switchgear rooms.
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This item is closed. No Violations or Deviations of NRC
Regulations were identified.
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3.
Previously Identified Violations (92702)
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a.
(0 pen) 50-528/90-25-02. Failure to Implement Fire Protection
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Ouality Assurance Procram
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Violation
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A Notice of Violation and a Proposed Imposition of Civil
Penalty (Notice) was issued for failure to implement an
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adequate Quality Assurance (QA). program for fire protection.
The notice of violation and proposed imposition of civil
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penalty was issued on October 16, 1990. The NRC enforcement
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Licensee Actions
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During an Enforcement Conference held in Region V on July 10,
1990, the licensee committed to submit a Fire Protection
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Justification for Continued Operation (JCO) regarding the
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application of the QA program to fire protection equipment.
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The JC0 was submitted to Region V on July 20, 1990.
On March
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26, 1993 the licensee's Plant Review Board approved ' closure of
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the JCO.
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Inspector Review of Licensee Actions
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The inspectors reviewed the Fire Protection JC0 to assure that
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the licensee had met their commitment to provide adequate QA-
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program coverage for fire protection. The licensee's QA
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program commitments are:
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License No. NPF-41, Condition 2.C(7) for Palo Verde Unit
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1, License No. NPF-51, Condition 2.C(6) for Palo' Verde
Unit 2 and License No. NPF-74, Condition No.1.F for Palo
Verde Unit 3, states in part, "APS shall implement and
maintain in effect all provisions of the approved fire
protection program as described in the Final Safety
Analysis Report (FSAR) for the facility, as supplemented
and amended, and as approved in the SER through
Supplement 11, subject to the following provision: APS
may make changes to the approved fire protection program
without prior approval of the Commission only if those
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changes would not adversely affect the ability to achieve
and maintain safe shutdown in the event of fire."
(2) FSAR Table 9B.3-1 describes how the fire protection QA
program complies with Appendix A of the NRC Branch
Technical Position (BTP) APCSB 9.5-1, Section C, " Quality
Assurance Program." Table 9B.3-1 requires the
development and implementation of a QA program to assure
that the requirements for design, procurement,
installation, testing, and administrative controls for
the fire protection program for safety-related areas as
defined by the BTP are satisfied. Revision 5 of the
updated FSAR, dated March 1993, revised Table 9B.3-1 to
state that the Operations Quality Assurance Plan,
-
Appendix F-1, has been developed and implemented to meet
these requirements.
(3)
FSAR Table 3.2-1, Section 16 lists the quality
classification for the fire protection system. When NRC
Inspection Report 50-528/90-25 was issued, the QA
program, as shown in Table 3.2-1, "only applied to the
fire protection water suppression systems, gaseous
suppression systems and hangers." Revision 5 to the FSAR
has expanded the QA coverage to include 33 principal
components of the Fire Protection System.
For example,
Table 3.2-1 includes the fire suppression and actuation
systems, fire detection and alarm systems, fire barriers,
and the emergency lighting system.
(4) The Palo Verde Nuclear Generating Station (PVNGS)
Operations Quality Assurance Plan, Appendix F-1 contains
the QA requirements for fire protection. The operations
QA plan was approved by the NRC in March 1992. Appendix
F-1 entitled " Quality Assurance for Fire Protection"
provides the Quality Assurance criteria for fire
protection c'onsistent with Branch Technical Position,
APCSB 9.5-1, Appendix A, and the NRC Guidance Letter
dated August 29, 1977, entitled " Nuclear Plant Fire
Protection Functional Responsibilities, Administrative
Controls and Quality Assurance." Quality assurance for
fire protection covers: design and procurement control;
instructions, procedures and drawings; inspection; test
and test control; inspection, test and operation status;
nonconforming items; correction action; records; and
'
audits.
The QA program requirements for fire protection as
outlined in the Operations QA Plan were implemented
_
through various procedures categorized as program
procedures or administrative control procedures.
Administrative Procedure No. 81AC-0CC06 entitled
" Classification of Structures, Systems, and Components"
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was reviewed by the inspector because of NRC concerns
- 1
regarding improper classification of the emergency
,
lighting system.
Emergency lighting was previously .
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classified as non-quality related (NQR) and had not been
_
governed by Procedure No. 81AC-0CC06, Classification of
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Structures, Systems and Components.
Procedure No. 81AC-
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OCC06, Revision 2.20, dated December 23, 1992
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redesignated the quality classification. of: emergency
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lighting equipmant as Quality Augmented (QAG). QAG is
defined in the licensee's Operations Quality Assurance
. i
Plan, Amendment 1, as " items that do not perform a safety
related function but which,' as a-result of regulatory
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commitment or management directive, require the
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application of certain quality assurance program
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el ements . " Classifying emergency lighting as QAG ensures
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that the critical aspects of emergency. lighting design,
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procurement, maintenance, and testing are applied to
_
ensure that fire protection equipment is available and
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functional . Additionally the. licensee upgraded fire
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barriers, lube oil collection, and fire detection and
1
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alarms from non quality related (NQR) to QAG. The
inspector found that reclassification of these
components, from NQR to QAG, meant that the items were
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included in the licensee's " Operations QA Plan," Appendix
F-1.
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conclusion
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The inspector concluded that the licensee.has-adequately
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revised their QA program to include all provisions of the fire
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protection program described in the FSAR.
Inclusion of. the
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fire protection program.into the QA program ensures that fire
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protection programs and equipment will be subject to audits,
.i
inspections, and controls as required by the QA program.
The
. i
inspector also concluded that the Fire Protection JC0 ~
evaluation resulted in appropriate actions being taken to
assure that the QA program for fire protection was consistent
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with NRC Branch Technical Position 9.5-1, Appendix A.
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Licensee implementation of the QA program, as it applies to
installed fire protection equipment, was not inspected during
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this inspection. Therefore, this item will remain open.
No
,
new violations or deviations of HRC requirements were
identified.
b.
(Closed) Violation 50-528/90-25-01. Failurc'to Provide
I
Reliable Emeraency Lichtina:
Viol ation -
An apparent violation for failure to provide reliable
emergency lighting was documented in NRC Inspection Report 50-
.
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528/529/530/90-25, dated July 5, 1990. On October 16, 1993 a
Notice of Violation and Proposed Civil Penalty was issued, in
part,-for failure to provide reliable emergency lighting
required for access to, egress from, and operation of safe
shutdown equipment.
Licensee Actions
In response to the violation, the licensee took corrective
actions to improve emergency lighting reliability and
availability. These actions included revisions to the
preventative maintenance program procedures governing the
waiving of emergency lighting preventative maintenance tasks,
modifications to add additional emergency lighting, increase
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preventative maintenance frequencies of selected lighting
units, and upgrade the corrective maintenance priority of
To ensure that waiver of preventative maintenance tasks for
emergency lighting was controlled and reviewed by management
the licensee revised procedure 30DP-9MP09, Preventative
Maintenance Processes and Activities. The revision to
procedure 30DP-9MP09 required that Plant Manager approval was
required for a waiver of emergency lighting preventative
maintenance tasks. The licensee designated emergency lighting
work as priority level 2.
Priority level 2 work required that
corrective action should be started within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of
identification. The licensee revised the 10 CFR 50, Appendix
R emergency lighting QA classification from NQR to QAG.
The licensee modified and installed additional emergency
lighting fixtures under various design and modification
packages.
The licensee performed engineering evaluation request (EER)
91-Q0-083, Appendix R Dual-Lite Emergency Lighting Fixtures to
,
evaluate acceptable emergency lighting preventative
maintenance (PM) frequencies. The evaluation included
emergency light batteries in the main steam support structure
(MSSS), diesel generator building, and turbine building.
These areas were high temperature areas where emergency light
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battery failures and resultant emergency lighting failures had
'
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occurred. The results of the evaluati.on resulted in: a higher
'
frequency of preventative maintenance (quarterly PM),
replacement of batteries with batteries suitable for the
environmental conditions, or the replacement of the individual
lighting system with a centralized uninterruptable power
source (UPS) and fluorescent fixtures.
Previous NRC Inspections
Emergency and essential lighting system modifications and new
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installations were previously reviewed by NRC inspectors. The
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results of the inspection were documented in NRC Inspection
'
Report 50-528/529/530/91-30, dated October 16, 1991. Results
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4
of emergency lighting performance were not available at the
time of that inspection.
j
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Inspector Review of licensee Actions
[
To determine the current availability of 10 CFR 50, Appendix R
emergency lighting the inspector reviewed administrative
3
procedures, test records and procedures, material non-
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conformance reports (MNCRs), and availability calculation
i
methods and studies, for emergency lighting.
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Administrative Procedures
The inspector reviewed licensee procedure 30DP-9MP09,
Preventative Maintenance Processes and Activities, Revision
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00.02, section 3.4.3, and confirmed that the procedure
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required Plant Manager approval for waivers of emergency
,
lighting PM. The inspector reviewed procedure 30DP-9WP01,
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Revision 03.00, Work Initiation, and verified that emergency
t
lighting is categorized as priority level 2 for corrective
maintenance requests. The inspector reviewed licensee
procedure 81AC-0CC06, Revision 2.01, Classification of
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Structures, Systems, and Components, and verified that the
procedure classifies 10 CFR 50, Appendix R emergency lights as
QAG. QAG is defined in licensee procedure 60AC-0QQ09, revision
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1, Classification of Activities, as " items that do not perform
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a safety function but which, as a result of regulatory
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commitment or management directive, require the application of
!
certain quality assurance program elements."
The inspector randomly sampled 3510 CFR 50, Appendix.R
!
emergency lights in the station information management system
(SIMS) and found that the emergency lights were classified as
QAG.
'
The inspector reviewed licensee-internal document " Emergency
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Lighting System Annual Report," Dated February 19, 1993. As
documented in the following " test records and procedures"
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section of this inspection report, the availability of 10 CFR
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50, Appendix R emergency lighting increased from previous
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records of below 60% to above 90%.
Licensee methods for
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calculating emergency lighting availability.are described in
the " Emergency Lighting Availability Calculations" section of
this item.
The inspector concluded that the licensee had revised plant
4
procedures to include plant manager approval for waiver of
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emergency lighting PMs, emergency lighting had been revised to
"
priority level 2 for corrective. actions, reclassified 10 CFR
i
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.
.
15
50, Appendix R emergency lighting as QAG, and that emergency
lighting availability had increased from 60% to above 90%.
Test Records and Procedures
The inspector reviewed licensee emergency lighting discharge
test records and procedures for Dual-Lites, Holophane, and
Exide lights. The procedures reviewed were: Dual-Lites, 32MT-
9QD01, Revision 1.01, Emergency Lighting Fixture Battery
Discharge Test, Wall Mounted Types KE, KF, KG, and KI;
Holophane, 32FT-90D03, Revision 0.01, Holophane, Emergency
Lighting, 8 Hour Operational Test QDN-NO3; and Exide, 32FT-
9QD02, Revision 01.01, Exide Emergency Lighting System, 8 Hour
Verification Testing For 1, 2, 3EQDNN02.
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The inspector reviewed licensee 1992 10 CFR 50, Appendix R
emergency lighting records and status reports. The inspector
found the availability figures for emergency lighting to be as
follows. Holophane emergency lighting systems had an
availability factor of 92.3%.
Exide emergency lighting
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systems had an availability of 96.6%.
Dual-Lite emergency
lighting systems had an availability of 96.5%.
(The licensee
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method for calculating availability is described below.)
There were approximately 440 dual-lite units for Units 1, 2,
and 3.
Units 1, 2, and 3 had six (two per unit) Exide battery
units, and 18 (six per unit) Holophane battery units. The
inspector reviewed records for 1992 licensee tests of eight
Dual-Lite, two Holophane, and one Exide emergency lights.
The
inspector reviewed test records and procedures to verify that
the licensee had taken corrective actions for any abnormal
readings or test failures, and that the licensee was not pre-
conditioning the batteries prior to the discharge test.
The inspector found that for the items sampled, the licensee
had written MNCRs for all cases of emergency lighting
problems, and corrective actions were being taken within 24
hours of problem identification. The inspector also found
that the licensee had revised emergency lighting PM
frequencies based on trending data and engineering analysis.
Emergency lights in higher temperature areas were receiving
1
quarterly preventative maintenance (PM).
l
The inspector concluded that the licensee had performed
'
testing on all 10 CFR 50, Appendix R, emergency lighting, had
documented and performed corrective actions for identified
problems within the established time periods, was not pre-
conditioning lighting units prior to discharge testing, and
had revised FM tasks based on trending data and engineering
analysis.
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16
Material Non-Conformance Reports
The inspector reviewed eight MNCRs for emergency lighting to
verify that corrective actions were taken and failure data was
being recorded and trended.
The inspector found, from a review of documents, that the site
Nuclear Engineering Department (NED) was reviewing MNCRs for
adequate corrective action. The licensee's Performance
Engineer _ing group and the NED System Engineers were jointly
trending emergency lighting in accordance with licensee
~
procedure 73DP-0ZZ03, Revision 00.00, System Performance
Monitoring Guidelines. The inspector verified that the eight
work orders written for the MNCRs were completed and that the
.
MNCR corrective actions were included in the work orders.
The inspector concluded that the licensee had documented,
performed engineering reviews, performed corrective actions,
and were trending data for 10 CFR 50, Appendix R emergency
lighting.
Emeraency Lichtina Availability Calculations
The inspector reviewed licensee calculation 13-NC-QB-200,
Revision 2, Calculation for Holophane Emergency Lighting Unit
Availability Study. The inspector reviewed the calculation
for methods of determining emergency lighting availability.
The licensee unavailability indicating factor of each
component or group of components was calculated for a specific
time period.
For this time period the indicating factor was
calculated by dividing the total number of unavailable days by
the total number of days in the time period.
The licensee
used three dates for the calculation; the failure discovery
date, the component repair date, and the last date the
component was known to have been available. The licensee used
two factors in determining unavailable time.
The time between
the failure discovery date and the component repair date was
the known unavailable time period. The unknown unavailable
time was an estimate and was calculated as one half the time
between the last time the component was known to be available
and the failure discovery date.
The estimated unavailable
times were added to the known unavailable time period.
The inspector verified that the licensee calculated
availability for Exide and Dual-Lite 10 CFR 50. Appendix R
emergency lighting using the same method as the Holophane
emergency lighting systems availability calculations.
Exide
lighting fixtures were calculated in licensee availability
study 13-NC-Q-201. A final Dual-Lite availability calculation
was not available for review at the time of the inspection.
Calculation for Dual-Lite availability were being performed by
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17
the NED System Engineer. The inspector reviewed the system
engineers data for the dual-lite availability.
,
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The inspector concluded that the licensee had calculated
emergency lighting availability, and that the method for
calculating availability was the same for all 10 CFR 50,
Appendix R, emergency lighting. The inspector also concluded
that licensee calculations accurately supported emergency
lighting availability figures provided in licensee emergency
,
lighting'. system annual reports.
>
Conclusion
The inspector concluded that the licensee had taken corrective
actions to improve the reliability of 10 CFR 50, Appendix R
emergency lighting and that the licensee's corrective actions
had increased the availability of emergency lighting to above
their 90% availability goal.
This item is closed. No new violations or deviations of NRC
requirements were identified.
c.
(Closed) Violation 50-528/92-14-03. Different Than Specified
M&TE Used for Calibration of Instrumentation
Violation
NRC inspectors identified that maintenance personnel
performing calibration tests on a low pressurizer pressure
transmitter had used maintenance and test equipment with a
lower range (0-3000 psi range used rather than a 0-4000 psi
gauge). than specified in licensee surveillance and test
t
procedures.
Licensee Response
In response to the Notice of Violation the licensee committed
to review instrumentation and control (I&C) surveillance
procedures to verify that required M&TE was properly
identified in the "Special Test Equipment" section.
If the
review found that there was not a technical justification to
specify M&TE in the " instruction" section, the surveillance
procedures would be revised to allow the performer to select
,
the appropriate M&TE based on the guidance provided in the
"Special Test Equipment" section of the procedure.
The licensee also committed to incorporate the lessons learned
from the Notice of Violation into the licensee's training
change system and to the appropriate training.
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Inspector Review of licensee Actions
The inspector sampled 15 surveillance test procedures and
verified that conflicting M&TE guidance had been removed. The
,
inspector also selected and reviewed two procedures where M&TE
guidance was referenced to the "Special Test Equipment"
!
section of the procedure.
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The inspector reviewed lesson plans and training records to
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verify th~at the licensee had incorporated '.'s lessons learned
(
from the Notice of Violation into the appropriate training
programs. The inspector reviewed: industry events mechanical
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staff lesson plan NMC-13-13-XC-001-000, industry events for
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technical staff NGT22-13-RC-001-000,- and industry events for
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I&C technicians NIC50-17-RC-001-000, and their associated
,
training records. The inspector found that the training had
!
been completed by October 1992 for all three groups.
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Conclusion
ne inspector concluded that the licensee had reviewed and
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ievised I&C surveillance procedures to remove conflicting
.
guidance for M&TE, and that references to specific test
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equipment was included in the " instruction" section of the
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surveillance procedures.
l
The inspector concluded that the licensee had revised
[
appropriate training programs to include lessons learned from
the Notice of Violation. The licensee had also provided the
i
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training to appropriate personnel.
This item is closed. No new violations or deviations of NRC
!
requirements were identified.
d.
(Closed) Violation 50-528/93-09-01. Inadeauate Corrective
Actions
Violation
During an NRC inspection of the licensee's closure of licensee
'
event report (LER) 50-529-90-09-L1, " Report on Fire Barrier
Inspection," the NRC inspector identified two cases where the
licensee had closed MNCR's where the corrective actions were
not completed as stated in the LER and associated work order.
The inspector had randomly sampled 27 of 579 MNCRs written for
the three Palo Verde Units. The inspector had identified that
threaded metal plugs had not been installed on both ends of
two conduit penetrations as required by the MNCR's and design
drawings, and that the two work orders and MNCRs had been
signed off as being completed.
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Licensee Response
In response to the violation the licensee issued condition
report / disposition request (CR/DR) 930164 (Incident
Investigation), and MNCRs 93-FP-2027 (Unit 2) and 93-FP-1030
(Unit 1) to initiate corrective actions to address the non-
conforming condition identifhd in the violation.
Additionally the licensee performed a 100% (total of 31)
visual inspection of conduits sealed with threaded plugs
performed by Unit maintenance groups, and a 20% sample (50 of
250) conduits sealed with threaded plugs performed by the fire
protection support services. The licensee did not identify
any conduits where the conduit penetration repair had not been
completed as required by the MNCR or work order.
To prevent further violations the licensee committed to revise
procedure 14FT-9FP67, Thermo-Lag Fire Barrier Surveillance, to
!
provide guidance in completing MNCRs and work orders to ensure
j
that work on spare conduit penetrations meet fire protection
l
requirements. The licensee also committed to brief Quality
Control inspectors, Unit planners, central maintenance
electrical planners, and civil work planners regarding the
violation.
Inspector Review of Licensee Actions
The inspector reviewed MNCRs 93-FP-2027 (Unit 2) and 93-FP-
1030 (Unit 1) and work order 573342 (for Unit 2). The
inspector found that the MNCR instructions to repair the
conduit penetrations appeared to adequately describe the
actions to be taken to complete the task. The inspector
,
I
visually inspected the Unit 2 penetration seal performed under
work order 573342. The Unit 2 penetration seal was modified
to have a foam filled conduit without a metal cap. The
l
inspector verified that the foam filled seal met the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />
fire barrier requirements. The inspector noted that
corrective actions for Unit I would be completed by June 25,
1993.
I
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The inspector also visually inspected 10 completed conduit
penetrations identified in the licensees sample, four for Unit
I
1, 3 for Unit 2, and 3 for Unit 3. The inspector did not
identify any conduit penetrations that were not completed in
accordance with the associated MNCR corrective actions.
The inspector reviewed attendance sheets of the incident brief
l
for the quality control inspectors, Unit planners, central
maintenance electrical planners, and civil work planners of
the incident. The inspector found that all of the groups had
been briefed on the incident.
The inspector had reviewed a licensee proposed inspection
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guideline sheet for conduit penetrations for procedure 14FT-
9FP67. The proposed guideline would be incorporated in the
procedure by November 30, 1993, which would be prior to the
next scheduled performance of the procedure.
Conclusion
l
The inspector concluded that the licensee had completed
actions to correct the conduit penetration deficiency noted in
i
Unit 2 and that corrective actions would be completed for Unit
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1 by June 25, 1993, and that corrective actions to prevent
,
)
recurrence appeared to be adequate.
This item is closed.
No new violations or deviations of NRC
requirements were identified.
4.
Previously Identified Inspection Follow-up Items (92701)
a.
(Closed) Unresolved Item'50-528/529/530/92-43-05
Oriainal NRC Inspection Follow-up Item
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Licensee corrective action report (CAR) 90-0010 identified
!
that certain administrative controls had not been sufficient
t
to ensure that equipment design output information was being
incorporated into plant configuration documents (information
in the station information management system (SIMS) equipment
'
data base was not being translated into the preventative
maintenance program). This resulted in preventative
maintenance (PM) work orders (WO) potentially being issued and
work being performed at a lower quality classification than
that required by the component.
,
One of the completed corrective actions for CAR 90-0010 was
that the equipment data bases in SIMS had been updated to show
!
proper quality group classifications and that tasks would be
routinely updated to include correct quality classifications.
As part of an NRC inspection licensee corrective actions for
CAR 90-0010 were reviewed. The results of the inspection were
documented in NRC Inspection Report 50-528/529/530/92-43.
!
During that inspection the inspector reviewed a listing of
equipment in the SIMS program which did not have a quality
classification listing. The listing indicated that
'
approximately 3300 task items in SIMS did not have quality
classification listings. The inspector also found that
i
approximately 10% of the 3300 task items which did not have
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quality classifications were listed as being quality related
work items. Quality classification and quality related work
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items appear as two independent fields on the SIMS.
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Licensee Actions
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In response to the NRC inspector's findings, the licensee
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issued Condition Report / Disposition Request.(CR/DR) 9-2-0745
!
and stated that an evaluation would be performed to determine
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if any preventative maintenance or work tasks were performed
j
at a lower quality level than the equipment classification.
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The licensee's review of Pms and work tasks did not identify
any Pms or work tasks which were performed for any quality
related items identified without quality classifications.
The-
{
licensee also found that the approximately 3300 items
i
identified during the NRC inspection were unapproved tasks
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which were in the SIMS data base for information only. The
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licensee also noted PM and/or work orders of any type could
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not be generated from the SIMS without a quality
!
classification.
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The licensee also stated that unapproved tasks were not part
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of the scope and closure of CAR 90-0010.
!
Inspector Review of licensee Actions
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The inspector sampled 20 of the items on the original 3300
,
item list to verify that the tasks were unapproved. The
!
inspector verified that the tasks were unapproved in the SIMS
!
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data base.
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The inspector sampled five of- the unapproved tasks on the SIMS
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data base using licensee procedures for generating Pms and/or
!
work tasks. The inspector confirmed that licensee SIMS
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program software prevented a PM and/or work task order from
being generated if the quality classification field of the.
SIMS was blank.
i
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The inspector requested a SIMS listing of approved tasks in
.
the SIMS data base which did not have the quality
classification field completed. The SIMS sort did not
identify any approved equipment which did not have the quality
classification field completed.
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Conclusion
The inspector concluded that the licensee had not performed
any maintenance tasks on quality related or quality ' augmented
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group equipment which did not have the quality classification
field completed from the time of the closure of CAR 90-0010
and the time of this inspection. The inspector also concluded
that a PM and/or work order could not have been generated from
the SIMS data base without the quality classification field
being filled in, and that the original 3300 items identified
were unapproved tasks.
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Since the SIMS items list generated during the inspection
i
documented in NRC Inspection Report 50-528/529/530/92-43 were
unapproved tasks, were not part of the CAR 90-0010, and work
i
orders were not generated for these items, there were no
violations of requirements.
This item is closed. No violations or deviations of NRC
requirements were identified.
b.
(Closed): Inspector Follow-up Item 50-528/91-25-08. Review of
I
Licensee's Control of Vendor Services and Software
!
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Oriainal NRC Inspector Follow-up Item
t
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An NRC inspection identified that although the licensee
verified that Motor Operated Valve and Test System (M0 VATS)
,
Incorporated personnel had been verified to comply with MOVATS
standards, the licensee had not verified the MOVATS.
i
certification to be in compliance with licensee requirements.
l
Furthermore, M0 VATS Incorporated had issued updated software
!
for their valve test equipment, which the licensee was using
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without verifying compliance of the software to the Palo Verde
i
Nuclear Generating Station (PVNGS) standards. Prior to using
j
any new software, the licensee has a procedure that requires
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the new. software to be checked to verify acceptable
!
performance.
!
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ticensee Actions
i
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The licensee verified software programs issued by M0 VATS in
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accordance with licensee procedures. However, the licensee
i
did not complete verifications that M0 VATS personnel
certifications were in compliance with PVNGS requirements
j
since the licensee no longer contracts with MOVATS to perform
!
valve testing. The licensee had established their own valve
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group to perform the M0 VATS program.
Previous NRC Inspection Follow-un
NRC Report 50-528/529/530/93-02 reviewed Inspector Follow-up
item 91-25-08. The inspector ccncluded that the licensee had,
verified that M0 VATS software was in compliance with licensee
standards.
However, the verification that MOVATS personnel
certifications were in compliance with licensee standards had
not been completed.
Insoector Review of Licensee Actions
MOVATS Contractor Usace
The inspector was informed by the licensee valve group that
the licensee no longer employs M0 VATS as a contractor to
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perform motor operated valve testing. The licensee now has
its own valve testing group which performs the MOVATS program.
MOVATS Software Verification
<
The inspector reviewed one licensee M0 VATS software
verification and confirmed that the licensee had continued to
perform verification of MOVATS software in accordance with
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licensee procedures 87AC-0CC08, Control of Vendor
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Documentation, 81DP-0CC05, Design and Technical Document
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Control, .and 80AC-00Q01, Control of Computer Programs,
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Software Documentation and Error Notices.
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Licensee Valve Testina Group
The inspector verified that the licensee's valve testing group
was established by procedure 39AC-9ZZ01, revision 00.00, Valve
Services Engineering, and the responsibilities and
requirements for the motor operated valve program are
established in procedure 39PR-9ZZ01, Revision 00.00, Motor
Operated Valve Monitoring and Testing Program.
Motor Operated Valve Contractor Personnel
since the licensee had cancelled the contract with MOVATS to
perform motor operated valve testing the inspector verified
that the licensee retained a program to determine if
contractor personnel were certified / qualified to PVNGS
standards for motor operated valve testing. The inspector
reviewed licensee procedures which addressed verifications of
certifications.
The procedures reviewed by the inspector
were; 13AC-0PR02, Revision 01.01, PVNGS Contract Personnel
Request and Exiting Procedure; 15AC-0TR01, Revision 04.01,
Personnel Qualification and Certification; and 020G-0ZZ08,
Revision 03.01, Site Maintenance and Modifications
Organization and Responsibility Policy. The inspector's
review of these procedures verified that the licensee had
procedural guidance in place to ensure that contract personnel
contracted to test motor operated valves would be required to
meet PVNGS standards of qualification for that task.
Conclusion
The inspector concluded that the licensee had procedural
guidance to ensure that contract personnel performing motor
operated valve testing at PVNGS would have to meet PVNGS
certification requirements. However, since the licensee no
longer contracts with M0 VATS Incorporated to perform motor
operated valve testing, checking M0 VATS personnel
certifications to assure they meet PVNGS certification
requirements was no longer appropriate or necessary.
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,
.
.
24
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This item is closed. No violations or deviations of NRC
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requirements were identified.
5.
Erosion / Corrosion and Pipina Overlay Weld Repairs (49001)
a. Pipino Overlay Weld Repairs
.
The licensee performed weld overlay repairs when projected wear
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rates (WR) may erode or corrode a section of piping or fitting to
below or near minimum allowable wall thicknesses prior to the next
refueling cycle outage. The need for weld overlays were determined
by engineering evaluations.
The evaluations were performed using
ultrasonic test readings of piping or fittings which were
identified by the erosion corrosion program and the calculated wear
rates of the piping. At the time of the inspection there were a
total of 23 weld overly repairs for all three units.
Inspectors Review
,
The inspectors reviewed licensee procedures, calculations,
engineering evaluation requests, and work orders for piping weld
overlay repairs. The inspector also visually inspected completed
weld overlay repairs.
The inspector reviewed three weld overly repair packages performed
during the recent Unit 2 refueling outage (U2RS). The repair
packages were for a reducer downstream of a level control valve for
feedwater heater 3A and 3C, level control valves LV-301 and LV-303
,
respectively, and for an elbow on the high pressure turbine
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extraction line 2PMTNLO32.
The three work order packages reviewed
were 00609556 (feedwater heater 3A), 00609907 (feedwater heater
3C), and 00602389 (HP turbine extraction steam).
The inspector found that licensee engineering evaluations and
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calculations for the repairs were completed in accordance with
licensee procedures 81AC-0RA02, Revision 01.01, Erosion-Corrosion
Administrative Control, for engineering evaluations, and 81DP-
ORA 02, revision 02.01, Erosion Corrosion Department Procedure, for
minimum wall thickness calculations.
The inspectors review of the above work orders, post weld overlay
repair ultrasonic test measurements, and visual observation of weld
overlay repairs for feedwater heaters 3A and 3C, found that weld
overlay repairs were completed in accordance with their associated
engineering evaluations and calculations.
Conclusion
The inspector concluded that the licensee was evaluating and
performing weld overlay repairs in accordance with licensee erosion
corrosion and welding procedures.
_ - -
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25
b. Erosion Corrosion Thickness inspections
Backaround'
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An inspection was conducted by NRC mobile nondestructive
examination laboratory personnel at Palo Verde Nuclear Generating
Station Unit 2 during the period of April 19 through 30, 1993. The
results of the inspection were documented in NRC Inspection Report
number 50-529/93-13, transmitted to the licensee June 11, 1993.
NRC Inspection Report number 50-529/93-13 identified that thickness
measurements taken by NRC inspectors on component F009-26-01 (26
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inch diameter feedwater pipe), were different than those recorded
,
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by the licensee in licensee ultrasonic thickness examination
inspection report number 93-89. A licensee reinspection of the
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component identified that there was a laminar type indication in
the pipe.
Inspector Follow-up Actions
The NRC inspector reviewed licensee erosion corrosion program
procedures for NDE inspector guidance for identifying and recording
piping defects or anomalies while performing erosion corrosion
thickness measurements. The NRC inspector reviewed NDE thickness
inspection records for eight additional components or piping (five
of which were performed by the same licensee NDE inspector who
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performed the inspection where the NRC NDE laboratory personnel
found a different thickness reading in certain areas).
The NRC
inspector observed a follow-up NDE thickness inspection of a
component and compared the results with prior thickness inspection
data for the same component. The NRC inspector reviewed quality
assurance monitoring reports for erosion corrosion activities. The
NRC inspector interviewed the licensee contractor NDE inspector who
performea the inspection where the NRC NDE inspectors found
different readings and reviewed the licensee's NDE UT test
identifying the lamination in component F009-26-01.
Procedures
The inspector reviewed procedures 81AC-0RA02, Revision 01.01,
Erosion Corrosion Administrative Control, 81DP-0RA02, Revision
02.01, Erosion-Corrosion Department Procedure,
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revision 03.00, Erosion Corrosion Monitoring, and 73TI-0ZZ02,
revision 04.01, Ultrasonic Thickness Measurement.
The inspector found that licensee erosion corrosion monitoring
program and procedures did not provide the erosion corrosion NDE
thickness inspector guidance regarding documentation of a flaw or
an anomaly found in a carbon steel pipe during an erosion corrosion
thickness inspection for evaluation by engineering. The licensee
stated that at the time of this inspection an erosion corrosicr. NDE
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t
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,
26
thickness inspector could move the ultrasonic test transducer probe
f
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around inside a grid until an accurate reading could be acquired.
The NRC inspector stated that allowing the NDE inspector the option
of moving the transducer probe around in a grid until a good
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reading was obtained without recording any noted flaws or anomalies
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could potentially allow a piping flaw to go unrecorded or analyzed.
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Licensee NDE UT Inspection Reports
The NRC inspector reviewed a sample of eight additional erosion
corrosion non-destructive examination ultrasonic test (NDE, UT)
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thickness inspection records. The inspector found that the records
appeared to be accurately documented, engineering evaluations were
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completed for unacceptable conditions, and that corrective
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maintenance repairs were performed in accordance with licensee
procedures when required.
On June 30, 1993 the NRC inspector observed a licensee NDE UT
follow-up inspection of a 16 inch feed water pipe elbow, part
number E-218-16-06. The follow-up inspection sampled 75 of 450
total inspection points for this component. The inspector compared
the results of the follow-up NDE examination with licensee NDE UT
thickness inspection results obtained on March 24 and 25,1993 for
the same component. The March 24-25, 1993 inspection was performed
'
by the licensee inspector who performed the ultrasonic test
inspection documented in licensee UT inspection report no. 93-89.
The NRC inspector found that the follow-up inspection results
performed on June 30, 1993 were consistent with readings obtained
by the licensee NDE inspector during the March 24 - 25, 1993,
erosion corrosion HDE thickness inspection. The NRC inspector also
observed that visual signs of previous (March) couplant residue on
the piping reinspected was random, ie., appearance of couplant
residue could not always be visibly observed.
The NRC inspector observed that during the follow-up NDE UT
thickness inspection that the NDE UT inspector had applied liberal
amounts of couplant (Ultragel) to the areas of the pipe to be
inspected. The NRC inspector also observed that the NDE UT
thickness inspector wiped the couplant off of the pipe and fitting
(90 degree elbow) when the inspection had been completed as
required by the procedure 73TI-0ZZ02, Revision 04.01, Ultrasonic
Thickness Measurement. The NRC inspector observed that after
approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the follow-up inspection the couplant
had begun to dissipate or evaporate.
Quality Assurance
The NRC inspector reviewed QA monitoring reports 93-0305 and 93-
0376 performed by the component condition monitoring (CCM) group.
The reports documented quality assurance reviews of erosion
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a
.
28
significant movement of the probe or a random possibility that the
probe was placed on the 10% of the grid not occupied by the
lamination. Allowing the NDE UT inspector to move the transducer
probe around in a grid to obtain accurate readings is permitted by
the procedure, as discussed in " Procedures" above.
Conclusion
The NRC inspector concluded that the licensee was performing
erosion corrosion NDE UT thickness inspections in accordance with
licensee procedures. The inspector could not conclusively
,
i
determine why the lamination indication on component F009-26-01 had
not been detected during the inspection documented in licensee
ultrasonic thickness inspection. report number 93-89. The inspector
concluded that the failure to detect and document the laminar
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indication on component F009-26-01 was probably an isolated
,
performance error by tile NDE inspector. The NRC inspector also
'
concluded that licensee erosion corrosion procedures did not
provide guidelines to licensee NDE thickness inspectors for
determining when a piping flaw or anomaly should be recorded for
engineering evaluation. The licensee stated that an evaluation
would be performed to determine what procedural guidance would be
,
!
'
provided to NDE thickness inspectors in determining when a piping
flaw or an anomaly should be recorded for evaluation.
The results
of the evaluation would be incorporated into erosion corrosion
,
inspection or program procedures and/or NDE UT training programs.
No violations or deviations of HRC requirements were identified.
6.
Exit Meetina
Exit meetings were held with persons noted in paragraph 1 of this
report on June l'1, and July 2,1993.
During these meetings the
scope of the inspection and the resultant findings were discussed.
Licensee management present at the meetings indicated that they
understood the concerns presented and that there was no further
j
questions at that time,
i
At the conclusion of the meeting the inspector requested that the
!
licensee identify any documents given to the inspectors that might
i
be proprietary so that they could be returned.
The licensee
indicated that there were no documents that were proprietary.
1
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Docket File
Resident Inspector
Project Inspector
G. Cook
7. Huey
B. Faulkenberry
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J. Zo111 coffer
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M. Smith
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