IR 05000528/1984014

IE Insp Repts 50-528/84-14 & 50-529/84-11 on 840402-30.No Noncompliance Noted.Major Areas Inspected:Startup Testing & Noncompliance Followup

ML20151J370
Person / Time
Site:	Palo Verde
Issue date:	05/11/1984
From:	Bosted C, Fiorelli G, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20151J367	List: IR 05000528/1984014 ML20151J361
References
50-528-84-14, 50-529-84-11, NUDOCS 8406270066
Download: ML20151J370 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION V

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Report Nos. 50-528/84-14, 50-529/84-11

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Docket Nos. 50-528, 50-529

 - License Nos. CPPR-141, 142 Licensee: Arizona Public Service Company
  'P. O. Box 21666
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Phoenix, Arizona 85036 I Facility Name: Palo Verde Nuclear Generating Station Units 1, 2

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Inspection at: Palo Verde Site, Wintersburg, Arizona

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Inspection Conducted: April 2 - April 30, 1984 Inspectors: M - ~M' G. Fiorelli, G () [/ Date Signed SAuY% [/h./br CY Bosted, ( / SW-W Date Signed Approved by: / a . bO' M Yo'u'ng, Jr. , [pief g/ Date Signed Reactor ProjectW Section 2 Summary: a Inspection on April 2 - April 30, 1984 (Report Nos. 50-528/84-14 and 50-529/ 84-11)

Areas Inspected

Routine, resident inspection of startup testing and

' noncompliance followup. The inspection involved 96 hours on site by the resident inspector Results: No items of noncompliance or deviations were identifie s h0

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? DETAILS

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1 Persons Contacted Arizona Public Service Company (APS)

  * E. Van Brunt, Jr. , Vice President Nuclear ANPP

* R. Bynum, Nuclear Operations Manager ,

  *W. Ide, Corporate QA Manager

*J. Kirby, Startup Manager D. Hayes, Unit 1 Preoperational Startup Manager

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  *0. Zeringue, Operations Technical Support Manager

. C. Crane, Startup Engineer

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! J. Dennis, Shift Supervisor ! J. Barber, Startup Engineer

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W. Furra, Startup Engineer

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J. Middleton, Startup Engineer , ' '

  'J. Brantly, Startup Engineer

- D. Sanchez, Startup Engineer

{ Leigh, Startup Engineer

; Barrow, Electrical Engineering, Supervisor

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 , Kaplan, Quality Control Supervisor 4-  - Raines, Electrical Engineer
  * Craig, Startup Engineer L. Sousa, Startup Quality Assurance Manager R." Kimmel, Startup Engineer

  *C. Gross, Licensing Engineer R. Berneir, Operations Superintendent D. Callaghan, Operations Shift Supervisor j   P. Wiley, Operations Shift. Supervisor

" Bechtel Corporation J. Houchen, Transition Manager " R. Moody, Training Coordinator

  * Attendees at'the exit meetin ~

l i I- Followup of Previously Identified Items

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? Noncompliance - Unit 1 Steam Generator Overfill'(83-44-01, Closed)

! The inspector' concluded based on wfitten communications,'and >

  ' discussions with several staff members, that the corrective actions   +

stated in the APS response of January 13,1984 to the- NRC were implemented.

, Noncompliance - Unit 1 Containment-Pressure Sensing Lines' Capped   I
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  (83-34-22, Closed)
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l Based on a review of-the-following licensee activities-the inspector' concluded that the actions ;taken or 'in progress are consistent with ~ -l

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those discussed in the APS response of January 31, 1984 to the NR These actions included: 1) The lines were observed to be capped. The caps are tagged and controlled in accordance with an approved temporary modification procedur ) Station manual operating procedure 41 ST-1ZZ13 is in a revision status and addresses removal / verification of sensing line caps prior to entry into mode 5. The response states prior to mode 4. This matter is under review by the licensee. The procedure still requires final approva ) Surveillance Procedure 36 ST-9SB03 has been drafted to include an inspection and blowdown of the lines on a refueling outage frequenc c. Noncompliance - Unit 1 High Pressure Safety Injection Valve SI 470 Did Not Have The Manual Operator Installed. High Pressure Safety Injection Valve 402 Was Positioned So That The Valve Could Only Be Opened 30-35% of Its Full Open Position. (83-34-05, 83-34-07, Closed) Based on a review of the following licensee activities the inspector concluded that the actions taken or in progress are consistent with those discussed in the APS response of January 31, 1984 to the NR These actions include: 1) Startup field report SFR 292 and startup work documents permits 15578 and 22507 were issued to correct the problems. The work has been completed, however testing is not completed as these , two valves are boundary valves and are tagged closed. Testing will be performed at a later dat ) Based on discussions with APS staff, the inspector confirmed , the vendor of the valve operators Roto Hammer has been > contacted of the conditio ) Construction installation procedure (Special CIP 521.0) requires documentation that the bridle installed is the size ' specified for the particular valv ) A walkdown of safety related valves in Unit 1 and 2 utilizing Roto Hammer operators is planne Some inspections have been performed but are not supported by confirming record ) APS operation has issued instruction to operators authorizing their issuance of startup work authorization when they identify equipment problems regardless of. jurisdiction of the equipment.

l 6) System acceptance by operations of systems transferred to i operations from startup will require system walkdown. This-activity is described in procedures 90 CA-0ZZO4 "Startup System Turnover" and 70 AC-0ZZ04 " Subsystem Acceptance by PVNG Nuclear Operations".

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, . 3 7) APS project management has issued a directive to PVNG startup and nuclear operations staff stressing their responsibility to identify problems and not to perform work without proper authorization and control ) A generic surveillance test procedure 91 GT-0ZZ24 has been developed and is under review. This procedure will be used to verify valves are operable and position indication is representative of the valve positio . Programmatic Actions In addition to the specific corrective actions identified in paragraph 2 above, the following programmatic actions have either been taken or are-in the process of being finalized by the licensee: Determination of Work Testing Priorities

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The licensee stated priorities would be established for the workcand' testing which needs to be completed so that resumption of activities would be done sequentially and in a controlled manner. The inspector observed the priority listing of subsystems which would be walked down and whose status would be confirmed in order to perform testing on a logical basis. Detailed schedules of component and preoperational testing have also been developed to the pump demonstration run. Currently the safety injection system is receiving priority attention since its testing'is a prerequisite to

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other system testin b.

System Configuration Confirmation The licensee stated that safety related subsystems ^will be walked

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down to confirm the configuration of each system. The inspecto observed evidence of this action. Also observed were- the reviews performed by QC and startup supervision prior to authorizing the resumption of prerequisite testing. Those findings were documented in inspection report 50-84/0 Procedure Revisions The licensee stated that procedures necessary to perform work or testing would be evaluated and~ revised to more effectively control

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e the activities. .These procedures include: Startup IC work control No. 90 GA-00ZZ25 Startup Electrical. work control No. 90 CA-0ZZ27 Startup Mechanical work control No. 90 GA-0ZZ26 Startup Temporary Modification No.,90 GA-0ZZll Startup Test Conduct No. 90 GA-0ZZ02 Startup Work Authorization No. 90 GA-0ZZO8 Startup Master Tracking No. 50 GA-0ZZ14

    . Startup Field Report No. 90 GA-0ZZl9
 . Work Control No. 30 AC-9ZZ01 The inspector noted that these procedures had been recently . revise '
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Training

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A comprehensive training program was initiated prior to the resumption of startup testing. The program included training on administrative controls dealing with testing activities, housekeeping, equipment tagging and controls. A matrix of courses and staff attendance had been developed. The training program required that an examination be taken on six of the key administrative control courses. The inspector saw in the licensee's files evidence of attendance and examination grade In addition to course instruction, a tape made by the chairman of the board of APS was to be presented to each PVNGS employee. This tape stressed the importance of quality, adherence to procedure and attention to detai d. Review of Work Authorization Documentation The licensee stated that a review was being conducted of work authorization documents for the purpose of confirming that no new testing requirements existed because of work which may had been done on a system. These work documents include startup work authorizations, master tracking lists, nonconformance reports and startup field reports. Based on discussions with testing personnel and observations of the files of reviewed work documents, the inspector determined that this effort was in progres Priority has been given to the safety injection system since its testing is a critical path ite e. Review of Discipline Test (DTS) Schedule The licensee stated that the discipline test schedule is being reviewed to ensure each component requiring testing is liste Based on discussions with reviewers and observations of the compilation of project drawings and review status information, the inspector confirmed this effort is being carried ou Changes which require test schedule updating are formally submitted to the DTS coordinators for inclusion in the schedule. Controls have been established which preclude the removal of tests from the schedul The review of the DTS for instrument / control, electrical and mechanical testing is essentially complete for Unit f. Review of Preoperational Test Data The licensee stated that safety related preoperational test data is being reviewed to ensure that the tests were completed and correctly

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documented. Based on discussions with testing staff the inspector' confirmed that this effort was in progress. Reviews of completed

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preoperational tests will be conducted as will future completed 3 . F tests. This effort has always been a part of the fo,rmal test review - l \

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,   5 process, however additional staff and technical support has been added to the process. The inspector observed files of completed reviews of several chemical and volume control subsystem tests as well as the auxiliary feedwater test. These reviews included acceptability of test data as well as technical adequacy of the procedure. The reviews are used by the test working group in their final evaluation of acceptable system performanc h. Records The licensee stated in his response that the flow path for quality-related records is being more closely defined to ensure the location and responsibility for control of these records is clearly define The inspector observed efforts to support this action. A Plant Policy No. 20 entitled "PVNGS Generated Documents / Record" was issued February 1, 1984. The purpose of the policy is to provide guide lines for generation, maintenance and storage of documents / records created in accordance with approved procedures. These procedures include 78 AC-0ZZ06 " Document and Record Control Turnover", 78 PR-0ZZ01 "PVNGS Document Control" and 90 PR-0ZZO3 "Startup Document Control". These procedures had already existed but were revised in some cases to improve their effectivenes In' addition the inspector saw the draft of the records program description document which provides indepth information on capability service and philosophies'of document control at PVNGS. This document also'

identifies specific and classes of documents showing defined flow paths. A document users index is also under development. This document describes the various documents, the type of information contained and where the document may be obtaine h. Configuration Control The licensee stated that a configuration control section within Nuclear Engineering, headed by a dedicated supervisor has been established. The inspector confirmed that the individual has been selected and that he has been directing such activities for a period of time. The controlling document has been written to govern this activity. Supporting procedures have either been completed or are in development. This control process will apply to all " owner" design change The operating organization has reevaluated its commitment related to requiring its concurrence prior to undertaking any testing or wor Since it does not have jurisdictional control over many systems, the stated authority was not practical or consistent with the status of equipment or ongoing testing activities. APS is modifying its policy in this' matter and will submit the changes to the NR !

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In discussing the corrective actions taken with several organizational units having responsibility for follovup, the inspector determined that communication with various groups of the commitments made to the NRC had not been timely. Consequently some completion schedules had to be revised and communicated to the NRC. This may be the result of ambiguity in the identification of the organizational unit having the overall responsibility for coordinating such activities. This matter was highlighted in the exit meeting with APS managemen . Plant Tours Several tours were conducted in units 1 and The housekeeping was noted to be good. No instances of equipment damage or abuse were note Several conditions which appeared to be in an abnormal configuration, were confirmed to be properly authorize Safety injection system chemistry was noted to have halogen concentrations within limits. Some emergency lighting units in unit I and 2 were found inoperable and a ' permanent fire extinguisher required relocatio Some items were also observed by representatives froia APS and Bechtel who were on one of the tours. Others were identified to the license No items of noncompliance or devitaions were identifie . Exit Meeting An exit meeting was held on April 27, 1984. The results of the inspection were discussed. Highlighted were the revisions to the completion schedules associated with commitments made to the NRC and the need to review coordinating responsibilities related with these activitie .

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