ML20217C148
| ML20217C148 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/27/1990 |
| From: | Coe D ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Huey R, Wong H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20213E767 | List: |
| References | |
| FOIA-90-570 NUDOCS 9107100044 | |
| Download: ML20217C148 (1) | |
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,,.07/27/1990 15103 US IFeC PALD UERIE 6U2 256 2739 P.01 c-i TRLECDP11N_ t31VtM Lkttag Pain Varde_ sit.q, AH H
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H AHE I.ji. WONG DEptt,.BEtti 11_. CHIEP. MKQJON V EXT t 3733 4
Pale Verde Nuclear Generating Ntation (PVN09)
Resident inspector's Of fice EXT t t602) 396-3650 or 356-3635 9UBJECTt -
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This message is being sent f rom a UP-400-PAtlAPAX sutomatti machine, if there area atty questions, pleaste cat t (602) 396-3650/$l:38.
Palo Verde tiesident thspuetor's automatic fascimliv humber is (602) 3N6-2738.
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07/27/19N 15103 U3 tFC PALO VERDE 602 386 2738 P.01 MLWM6lHW25Igggw umacmemanmg moremomrnomy EXECUTIVE StJADIARY At the request of Arizona Public Bervico Company, ABB Impell Corporation performed an independent roview of the Palo Verde Nuclear Generating Station (PVNGS) omergency lighting system. In this rolo ABB Impellt 1)
Determined the NRC requiroments applicab!: to the emergency lighting
- system, 2)
Determined on a samplo basis, whether APS work dono to dato meets the applicable requirements, 3)
Determined what selected other nuclear power plants are doing to meet requiroments applicable to their emergency lighting systems, an?
4)
Evaluated the emergency lighting concerns raised by the NRC in Inspection Report 90 02 and by the NRC or others subsequent to January 1,1990, and determined whether the APS discussion was responsive to those concerns.
ABB Impell reviewed the Code of Fodoral Regulations, NRC guidance documents, NRC Inspection Procedures, PVNGS Licensing documents and correspondenco, Regulatory Commitmor,t Tracking (RCTS and ROTR2) output, design basis documents, and industry codes and standards to ascertain the NRC requirements applicable to the emergency lighting system.
ABB Impoll performed a sample based review of the PVNGS cmcrgency lighting system to determine whether work dono to date fulfills the NRC requirements identified. The investigation by the ABB Impell review team was conduced in a manner similar to an NRC inspection. The depth of the review and the sampling methods (e.g. document review, physical verification or interview) were based upon the judgment and knowledge of the review team and were limited h. scope to the NRC fire protection related requirements for omorgency 1.g ting.
t Conclusions drawn by ABB Impell are based solely on the review of PVNGS documentation, limited walkdowns and information supplied in meetings.
A survey of other nuclear power plants was conducted to determine what the industry la currently doing to meet requirements applienble to omorgency lighting systems.
Finally, ABB Impoll reviewed the concerns identified by the Nuclear Regulatory Commission in Inspection Report 90 02 and the subsequent concerne identiflod by the NRC and APS personnel to ascertain the source requirement / commitment for the concern and to determine if the APS discussion was responsive to the
- concerns, i
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ABB tmpellNo. 01165818L5 Revision 0
07/27/1990 1E:04 U5 tFC P,4.0 UEGIE 601 286 1729 P.03 ABIZONAITmdCtmtWIqqggMpMY ___
t@nntopcytoirrma mozenmr unw ABB Impollidentified four issues as a result of the review of NRC requirements and APb implementation. These issues woro 1) Quality Assurance Requirements,2) Design Adequacy,3) leighting Placement, and 4) Maintenance.
Those finding', have also been identified by APS through their internal review process. APfl has indicated that the following actions are to be completed:
PVNG9 emergency lighting is now dualgnated QAG, consistent with the Quall',y Assurance Criteria Manual. Plant proceduros will be reviewed to en:ure the QA0 program is being fully implemented.
Replacement of Holophano batteries is in progress. APS will obtain confirmatory vendor data from bottory manufacturers which have not as yet provided necessary data.
The action plan identifled in CAR 90 014.
The preventivo maintenance program will be upgraded to ensure that lights are properly aimed.
The utility survey identified a wide range of technical positions on emergency lighting; however, the following points are ofinterest:
Two of seven utilities produced evidenco that temperatures other than 77' had been considered in battery sir.ing.
Five of the seven utilitles contacted considered emergency lights part of their augmented quality program for fire protection.
Three of the eight utilities contacted rogarding operability /repottability issues had some sort of compensatory measure for an out of service omorgency light.
ABB Impoll determined that the discussions developed by APS in response to the NRC and APS generated concerns, wore generally responsive.
Recommendations are provided for a number of the concerns.
In conclusion, AP8 has, over the years, identified the individual issues regarding omergency lighting at PVNGS. Corrective actions to address the identiflod issues focused on the immediate concerns with limited attontion to the underlying programmatic issues, Recent correctivo actions identlfled/ reviewed during ABB Impell's independent evaluation appear to address the broader programmatic issues. In ABB D ' poll's opinion, these issues represent the source of the individual deficiencice.
07/27/1990 15:05 US t4RC PALO VERIE 602 396 273G P.04 m-.-_.--.__-..
INDEPENDENTREVIEW t
Completion of the APS correctives actions and the implementation of the ABB Impell recommendations in this report will establish a program for continued compliance with the fire protection emergency lighting requirements.
t I
gii ABBImpellNo.0116661815 Revision 0
ew27n 990 15:05 us tac PALo utntE 602 2M 2738 P.05
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5.0 Conclusion As documented in this report ABB Impell performed im independent review of the PVNOS emergency ghting system. In the course of thle review ABB Impoll found that the m r issues regarding emergency lighting had boon formallyidentified by AP.
Emergency Lighting Battery Sizing Identified in LER 86 59 Emergency Lighting Placement identified in LER 8012 01 Emergency Lighting QA Classification identified in APS Letter 107-02588 MFH/ JAB, dated July 25,1988 and in QA Audit Report 89 018 Emergency Lighting Maintenance in LER 86 50 and in internal APS Memo 19100012 RRB, dated April la,1987 Corrective actions to address the identiflod issues focused on the immediate concern (s) with limited attention to the underlying programmatic issues, Recent correctivo actions identiflod/roviewed during ABB Impell's indopondent evahte.tlon appear to address the broader programmatic issues.
(
In ABB Impoll's opinion, these f asues represent the source of the individual deficiencies.
Completion of the APS correctives actions and the implomontation of the ABB Impell recommendstions in this report should establish a program for continusd compilance with the fire protection emergency lighting rcquiren)ents.
r.1 ABB InvallNo.ol 26554fYl Revision o
PALO VERDE N0 GEAR forReleases E GENERA T1HB
[q ROP 0,1990 STATION rsday, Octobe 1 NRC P r
OSES
$125,000 civilpeWINTERSBURG civil PEN ALTY Co tatt:
n notty against he P, Ariz. - The Nucl FOR PALO Do Andre violations inv lvi n
(602) 250 1530or Mark Fe, VERDE ws e
olo Vorde Nu lear Regulotory Co EMERGENCY o
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HTING erating Station fo oposed a os pr em.
ofoporoting for man n 2 "failuto to r
ent o agem oppor mply with then dequato Qualitent, NRC state o
ent equipm minim o
co ent. "
um feight hours i requir yAssur e pena ty is bein o
The em an ce (QA)progr n llcr ont to hav oppor g
August,1990e t violations a
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. Polo Vorde resultedfro e dedfor erge m for fir e
operatio n ylighting cop b c
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and hepropos d The first oppore e impo itio ent has 30m NRCinspection t
man n fsofo hutdow o
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o the ivilpon ltdays in hich tco dudedbetw po ificollyidentifi nt violatio, foilure s
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nv n pr ergen to implem n
ogra. The fire cylighting system e to QA progra notice f m
pon n
ents, procedures protection progr o
is compo caso, em nents required asm for fire protectio andpers am, o ergen ylighting f n lutilizedin ccording to the NR on c
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were the fire Polo Verdo perfnotproperly coror firo protection carrying out allo ormdo re ted,"NRC equipm c
ct vities ffirepr es "oll cylightin, a did ev luotion fthe Gnot odoquotely te otection. '
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n stated.
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te for the pr b e tified n
o etion ystems to po lemsidentifieddeficiencies in J l A sted ond o
. These uy 199. Imm for fire protectio s
0 erform their octions m diate n, including e
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N 2-f of operating or copable of emergoneylights os d involves 11 cited inst tohave ront violation,failured wn quipmentislocate e
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second oppowhere sofoshut oi ce 1987. In ea nit perform ond The anco problems orcos in emergencylights s nfoiled test requirements.
emergencylighting uoctions have been ken sght hours of voroll performance in perable some ive ver, m y correct and o o
wledge operate properly orofficiols ockno an PoloVerda87 and 1989. Ho design, maintenance since 1989 we curredbetween 19 h 1989 toimprove the dinimp completed since Marc stem. Thisis reflecte willbe requirod to oc mentsin em goneylighting r Additionalimprove f rman emergencylighting sy er Additionalactivitics pec co pleted this yea.
assure that the per o ificto the s
orgoing.
willbe onitored closely,toond proposed civ m
are vements activities m
Plonned designimpromergencylighting w of violation illbe Those molntononco continues to improve.i re ie ingtheNR werfacility ocated ofe C's notice 55 l
the of em gencylighting w
v wns anagement s PoloVerdo dtothe gency withinthe mercial nuclea vice Co.,which o er m
nalty, and will respona tonderdizedtripe-u b the ArizonaPublicSeroro S o
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wners ElectricC pe PoloVerdeisi ono, itis perated y The other coe s
w Mexico, ElPoso o
west of Phoenix, Ar z ldstheNRClicenses. Service Co. of N Californio Pu enough cloct 29.1% of the plant and olifornio Edison,Pu h
mitos Dopt, of Water & Power plantin (Arizono), Southern Co l
l (Texas),the1.os Ange es clear po Authority. Theforgest nu ple.
tely ourmillionpeo f
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.2 PnIs' verde Ceaussakstions e P.O. sea $2034
- Wheemia, Arimens 85072-2034 * (602) 250-5530 For Releases bridoy, October 18,1990 Contait Do, Andren or MoA Fe:lon (602) 250 t$30 NRC PROPOSES civil PENALTY FOR PALO VERDE EMERG WINTERSilVRG, Ariz. - The Nuclear RcGulatory Commin, ion (NRC) has prop
$125,000 civil penalty agolnst the Polo Vorde Nuclear Generating Station for ap violations involving the plant's omergency lighting system.
In a notico of violation to Polo Verdo monogement, NRC stated the penalty i proposed for 1) "follure to implement on odequato Quality Assurance (QA) program f protection," and 2] "foiture to comply with the requirement to have emergency lighting c of operating for o minimum of eight hours in all creos needed for operation of sofo shu equipment."
The apparent violations resulted from NRC inspections conducted between Ja August,1990. Polo Vorde management hos 30 days in which to respond to the notice of violotlen and the proposed imposition of the civil penoiry.
The first apparent violation, failure to implement o QA program for fire protectio specifically identifies emergency lighting system components required as port of the fire protection program. The fire protection progrom, according to the NRC, encompasses "oll components, procedures and personnel utilized in carrying out all octivities of fire protection In this caso, emergency lighting for fire protection equipment "was not odoquotely t deficiencies were not properly corrected," NRC stated.
Polo Verde performed on evoluotion of the QA program for fire protection, i emergency lighting, and identified deficiencios in My 1990, immediate action was taken to compensate for the problems identified. These octions assured the avoilobility and effectiv i
of firo protociion systems to perform their necessary functions in the event of a fire.
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2 The second opporont violation, failure to have omergency lights capable o oight hours in orcos where sofo shutdown equipment is located, involves 11 cited ins inoperable emergency lights since 1987. In each cose, NRC says the lighting units d oporofe properl, at failed test requiroments.
Polo Verda officiols acknowled e some emergency lighting unit performanco pro 0
occurred between 1987 and 1989. However, many corrective actions have been token a completed since March 1980 to improve the design, maintononce and overall perfo the emergency lighting system. This is reflected in improved performance since 1989.
Additional activities specific to eme jncy lighting will bo required to fully resolve this iss Those activities are on1;oing.
Planned design improvements will be completed this year. Additionalimproveme the molntononce of emergency lighting will bo monitored closely, to assure that the of emergency lighting continuos to improve.
Polo Verdo management is reviewing the NRC's notico of violation and propose penalty, and will respond to the agency within the required time.
Polo Verdo is a stonderdized triple unit commercial nuclear power facility located miles west of Phoenix, Arizona. It is operated by the Arizona Public Servico Co., whic 29.1% of the plant and holds the NRC licenses. The other ccmwners are Salt R (Arizono), Southern Californio Edison, Public Service Co. of New Mexico, El Poso Ele (Texas), the los Angeles Dept. of Water & Power, end the Southern California Public Power Authority. The largest nuclear power plant in the U.S., Polo Vorde generates e to servo approximately four million people.
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PALO VERDE COMMUNICATIONS DEPARTMENT +
STA. 6345 +
EXT 82 5702 Wednesday, November 7,1990 90-107 SECTION 2.206 PETITION PARTIALLY DENIED
' i a recent decision, the NRC has denied, in part, o petition filed by on employee. The petition, filed on May 22,1990, pursuant to Section 2.206 of Title 10 of the Code of federal Regulations, sought modificerion, suspension or revocanon of the Polo Verde operating hconsos.
Thomas E. Murley, Director of the NRC Office of Nuclear Reactor Regulation, stated in his decision that a proceeding to "rnodify, suspend, or revoke the NRC license: hold by APS is not worrontod' rogording emergency lighting and fire protection. "This decision is based on the corrective actions initiated by APS to dool with the concerns. There is reasonable assurance that PVNGS con be operoind with ndequote protection of the public health and safety, pending completion of ongoing correctivo actions," Murley stated.
Those corrective actions include designation of ornergency lighting as " quality ougmented,"
4 con:.istun! with the Pc!c Verde OA Critcric Menuc!; upgrcdc of prcycntivs mc!ntsncncs (PM) programs; and revision of test proceduros. Corrective actions addressing immedlote concerns of APS end the NRC have been completed, wh!!e enge!ng cetiv!!!es cro being men!!cred by the NP.C.
The petition also alleged that Individuals employed by APS and the NRC were involved in wavngdoing und sequesled ihai appropriate actions be token. The oilogotions of APS wrongdoing in tha oreo of emergency lighting and fira protaction nrn enrrnntly undne investinntinn hy the NPF Offira of Investigations and will be the subject of a tuture decision. Allegations of improprieties by NRC personnel have been referred to the Office of the Inspector General and are under investigotion.
$UPPORT THE CLEAN TEAM... RECYCLE THIS BULLETIN AND ALL OTHER WHITE PAPER.
FOR DAILY PLANT STATUS, CALL PALO VERDE UPDATE AT EXT,82 6397 Pl. EASE SHARE WITH FEl.l.OW EMPLOYEES U
,6 b
rule Verde Commenkations
- P.O. Den $2034 + Phoemia, Arizese 85072-2034 + 402) 2501530 For Releoso: Neuember 16,1990 Contest: Don Andrews or Merk follon (602)250 1530 PALO VERDE PAYS NRC civil PENALTY FOR EMERGENCY LIGHTING WINTERSBURG, AZ-The oporotors of the Polo Verde Nuclear Generoting Station have pold a $125,000 civil penalty, proposed lost month by the Nuclear Regulatory Commission (NRC), for violations arising from NRC :nspections of the plant's emer0ency lighting systems, in a letter to the NRC Executive Vice Prosident William F. Conwoy stated that the Arizona Public Service Co. (APS), operators of the plant, will not contest the civil penalty.
The civil penalty was proposed Oct. 16,1990, and APS had 30 days in which to respond. According to the NRC, the violations included "follure to implement on adequate Quality Assuranco program for fire protection" and "foilure to coinply with the requirement to have omorgency lighting copoble of opo,oting for o minimum of eight hours in all areas needed for operation of sofe shutdown equipment."
Extensivo correctivo actions have been implemented to improve Polo Verde's emergency lighting and other aspects of firo protection since 1989, Conway stated. Those include revision of the proventivo maintononco program, modifications to add additional omorgency lighting and to improve lighting system ovoilobility, increasing preventive maintenance frequency on emergency lighting units, and upgrading corrective maintenance prioritics.
"These actions demonstrate APS' recognition and acceptance of its responsibility to ossure that emergency lighting meets the opplicable NRC requirements and APS' commitments,"
Conway wroto.
Design improvements in Polo Verdo's omergency lighting systems are on going and will be completed this year. Additionalimprovements in maintenance will be monitored closely to assure that the performance of emergency li hting systerns continues to improve.
0 (more) 90 24
2 Polo Verdo is a standardized triple unit commerclol nuclear power facility located 55 miles west of Phoenix, AZ. It is operated by Arizona Public Service Co., which owns 29.1% of the plant. The other co owners are Solt River Project, Southern California Edison, Public Servico Co. of New Mexico, El Poso Electric Co., Los Angolos Dept, of Water & Power, and the Southern California Public Power Authority. Polo Verdo gonorotos cloctricity to serve opproximately four million people.
All three units are currently in ocorotton of 100% power.
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- age Sgi.are. Seventh and Monroe streets. The rurtet.cpe ewry were k=s wednesday frorn 4 to 7 p.m has beers extended Entd. lune 27. AbciA 2D focat grcwers offered their wares tNs week.Short Takes.D3.
- That o their c, ?
Camfra U Democra A Complaint targets top A-plant aides IF RepaNics -J Wy Davod Schwartz Ihe mid.4 stenzs from inspec-
"It shows the U xi d rere the %%h.6-g and icTedrg centralIT *I
- * ' = ' * * *
- tions made carfier this year by NRC people at APS wiH snoop to to try to an ongomg NRCissrect. ion -
The o The top two c2ecutrves at the Palo WM The inspecisons covered get the beat cKthch backs hesaid.
The co rpia:=t names Wiriam psnd. C1 Verde Nudear Generatzg Statice the plant's u~ ry-tighting system.
AP3 had co i-~be-reactim to Comray. top em.sve at the phat. Pat Wng Erve been acursed of pressuring US.
Pab Verde has been fined $100.000 in the aikgatiers.
and James kevine;. vice press 5ent for Img and _
regulators into " watering oc *a" a the past by the NRC for gia -
The comp!amt by electrical cagi-maclear productum.
son.cr:=r h crmcal report shoot the plant.
with the syssent
' me=r Ilada Misebei scels to have The two said threegh a spoke:rnan Ik E" A formal u.,Jsi4 IEed with the "We can't believe that APS would Paio Venie's beeme *%offert re-that they had not seen the co-iptamt deade wh T Nocksr Regahtory Cocunisnou aho put in tie fix with the NRC ratocr voned or susgraf-and that they haf no cousment.
and ic g, r*
claims that Arizona PuNic Service than just trying to fix the phnt
- but
).fitchcII has filed cxncelaints with As NRCspokesman do$ned crun-cocsader a E
Cc. ananagernent 1-.rt,a a con-it did. Washmgros. D.C attorney the NRC in the past, bct this is the cie: t en thecocsplaint s spedfxs-dien s certed efTort to harass and dheredit" David Colaps ta sail first that les becocie pob5c.
We have rrrerved the petroon and hgs'at. ion A coe of the inspectors invo}ved.
Cohpinto Ekd the cos pla ct with The chirs aho seeis to have APS wd! address it
- saki GregCook dthe A3 este l
m APS. which rucs the plar:t west d the NRC on behalf d ao cug:ncer and Palo Verde's tcp two esecut:ves agency's Repne 5 cdiice fu Wa:ast e,e e.
Phoenrx cwns about 30;e:ce=t ofit, who woris at Pab Verde.
fined a total of sin:iimens for
-See FEB MEE. page B15 Comai:rtce Wxg Park's rocks glitter and cost gold.
$14,000 By.n:".:'.cbeco as the Phoeux Gry Couce] voted 30 to Red Mountan Miz=rg Inc. which wi;I M:ncta:n's inicatory, it saw a sa d
- '""**'5"A**
boy 900 tos s of the besiders.
supply the boulders. Iley have 3 cts d sarrpic of the silver schists, which $
FecI Lie taking a quici lick at one of Visitors to the 32.8 million garden, chara:scr.'
cuore Lke the rects used in hpan's
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the boulders that will be featured in the which is espectal to be campicted at Seven las6 cape arclutec:s fraus Hi-gardens.
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His eji Friendship Garden at Thocaix's Moreland Street and Ccztral Avenue in meji. Phoenix's hpecese s=ter city.
- 'We actuai*y took thers out to
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sgutng 1992, wi5 srp bct tem among visssed the VaBey in henary to select field, and they staked est the rocks il y Doa't.
flowers, trees and sparireg si!verschists-In*nges rasterials Ihr the 3. acre tea wacsed Le said.
y g'
These are not cheap rocks we're Silver schssts are scsooth. Iight gray er prden.
There's a ether reason for tes-ga:e talking about.
alver. gray and cccia:n the shiny t=nerJs The hgercse were not interested in visitors to resist the te=rpation to 1, These are hand-selected silver cr Art snica and white q=artz. ~
red-or gold-coicred " local rock." Img-the silver schists: They're big.
8 worth a totald514.000L plcs tas-
"It s got lots d layers, lots of sp.erile brake said.
TIr range is sire frosr half a tcm 3 Price didn't seem to mzMer Tuesdsy. Io it." said Dale Ire 5 rake of Mesa's But as the delegstm r*MM out Red 17M tes:s.
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Men Locaikws Higher bus fares, better service proposed
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complaint alleges
--PALOEtDI. Aumpaso#1 being too agtteulvo in his Ondingsw s
Cmk Calif.
Cook uld the agency, received the ebout the emergency. lighting system, j
i complaint Int week.
An unidentined employee at Palo the NRC's inspector general, wholie told it has been turn d
Verde alletedly told Mitchell that Ramsey would be transferred.
5 conducts internal probca and audits.
claims Ramsey wra r,etallated e ains Cook declined to any whether there la t, '
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g an on.goinginvestigation.
and that APS succeuM1y he The complaint stems from inspeo-his comsponding inepection report t,
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Inspector Charles Ramicy and othermade earlier this year by luted to "whitewnh ilgnincant ur dl.
problems at Palo Verde."
ety NRC personnel, Cook ald Ramsey intends to q found that parti vacd in the plant'sDuring the Inspections 4
soon but li not being forced out. H uit l'.
uld Rembey began looking for a e
emergency. lighting system did not other fiied, job befort the complaint w n.'
meet requirements.
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The complaint alleges that APSRamseydeclined comment.
was infortned of 14 potential viola.Colipinto uld the nettons of AP p
the finalreport wn lisued April 24tient that could result in O and NitC esecutivre are sending th S
wrong lignale to e
APS management including Con-Verde employees. inspectors and Palo (j -
way and Levine, un,tenhed a cam-"Tidt has a tremendout chl!!!ng paign almc4 at Ramsey's supervisors effect on concemi" people who have tafety in " cover up and choose w,hether they want tolahe said "Ihey hav 6erious violations,"suppreu additional 4
11 uys, Levine and Conway sito were jobs on the line orjust play ufe.y their top regional NRC onletals to accuseaccused of personally co
- I' In September fined $100.@, plant operstors wert t
for violations that 1
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Ramicy of misconduct.
included falling to inspect the eyetem i
Mitche!! said the also heard her for more than a year and to e
implement an adequate testing system.
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1 IL4 The Arizona Repel:IIe Friday..Isoe I. s993 APS, denies. skewing-rep,o,rtm Palo Verde.
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- 7M clear Regulatcry CommissSe cGicials 'partare retalIy withoutfoundation"-APaloiVe'r$g?.4~,OrM]M the W.ji'h
-mara rmeri.g twel NQchrges cfimper aWect m theff:ar.? W-e
.? opera'orstof the Pals Verde Na-.
de spokesr:sasiDc4 An-- there is Exandation to clear Generating Statmnh. Thursdayn into."watericg idoya".a ' scathing.; VConway and levise apparently saw,, tws said the).cc:mpe=
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"categoncal7de5ied aBegsoons thaty insp21.osr' report on thEeniergemeyg the
- for the K, time Inte;hichherg.eomme:2,\\ cafthe_Waict ne.cces.om was mee by u.ds..g.. 411[,,**" Yrs A iw'Mi Levme z Wir{y;,ayPalo4 beng,:re,y,$ngg,
, ;3,;; 3oM it. Never'hefore he've I a
top'esecutives at the plact imrreperly ' figtedag'sysuhF,Jttg s' intiencedf ree&.1:.ph e
.= seenipchJacCorjnpropraiy;so Plast;,crer* prs aho denid cisms: g.Etcheri,=an..cogmeer.3 o
.,%,o.g3,c,,,13,.% g;acha;,i hi, r,io ye,ge o,ra, asi. --e &#t h
l tha't manage:neas iried to discredit.erghe nue! car plant.fdwy, york, at,3,,2,,sghting at the pwo veree 'anwaydid not reterm caits.y p N
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n o: insW~whof helped ecmpRe, the ? ; In ' ar courplairti E?ed -with p;--' ; facility, the raat
-the The Westsagton, D.C; a:torney. spokes: man Greg Cock sad t'.2 a:atter the[saane way es-other. regulatory; S.fded O' reportNthe s'oclear' power plant *s? federal'igency,' Mitcheliciniso 'aBegen' r 1
companysy nsponse. was - w.Jch rmi ed m wmpanist rast ;
s 5 eineisency lighting system.fJR. 43 that.thi iispecici ves' harassed and. iss=es.? the utilitis stde=sent sa:
U I1. ara 7 two.gbrsgraphi statement,pretaliatedIagainsfis 'a'iesielticf'syfnThe federal agency IImed the plasty,W cJ _;.,C -: a. n _weelg
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0 ArizocadabSc.$ervke ds said-it".'cethestra'ted eErt by APS aiesiitivi:sj p@WN I*I4..the,g.,,
l m September Ear #='h 9 "welecMes ~andMII'cooperasei. wit ( Iam Chailes, Ramieyjepori@ W g a!!egadas.%@ypneecintol_thF caly.fimid; hat parti is the prants mnylindependent o
44pm:0%Mlightics system!didfcoi a FAPS nacsges sad My mma Pakiv rnect requirements. S.M46..E E Vefde,Ywhich isi:50ges rdt of% ' APS~.said thai BiE'Cci:ivay. Palo i
' downtown PhidirN.M.ji?.-B MS Verde'sE No;, l'eEmdivefand James T *hwillity's stateMNresceIdifLeviMe^pisafs cacic'ar-productica 5 one day ener ii W revesia th.c aEtvicegresnient:s,.i+ reviewed. :.me h
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Adaorta Pubtle Servics Compamy NEWS MEDI A REPORT o,,,
Friday, June 1, 1990 ce Mesa / Chandler /Ternpe, Arizona Tempe Ud11y News Tribi,lne Me$A Tribune / Chandler Arizc, nan Tribune p g g,3 y
Corporate Medla Relations Department
"* ** B-5 (602) 250 2277
\\
l APS denies pressuring inspector to tone down Palo Verde report M ape rooons-The complaint cal!s for the NRC to for aggressively rnonitoring the Palo WINTERSIsURO - Arizona Pub- " modify, revoke cr suspend" Palo Verde emergencylighting system and l
h e.eMee f'o officials derued auega-Verde's operating liceroe a.1d caus over a two week period, beasted that j
l tions ThurWay that two top for Conway and Levine to be fined $1 APS management was going to 'get executhas attempted to pressure en mUllon "for tampering, obstructing rid' of (Ramsey)."
inrpector into
- watering down" a and impeding an or, going NRC Additionally, an unnamed APS etgativeinspeedon report on the udb ir,spection "
employee told Mitchell that APS ity ablo hd*
- elm M*
APS, which owns 30 percent cf would get Ramsey trarsferTed to The allegatons were made in a Palo Verde and operates it, w:ll coop-another regica because he was caus-titlen filed with the Nuclear Regu-erste with anyindependent review by trg too much trouble at Palo Verde Fatory Commitslon May 22 by Linda the NRC, according to its pren and the San Onofre Nuc! car Generat-hDtchell, an APS clectrical engineer release.
ing Station, accordans to the com-at Palo Verdt The complaint alleges Mtchelfs complaint, filed by. plaint.
)
l Chuck Ratnsey,a Region V inspector, Washington, DC., attorney David Greg Cock, spokesman for NRC was pressured to tone down an Colapinto, al!eges that upon learning Region V,said the agency will resiew Inspection report that allegedly con-of the vlo!adons in the report, APS the allegations and do whatever b tained numerous violat!ons with the. harassofficials " began a concerted effort to needed to review the plant's emergency Ightleg system.
and discredit (Rarmes)
Cook described the allegations as Two APS offic!als named in the throgh his superiors at NRC Region ' "very serious," and uid more than complaint, Vice President William F.
V?
one arm of the regulatory ageacy Comeay and Nuclear Produccon Yace The complaint did riot name Ram may have to review them.
President James Levine, said the sey, but NRC offlefals confirmed "The regional staff normally is in i
charges ofimproper conduct on their Thursday that Ramsey was the charge of inspection of regulauons part are " totally without foundauon," inspector identtin! as " John Doe" la and safety aspects " he said. "Wroeg-accord!rg to a press relean put out Mitchell's petition.
doing of NRC personnel may well be by Palo Verde ThurWay.
The complaint states Mitchell wit redewed by the (agenefs) inspector "APS categorically derJes any of noped her superiors say the utility general."
its tt;p noclear officials attempted was go!ng to contact the NRCand get Accusaticns have been made that either to pressure NRC officials into Ramsey to *back off "The comelaint NHC personnel improperly moddied impropedy watering down a report aho 6tates APS employees"made disa an inspector's report prvviously, Ccok i
ce to dactedit any NHC hspector," At paraging and labe comments about said adding, "I don't know what the said (Ramsey), openly criticized (Ramsey) recults of those inqutries were a
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l Cook confirmed there were dis-cussions between Conwaydamsey'e 14 vin and NRC omeists about s
findings before the commission ler.*i a final inspection report Ap' ril 24. But he noled these kLMs
'of discussions are notimusual.
NRC has a longstanding polley 9f communicating !!ities !! regu.
its *.onterns with the nuticar ut lates. Inspectors, who are assigned i
to visit operating pinnts and evalu-ste,their compliance with hun.
l dreds of complex regulations, fre.
evently brief plant managers on their preliminary findings at the conclualon of their visits.-
. After these briefings, or exit interviews /' inspectorg return to l
their offlees, analyr4 the Informa-tion they have gathered in greater detail, discuss their findings with t
l etherinspectors and their supervi-sors and then write preliminary tecommendations During subse-quaht discussions and meetires.
lhoie recommendations may be emended before an hetions are taken, y regulatory l
such as the i'
on of fines or penalties.
uring this process, which can la e several months, utility offi.
clals have an opportunity to sug.
Best possible solutions to problems uhat have beenidentifled fuinspec-tLons or challenge the validity of kninepector's findings,
- The petition alleges, howmr,j tlat in this instanoo APS offielats Went far beyond the normal bpunds of secepted practlee, launching an attempt to discredit Ramsey in the eyes of his supervi-a6rs, so as to " cover up and oppr,e,as additlemal serious viola-The April 24 report israed by NRC
- ontains crit:clem about the adequacy of the emersency light.
ing system,but no ridditional fines l'
.were proposed. Cook said that NRO officiak are continuing to
. review -problems identified. by Ramsey at the plant.
l
- Arintu Pubtle $<rvico company NEWS MEDIA REPORT f idav. June 1.a.1990 f
ceie e,n _,PJtoonix, Arizona pge,i.3, _ The Pnoenix Gazette Corporate Media Relations Department p,,,%, J.1 A n.6 -
(602) 250 2277 Petition claims APS.
' tampering' 2
Tho complaint stems Itom inspections
- k. ;3C eo c 2 o. c a s nRC omca3,, node in,t y,,,
on n, emergency 118 ing system that failed to larBSS8C ins 30010r oper.te proper auring. shutdown.t tw
$9.3 billion, ti lo reactor plant 65 miles 1.y V!ctor DrleksVM912f2LQMlGTU-.
D west of downtown Phoenir.
Polo Verdo managers weie fined A petition filed with the U.S. Nuclear
$250000 by the NRC last year for Regulatory Commlulois claims two top probIctne relating to einergency shut.
Prilo Verde _ managers attempted to "hu' downs at the plant, including a $100h00 rots and dneredit" a federal inspector's fhic for fallute to properly ranintain and critical evnluttions of the nation's largest test the emergency lighting system.
nuclear plant.
But the petition alleges that alter APS The petition, Gled afay 22 with NitC officials jearned NRC inspector Chntles chairman Kenneth Carr, al!eges that
.Hamtoy had identified 14 other potential Arizonn Public Service (h executivo vico nesident William Conway and Jamen vine, APS' vice picsident for nuclear production, pressured highaankir>g ofli' violations in a report he was cials at NRC Hegion V bendquarteis in writing,they exerted an *1mproper Wulnut Creek Calif., into "waterinA in0uence" and " began a concerted down" a crit! cal repost on the Palo Verde effort to harass and discredit"him.
pinnt.
1 The petition claims APS tried to APS officlots sold Thursday that il get Ramsey transferred from the entegorically deny the ellegations, calh, icy ng NRC's Region V offico"because he I
them"tottdly without foundation."
was cousing too much trouble."
l The petition won flied in Wt.shington.
- ' Ramsey declined to comment on l
D.C., on behnif of Linda Mitchell, an the petition and is said to be electrical engineer who wor ks at the plant seeking ajob vilth the UA Depart-and who describes herself an n ment of Energy.
"well.known whistle blower at Polo
. NRC spokesman Oreg Cook said Vei de."
Ramsey, who works as a fire The petition, which socks a $1 million protection inspector, had been fine against APS for "tampeting.obotrott-aceking the DOE Jeb - whleh lug and impeding" the N!tC inspection, is Involves a promotion, raise and likely. to be reviewed at llegion V relocation ~ for serne time and the headquarters, the NRC's Of fico of invvati.
hb move was not related to the gations and possibly by the commlulon's current mattere.
Inrpcetor pneral.
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i NRC Stumbles in Dark Arizona Plant s
han dnde Metebau landed a >b at the Palo Several months later, when en NRC lampector W Phoonts.ahe thought abe Verde Nuclear Statlessent checked theli in bed not been n@ati,g system, Mitchen told him it d found the and she gave him the Cadmee of nuclear power planta. Now she thinks
""tofScott Sleek obtained a copy of M.
k's an Edsel.
Our associs
. Mitebeu, an eleetnc$ engineer, mother of four and NRC Qiarios Ramsey's report coo 8tming
. grandmothwof two,can newadda histleblowe"to that the system ots did not work.
w her resume, flhe has become the central Ggure in yet The washet beginalog for both Mitcheu enother story about how be#y the suelear power and Ramsey. Mitebeu claims that she board a industry does he dangwous job and bow federal escussion a which bar beseos planned how to get
+
reguistonlook the other war.
the NRC to take Rameef on their backs.
PaloVerdeis owned by the Arisons Puh The sempear a socimingnameerof
'Servios Co. and is the largest nuelser incility la the almodut a a lhy.N NRC, which
' country. MitcheN has haceae a erusador against would new betray ke we lupeaters han span,;
what she sees es safety prahl==== at the plast.
tbs indutry k is suppened to regulate, put the
, f,,,,,,e NR to N
,[,gn t bou's.
ted b N Pubue W Co.
-*-w*-wia-igyigg*a "T*'P.ilt'ath wany w s d *ien,.
d a
- r-a ae a rei co,,4' Commission alleging that Artmas Pu Swvios who hd as of apwtence in
' tried to escredit an NRC lovestigator after he. '
innd eenous safety problems at raio Verna nocinaramerSy, said she paid a price for tdag ? '
the true. She cialme es and her husband hve De story besar in March 1989 with a near disaster at Palo)'e'rde. De bem threatened anonymously,
' down during a power fauure. plant had t6 be abot The Pak Verde case reinforces pubbe fees The emusener bachap about the nuclear power industry. H the nation is 4
lisi ting systaan at the plant failed during the *.
eve going to how the con 6denco to reh on'
- blackout. in the darly operatore goofed the shutdown nuclear instead of erty coal-burning poww.. ;
. procedure and two other workare steppedin,
- plants, Islastry needs to keepits noas caen
.1 terrected the sletaka averted a cahndty.
and the toes need to do theirjob.*
j e whistle-blower. "ptimistic aftw her experience
. When the NRC fonad out, Arinona PubBe Service is not o was fined $150.000 for falling to malatala the.
Kthisis the future o(nu: lear '" W
.i
- lighting systes and for otbor violations,
anergy ( she said,"we're in trouble in this country."
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fuesday July 10, 199d Phoettix_, Ari20na The Phoenix Cazette p,, ng,,
Corporate Media Relallons Department 8 1 & B-2 (602) 250-2277 p
th b
The report, whkh nummarlres repoit elem from weaknce in NRC report rbs nnai+ mode by aur =C em. unee mnar mns a punt ocovby, clals during inspections of Units 1, said Oscit Cook, a spokerman for 2 ond 3 in up,.nd duno, the eommi,4;oe s ri.gien s ort;<. :n fire safety plan Identliied Sve opponent vlelntions Wahnut Creelt, Calif. 'lho.te areas
- r s"n'*"-
~ ami
- a a a ""a " ~ "-
at Palo Verde d aami or"Verdo othclais plan innee, engineering und techn!r NftC and Palo to inet t i day to discuss the repm t.
support, und ufetv este$r.inent Of Y1ctor Dilek, Federal ref.tilators' also crill-cod qunlity verification Palo Ifgf3pgtgpp.rmt cited Palo verdo effielais for Verdo received moicinal r,rade:iin Sm.co it began operating, the 10h.
falling to irovido 'rollable emer. those nrens in its most recent annual federal evolunlion, Verde HveltaLQginJailm'M4tlert has gene [,11[rht ng in key oicas of the Palo Verde offielels deellned to filIR on a nre notection plan that could pgn funy of the einerrency have humpeted workers atternpting to lights in11cd to peiform os designed comment on the N!!CicrorL.
shut the pInnt during on emergency, during eight hour tests - even Commission dfkints could ini-federaloffielole nny, ofter workers recharged or re-pose additional Ones ngninst Poh De fire protection plan und at Palo pineed batterlen beforchand.
Verde based en the outcome of Verdo - the nation's largest nuclear Although many of the problems today's meeting in Walnut Creek, power plant - elnce December 10B4 were identified by NRC ollicials in in May, Washington, D.C., atter-cllrects operators to use equipment in 10 1984, they took on added signifi-ney David Colnpinto (iled a pell-atens that might not be accessible during cance in March 1989, when an tion with the NitC claiming ihnt a fire Nuclear Regulatoly Commission emergencylighting system etIJnit two top exceutiven at.ApM4 L cllielaks sold In a report released Monday, 3 failed (o operata darIng an Etijk Eafyhaftt pressurec c
Decours worktre might need to manu.
ernerpeney shutdown.
cominission to tone duwn u sepott Palo Verde montgers were fined issued April 21 on the einergency n!!y operate invitches and valves in t. hose
$200,000 by the commistion lost lighting nystem.
arcos, it wits not clear whethcr they were year for pr blems reintin to William Conway, APS' top ene-suppond to try to breve smoke and flames t'morgency shutdowni nt ihe p ant, utlve at the plant, and Jntnem or welt until a fire was extingh.shed to in luding a $100,000 fine for Levine, APS' vice preildent for sh Jt the pbat' NRC officiels soid, failure to maintain and tttt the nuelcar production, have denied emergencylighting system.
the allegntions in the complaint All the proble;ns'ldentified by Colapinto filed on behalf of Linda the egency in the latest inspection Mitchell, a Palo Verde engineer.
I l
F
.B Palo Verde accused of 5 violations i
t'0 pmgram n inandatM by ideal ses set dhm Phenh.
per*a nid wie de NRC by a No
]
cperateg requiremads.
Specifically, the pbet was cited for Verde employee cmccruing problems k
NRC citations wie ac P ant's enW@nne E
l inVOlVC Safel"
~*** '*** "Y 'a*:$ a*ua$ ~ fadins em
$y J
said Greg Ov4 an NRC spokesman-o Provale reliable emergency light-system.
rh<s why we asica aem io co.ne in, fe, a,,ui,cd eight hoo,, fo,,,fe in u,y,,,ginee, t 12, uitchei, in shutdowns and exphin some of thae items to shcrdown of the phnt after a fare.
charged Palo Verde's top two caccu-7
- B e Report Grefrotection violations sives wih sucessfuDy pressaing 4
E_
- i,,y David Schwartz Tcp-level Palo Verde executsm to the NRC that affect Palo Verde's NRC offacials into watering &wn a n;4 woe at the agency's regimal dce an ability to " achieve and maintain" safe highly critical repcrt.
b
~ cles s
3*
ag Rey an oversight Pmfram in ved e
ened far five apparcat violanons of not te reached.
g emergw Jg g
ds_Med h M hay, Palo a
federal regulations involving their A Palo Verde spokesman declined other fire-protection program activi-Verde's top executive and an es cutive abihty to safcly shot &mn the phat.
comment on the apparent vaalations.
tia v b pres t, anx! James bne, tk De plant's operators could face a The NRC now will wait for written e Review safe shotdawn proceduars plant's nuclear-production vice presi-fme for the apparent abcses identiGed coeus, cats to the apparent siiolations canaused m e penre pmce&rcs dera-by Nuclear Regulatory Comm2ssion tdore deri.fing on the neat step. They 3"*""*l He irispor, Cha@ Ramsey, inspectors.
could dmp some of the wichtions e Follow regm. tions on ocidoor aho was mvhed in issumg the a
The items cited by the NRC deal based oe the rcsponse.
me of anergency li@ ting in utt and agency's latest report contammg the with operations that take place during he 6ndmgs stens from an inspec.
five apparent *.iolations.
an emergency. These include problems tion by NRC dIicials d the phet's damp areas.
Several of the concerns have been Conway and Lesine have vehe-with rehable lighting after a fire re-three reacsors in May and June. The lated shutdown and fac-protection repors ccmcen: rates on the plast's broached by federal regulators before, mently denied the allegations.
procedures that instruct employces to emergency-lighting and f2re potectioit most recently as part of a 3250,000 Cook said the new inspection me equipment that might siot be synems-two vital areas.
fine kw emergency shusdown prob-report dispuses some of the accma-reachable daring a fae.
NRC inspectoss chrtmicled a pat. lems. Tlad fme, issued in September, tions madeby Mitchell he iraspection report aho says tern of these apparent viotassom, some included $100.000 for emerge wy-
"De report imficates regional man-pimat opernicas did not report siola-of which have been allowed to exist lighting pmblems.
agement is not interested in covering tions of the plant's firesprotection for sestral years at (Le phns, about 50 The report comes on the heels of a up any potential siolation," he said.
'U B4 The Arizza Repubile Wafnesday, July i1,1990 k
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.. -i_a m..e
//7fA Palo Verde's Unit 1 O
f"mally producing power - a week late Full capacity still 7 to 10 days away By David schwarts were elated this moming to h:4 N v '
The Mrona pernAino found the problern."
1) ne probtern plagued Unit I rene-ne problem kicked in last wk, i
g,,o tor at the Palo Verde Hueleer when the turbine amerator shut itself
49 Generst}ng Stadon began produelns off twke whm cp: rating at low.
, a ejectrielly nursday, almost a week 6peeds. Inadequate oil pressure to later than projected.
devloed inskle the turke's control Operstors on nursday afternoon systern was blamed for the shutdowns...
began the comples procen of taking Andren pH that the system has.-
the giani reactor to full power, pying 'been teeted and that operators are.
problems involving a turbine geners. conytnoed the prob'ern hu been flied.""
i i
tor han been solved.
It's the nort of a probles you',
Unit I, dogged by problems s! nee it
' ouldn't have todoed until you used ;
w began commercial opersuon la Janu. the equiprnent," Andrews tald.
h' M'** *W4 to dispisy at Metrocenter's new ery 1986, had been out of 6erske since ' ' ' E1ecutives at APS had hoped " '
is scheduled to open nert week.
March 1989 for a major overhaul, it Unit I would be trady to help thern ',j' gg ggg g g,6 reak demandai,.
the toutyis that we're an anchor it will tste seven to 10 dayt before whern record hlsh ternperaturce baked.
- docan't compete with the mall's *he 1,270'megantt textor reaches Arltona. But the last minate problems i
full power.
. forced APS to buy power from othet" t r anchors. It doesn't help to bring a anchor that is name u the W umday, it was providing 20 utilities to cornpertsete for the k4s.
- 't stunt erita total power to customers APS own: 29.1 perust of thq.,'
n anchor is a large tenant, usually in Aritons and across the Southwest.
triple *rractor plant, whkh is about $0 3 rartment stone, that draws large ne plant, cyrated by Arirone miles weet of downtown Phoenix. nq : i bets of shoppen to a center.
Public Service Co., provides power for SRP owns 17.3 percent.
ameson said he expccta about 4 million people. It seem seven Plant execudves endmate that the i
kn people to go through the flouthwestern utilltles, including APS Unit 2 resetor wl0 be returned to rtainment and discovery pavillon and the Salt River Project, servloe by next Fridcy after a slmllar '!
year. The main entrance to the "It obviously cost us a few days, start up process.
tion is on the wetittn side of and we we:re disappointed," sald Don De Unit 3 reactor is operating a;l k,'
mcenter.
Andrews, a plant spokroman. "!!ut we 100 percent power.
tidway houn are 10 a.m. to dght dally, etu t for Prldsy and E r,"the i, 2, r e'tj Sales near for thrift's assets be 10 a.m. to 7 p.m. delly.
-$Al.!!, Acw/wselid N. 24th St. In Phoenliis another large,'.)
.s for comrneselal and residential devel. holding the receiver is atternpting to,'.
}hoenix tell, and Schafter uld there arq orm-<
uv e l- - e Pa - l -
- t no Superstiden Springs develop-ment originally encompassed about flank of America, shkh bought
. lie said negotiations still are 1,700 acres both north and south of Western's depc$lta at the end of May,.].'
mInary.
the freeway, but more than half has Schaffer uld llank of America,oI' whi Of,ch occupies the building, ha he city has selected a alte south of teen sold to other deve pers for 8 y
' "j convention center for that pro-go}cets sue l8ft a
titi rings tennwhile, the Rouse company, gional shorting mall.
Ile esid that the markella grod for "
- h is building Ariron Center, e The mall h espected to open in WeAtern a estets and that the receiver !
stown omte retail complex, has November.
has sold tiestly $100million of prop I-side space in that development for The Western Savings & Ican trty onr4 owned by Western since the '.
4el.
Association Corporate Center at 6001 start of the year.
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- f. alo Verd.,e fac..ino fine Q...
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1+6.g ncy fines iev,ed. gainst Paio vere. nuclear piants ii important.'"so si oL. aton can sa to safely shut down the m plant s lack of from 190 through 1989 and a hending 9
- -,amd - en m ou.
s>5.w0 r-,eem poi u m ew againt the nation a largeat nuacar piani at nighting systemi fut.
'backun,'In Itm, o "I
o more th a si <=ittica.
r>io verde >>oke>= a ooa ^=dre >
- ne latest note'estes*" apparent viola. said,"We have been aware there have been.
r 0"
<.t otions ' of' NRC. requirements" identified? 'dekicncierin the emergency.11 hting sys..
Mduring inspetiontifrom January throughF tem.We are cetially redes $ jng the
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f ign By Coy Wester.
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it Anone t<. pac, '
4 'y.
' ' Augtat. It uys one. season for the sim,of,.wboltsptem."
Managers of the' Palo' Verde Nuclear, lthe proposed fine. is "your. poor. put;.. Corrections to the system began in.
sb of keeping emergency lighting avai1*ble/*; performance involdng required emergency? M Generstmg Station have donc such a poor c Einergency 14ht!n'. failed.4.'.y.g.l 9 7 end of this year, Andrews ' '
?2 Cook sul, "At this time, all' parties
. b case of an accidenf that.they should be'.,,4Ltisg."
l s
when.nteded' '
lighting at Palo
, fined $125,000, federal regulators tif."'
? during an accident in:19&9 and 10is becQ,agru that Ahc emerbt toos sa tmdue.
.De U.S NucJear Replatoi9 Ccmma Y found delkient in tests 11 times in the past.7.Vuos is adequatt, alon proposed the fms t}us week in's notke 1 four 3 cats at Pab Verde, no:nrdicg,ta the, arcount. citime..to get there,.ard there..
~... f. were more than enough indicaton c( the -
- t.,* -
. Cook ssd problem?
Zhent to Arizona.Public Service CElyliicY.' potke.T NRC spokesman,Jf $;
Oreg o
tes Arid ewwns the nuejear power,.
ti.
j,.,j, y,;.Wu 6 hRursday;,that k,cepmg r. battery. powered,, e.g x 4 e M AVllti,page A L Paki Vsr'de=.fabind.iew fime v
,g Palo Vefde's lop executive,. Ihl!
Y l 'l'Al0 VERDE, from psp D6 t
.W conway,"If you had taken a broader N
7 view of emergency lighting and ad, Emergency lighting failed duringemergency shutdown of Unit 3 of' identified the QA thi,' three. unit nuclear plant in weakneswa following the March 1989 htarch 19894, Operators had to use event, the need for the enclosed flaihhghts in one steamy area where enforcement acuen may have been Gdk of better emergency lights con.
avoided.",,
tributed to, damage on a vahs they Palo Verde managernent hu 6ntil
- ere trying' to open to reduce the Nov.'15 to respond to the notice of steam," Cook uid.
violation and proposed fine. Andrews
.i','De difficulty they had in seeing said he. could not uy whether the equipment and reading the plae. management would contest a fine.
Ud ' instr.ictions (posted beside the Palo. Verde management also has talves) made it very difficult for thern not 'yetTresponded to a Sept.26.
tg open two of the vahes they needed proposal 1 rom the nuclear agency for toopen.They ended up breaking the a $75,000 ftne for inade(uate report.
ing on medical records of peopts who handle on one vahe."
..,pc vahes involved were Unit.3's operate the plant's reactors.
mais atmospheric-dump valves. Prob Fines are pad by Al*l,,the Salt leras that led to and resulted from that Riser Project, and the five out of. state esc'nt shut. down the unit. for 10 utilities that (wwn Palo Verde. The racinths.
. plant, which is $0 miles west of,
' In a coser letter with the Oct.16 downtown Phoenix, has had all three dotice, 'NRC Western regional Ad.
reacton going since Sept, 25. An.
r,uinistrator John R Martin wrote to drews said.
ARIZONA REPUBLIC October 19, 1990
Palo Verde facing $125,000 m FINE fine for emergency light failure From B1 NRC officials said the emer.
87 Victor (Meks cials said, some of the violations were gency lights failed Il times since THE PHOgi!X ON permitted to exist for Several years at the 1987. Many of those lights failed to Federal regulators todsy proposed a nation's largest nuclear plant, which is 65 perform as designed dunng eight-
$125,000 fine against the operators of the miles west of downtown I,hoemx.
hour testa - even after workers Palo Verde Nuclear Generating Station Although many of the problems were recharged or replaced batteries f:r failing to maintain an operable identified by NRC officials in 1984, they beforehand,NRC officials said.
gained e.dded significance in March 1989 Palo Verde rnanagers were fined emergencylighting skstem.
when emergency lighting at Unit 3 fe"od
$250.000 by the commission last This would be t o ninth time Palo to operate during an emergency.
year for problems related to emer.
Verde has been fined by federal regulato,rs NRC offleials said the failure of an gency shutdowns at the plant, since December 1963. The Arizona hu. emergency lighting system at that time meluding a $100,000 fine for clear Power Project, a consortium of seven " contributed to the severity of the event,a failure to properly maintain and Southwest utilities that owns the $9.3 hampering efforts of workers to activate a test the emergency lighting.
billion plant, has paid $810,000 in fines.
t,et of steam. relief safety valves after the The NRCinspection report came Nuclear Regulatory Commission ofil' plant had been shut down, on the heels of a petition illed by cla!s identified the problems with the In proposing the fine, NRC oincials plant engineer IJnda Mitcheft plant's emergency lighting system during noted that the base penalty for the with the hTC concerning prob.
inspections of the plant's three reactors violations is $50,000, but escalated be.
lems with the plant's emergency-betweenJanuaryand August-caura NRC previously identified th lighting system In May.
"The problems have been corrected problems and they had gone uncorrected.
The NRC's Irupector General is now, but they were not very prompt in In its inspection report, federal regula, touring the plant and interviewing getting to the bottom of the problem," said tors said plant mansgers failed to comply workers and nanagers in responte Greg Cook, spokes: nan for the NRC's with regulations requiring a reliable to the petition.
Region V offlee in Walnut Creek, Calif. emergency lighting system cepable of Palo Verde officials nottfled
" Fortunately, we don't think this is operating for a minimum of eight hours federal regulators in August that they disa findings, greed with some of their typical of their everall performance, and failed to implement an adequato but acknowledged that though."
inspection program for fire protection..
Despite repeated warnings, NRC om.
Soo nFINE, Pago 94 se emerg ney lighting systems did have pro lems in the past.
"Palo Verde management is reviewing the NRC's notice of violt. tion and proposed civil pen-l PHOEUlX CAZEITE alty, and will respond to the agency"fficials said today,within October 18, 1990 plant o i
l l
I
\\,
Palo Verde pays
$125,000 fine imposed by NRC Omcials at the Palo Verde nuclear power plant have paid a $125,000 fine for falling to maintain an operable e:nergency lighting system.
The fine, imposed Oct.16 b Nuclear Regulatory Commission, y the is the.
runth paid since December 1983 by the Arizona Nuclear Power Project, a consor.
tium of seven Southwest utilities that owns the 89.3 billion plant 55 miles west ofPhoenix.
NRC omelais identified problems with the plant's emergency lighting system during inspections of the plant's three reactors between January and August.
In a letter to the NRC, William Conway, executive vice president of Arizona Public Service Co., said APS officiala decided not to contest the fine.
APS, which owns 29.1 percent of Palo Verde, operates the plant on a day today l
basta.
Conway said extensive corrective &c.
tions have been implemented that "dem.
onstrate APS' recognition and acceptance of its responsibility to assure that emer-gency'llghting meets tholpplicable NRC requirements and APS' commitments."
Greg Cook, spokesman for the NRC's Region V omee in Walnut Creek, Calif...
conf.rmed that the problems identified by NRC inspecten have been corrected, but a l
stiff fine was imposed because problems were not dealt with in a tirnely fashion.
Despite repeated warnings, NRC om-cials said, violations continued for several years after federal Inspectors identified them in 1984. They gained added signifi.
cance in March 1989 when emergency lighting at Palo Verde's Unit 3 failed to operate, hampering efforts of workers to activste a set of steam. relief safety. valves after the unit was shut down.
PHOENIX CAZETTE November 17. 1990
_a--
a i
Ep to 130 jobs in jeopardy ~ y"@6~g;;lg6 n
g y[g~c-%
in Palo Verde restructuring q
C'g Conway said sie job cuts are needed beesuse t!c
-> j By David Schwartz plant is top heavy is sone aress stuf fuis too few N ^"2*" "*
workers ira cancrs. It is a cas of not fisving people q-c About 130 moikers at tbc Palo Verde Nticlear
- i.'
r Ge= crating Station may lose their jobs as gott of a in ole right slots, be saki.
In fact, saakg ;bos filed with the federal
- f'
!.7 scstructuring plan, csecuthts said Monday.
Nurbar Regulatory C&bmissitz: in Walact Ocet.
c Plant operasons said a!Tecsed workers have until Dec. 28 to accept a spcesal severance plan or find Otlif., est) for Palo Verde to add 50 peutions by the Q
..-g end of 199f.
amother job al the plant, A pact spolcsman said some of the week being The Palo Verde Nuclear Generainig Station serves 2 moori customers ivi Arsrona ed another 2 era The facihiy west of Phoenis is operated and donc by felttime emplarecs will be cenuraesed otst.
Ion in California, New IAexico aod Texas.
surtially owned by Arirona Public Sesvice Co.
Diil Conway, Palo Vcide's top cucutive and as The restructming piam stems from nearly a APS caccutive sicc president, said be espects that yearlong kd at sf-fhg at the noclear plaat. It is In additirne to (Wi-tinue e orloym. Palo Verde about half a the affeesed employees ui!I be ahic to separate frein a restrecturirig at APS sha4 s2w I,125 cucatives have a mcmacal ibat they w:II edace jobs slashed, with 675 people bcirg laid off.
it.cw contractors by twti-thiids by Decenita 1991.
fod other posisior.s as the plant.
Sts h g at Paio Verde was etandned by "I don't believe the 130 is indicatim of the emsultans Tim Martiti d ilcamdme, Va, early this Al us 500 cetraoors are there utnv.
namhcr of people w1m will t.c cut ofjobs" Onteay 3w. Mntia sakt l'a!o Verde :enerany was 5:afTed sad ancabri 2 milion in C,liftwaia. Nor Meu:e Palo Verde wires 2 millions cmtamers in An arcuna said. " People are going to find a corn;urable job.**
pauperly when comgered with about 35 miclear There are 2,560 full-timie employws at the mid Texas esiptorcacice plant.
plaats matinimite.
ARI711NA EI:Pt1BLIC November 20, 1990 4
I
6/22.-2.W(e d2 %
d
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y 4
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Arizona Public Service Company 4
P O BOX $3999 e PHOENtX, ARIZONA B5072 3499 WP.UAM F. CONWAY 161-03373-WFC/WFQ sucu g g ypisw o August 1, 1990 Docket Nos. STN 50 528/529/530 Mr. John b. Martin Regional Administrator, Region V U. S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210
,9 cs Walnut Creek, CA 94596-5368
] ra rq
References:
1)
Letter from R. P. Zimmerman, NRC, to W. F. Conway, APS. rla E:Yj dated July 5, 1990;
Subject:
NRC Inspection of Palo U ]W-j,S 1
l Verde Units 1, 2 and 3.
Inspection Report Nos.
r3 50-528/90-25, 50-529/90-25 end 50-530/90-25.
ig C
w 2)
Letter to J. B. Martin, NRC, from W. F. Conway, APS,
-c hted July 20, 1990;
Subject:
Evaluation of the rire Protection System Equipment (161 03349).
Dear Mr. Martin-Subj ec t:
Palo Verde Nuclear Cenerating Station (PVNGS)
Units 1, 2 and 3 s
Re^ anse to NRC Inspection Report Nos. 50 528/90-25, Su. s > M-25 and 50-530/90 Safe Shutdown Emergency Light.ng File: 90 019-026;90-056 026 At the July 10, 1990 enforcement confe re n<. e concerning the results of NRC Inspection Report 90-25 on emergency lightir.g, APS requested an opportunity to furnish additional information in writing. The conference was scheduled for July 10, 1990, and the Inspection Report was received July 6,1990. Accordingly, APS expressed the need for additional time to adequately prepare for the meeting.
In addition, an independent consultant's review of the emergency lighting issues, which was scheduled to be received on July 20, 1990, was expected to provide information that would assist APS' response. The NRC consented to APS' request, a nd this document is submitted pursuant to that understanding. APS appreciates the Commission's consideration in this matter.
The cover letter transmitting Inspection Report 90-25 notes that emergency lighting has been the subject of communications between APS and the NRC for some time.'
Although this is true in a general sense, and is a matter of personal concern to me, the nature of the issues hat, shifted over time. The record shows that difierent, singular problems of emergency lighting have been discussed over
/
' Attachment I, to the Enclosure lists a chronology of recent inspection f
activities related to th+.s.nubject.
GH.s0 Ij~
~*=
ggy '
1 y
A l
Mr. John B. Martin 161-03373-WFC/WFQ
(
U.S. Nuclear Regulatory Commission August 1, 1990
(
Page 3 This is not to say that APS' performance in the general area of emergency lighting has been entirely satisfactory or that APS' diligence can be credited for whatever degree of success has been attained.
Emergency lighting has been characterired by several different types of problems (location, fr,ilure to meet PM schedules and a variety of equipment problems). Too often, in the past, the essential stimulus for insights to problems and corrective ac tion has been the result of the NRC's vigorous oversight and enforcement. Based on our review of those issues, and input from our independent consultant, we believe that timely additional corrective action is essential, and these measures are outlined in the Enclosure, gparent Violation 90-25-02:
(@
icg NCV The failure to fully apply the PVNGS Quality Assurance Program to emergency lighting can be traced to an ambiguity in the PVNGS UFSAR that resulted in inconsistent application of the QA criteria.
As noted in the JCO transmitted to the NRC in Reference 2, however, many of the QA requirements which should have been applied to emergency _lighti_ng have, as a practical _ matter been compensated.
f r_by,._othpLproce_dures_ and_ programs,.,
Nevertheless, certain_QA deficteneies m
9 remain.
Ngne of these_remaini,pg_def_Lciencies compromise _theAllity_to ayh_ieve and maintain safe shutdown in the event of a fire.
However, as detailed in the,
\\
Enclosure",Triumb^ei~6f" corre c t ive actions have been planned and taken.
In p a r t i cul a r, AES_harmup grad e d_th e _qu a l i t y c l a s s i f i c a t.i o n o f e.me r ge ncy_l i gh t i ng,
an activity which haibeen_iniMated but not fully imple_mAntud at the time of the inspection.
Annarent Violation 90-25-03:
( D.n3 cw w ) -_.
$5 i%% %, cm_7-APS believes that the discussion of this violation may_ reflect a misunderstan.dinP, of events and PVNCS_antions. The record, as reflected in the Enclosure to this letter, shows that a timelyJoylew_ofdhe_ Pre-Bre_ Strategies _ Manual _(PESM) _was.
cunducted_irLJ988 _apd that concerns._identif,ied_.in_that;. review were addressed as they were identified. Nevertheless, as part of its Design Basis Review, APS_
h'as indEaled~a cQTe~te review of the Spurious Actuation Studies which form the basis for the Spurious Actuation Evaluation section of the PFSM.
D 4 )q c V 7
&forent Viointion 90-25-04:
(D 3 c3%
_ cy 6,. I wugf A _a,.%m mar-When APS designed and purchased the Emergi-Lite outdoor emergency lights in 1989, it relied on the requirements of NRC Brar.h Technical Position (BTP) 9.5-1 and the National Electric Code which we believu were correctly interpreted.
Apparent Violation 90:25-04_is_ based.on_ajlifferent NRC_ interpretation.of BTP 9.5 1 and Code requirements.
APS was not aware of this NRC interpretation before Inspection 90-25.
Regardless of which interpretation is correct, howeve r, _AP5' is not satisflied.with the performance of these lights _in service,and is replacing 1
l
.it l
l Mr. John B. Martin 161-03373-WFC/WFQ U.S. Nuclear Regulatory Commission August 1, 1990 Page 4
( b eM e7c }
D*
'L NC Apparent Violation 90-25 05:
Finally, we urge recons _ideration of Apparent Violation 90-25 05.
Based upon a review of -NRC practice, it is clear that the NRC~does not normally ci m licensee for_ an a
under1ying violation 1i violatioA The basic principle is set _and alsp. for failure to report th_at forth in 10CFiC'Pa7F2 Eppendix C:
"A licensee will not normally be cited for a failure to report a condition or event unless the licensee was
.aetually aware of the condition or event which it failed to report".
While APS was aware of certain facts noted in the apparent violations, the characterization of those facts, as set forth in Inspection Report 90-25, and the conclusions reached by the NRC based on those facts cannot be fairly imputed to APS recroactively.
APS should not be cited for failing to understand that the emergency lighting could, at some point, be determined " unreliable" or that the QA program was not being applied to the extent APS, in good faith, thought it was applicable.
As to both matters, active communication was in progress between APS and the NRC, and there were good faith differences regarding the underlying facts and their interpretation. In these circumstances, it would not be consistent with NRC policy to' cite APS for both an underlying violation and the failure to report.
We think this reasoning is particularly applicable in the context of Technical Specification 6.9.3 which clearly requires an awareness on the part of the licensee, not only - of the facts, but also that. (1) a violation of the Fire Protection Program has occurred, and (2) the violation would adversely affect the ability to achieve and maintain safe shutdown of the plant in the event of 'a fire.
Indonendent Review As mentioned - above, in evaluating the status of PVNGS' emergency lighting system, APS commissioned an independent review of the NRC requirements, the status of APS implementation of these requirements, and related matters.
APS contracted with ABB Impell Corporation (Impell) to conduct this review.
The result of Impell's study is reflected in the Enclosure where relevant to the apparent violations and is summa ri::ed in Attachment C to the Enclosure.
Specific issues raised in response to ic'entified NRC concerns have also been evaluated by Impell and included as " Additional Discussion" the Enclosure.
in Attachment D to
1 n
l Mr. John B. Martin 161-03373-WFC/WFQ U.S. Nucicar Regulatory Commission August 1, 1990 Page 5 Although in this letter and Enclosure we have taken issue with certain factual matters and conclusions reached in the NRC Inspection Report, I wish to assure you tr.at lessons have been learned from this experience; APS has a firm grasp of the scope of problems involving emergency lighting; and corrective action will be prompt and dispositive.
Sincerely, JAW WFC/WFQ Enclosure cc:
Document Control Desk S. R. Peterson C. M. Trammell D. 11, Coe A.11. Cutterman A. C. Gehr
(
v44 e
---.,_k e-(
s ENCLOSURE F
1 2
RESPONSE TO NRC INSPECTION REPORT NO. 90-25
TABLE OF CONTENTS L
INTRODUCTION 1
lLL AREQUACY OF EMERGENCY LIC11 TING 3
II.A.1.
APPLICABLE RECULATORY REQUIREMENTS 3
II.A.2.
ANALYSIS OF LICllTING AVAIIABIMTY,
6 II.A.2.a.
Purpose 6
II.A.2,b.
Method of Evaluation 6
II.A.2.c.
Results.
8 II.A 3.
CORRECTIVE ACTIONS 9
II. A 4 CONCLUSION 10 II,B.
ADEOUACY OF OUALITY ASSURANCE PROGRAJ 11 II.B.1 APS RESPONSE 11 II.B.2.
CORRECTIVE ACTION.
14 II.B.3.
CONCLUSION 14 IT C.
PRE-FIRE STRATECIES MANUAL REVIEW AND UPDATE 15 II.C.1 RESPONSE TO INSPECTION REPORT CONCERNS 15 II.C.2 CONCLUSION 17 j
_I I. D.
ADllE](ENCE TO DESICN CODE REOUIFEMENTS 18 u
f II.D.l.
APPLICABLE RECULATORY REQUIREMENTS f
II.D.2.
DESIGNED FOR ACTUAL ENVIRONMENT.
20 II.D.3.
CORRECTIVE #CTION.
21 II.D,4.
CONCLUSION 22 II.E.
REPORTABILITY REOUIRECNTS FOR FIRE PROTECTION EOU"PMENT 23 II.E.1.
APS RESPONSE 23 ATTACHMENT A "CllRONOLOGY OF INSPECTION" ACTIVITIES, INSPECTION REPORTS 90-02 AND 90-25 ATTACllMENT B ADDITIONAL COMMENTS / CORRECTIONS ON INSPECTION REPORT 90-25 ATTACHMENT C
SUMMARY
OF INDEI ENDENT REVIEW OF EMERCENCY LICilTING Bi ABB IMPELL ATTACllMENT D DISCUSSION OF THE CONCERNS LISTED IN THE ENCLOSURE TO INSPECTION REPORT 90-25 Ai?ACHMENT E UPDATED LICHTING FAILURE
SUMMARY
AND AVAILABILITY EVALUATION
,l'"
l L.
IRTRODUCTION APS has reviewed NRC Inspection Report 90-25 on emergency lighting and the results of an independent study by~Es consultant, ABB Impell Corporation (Impell). APS is submitting this response to the Inspection Report to supplement the information furnished at the July 10, 1990 enforcement conference.
The issues raised in the Inspection Report are complex and have evolved and changed over time in the course of extensive discussions and meetings between APS and the NRC, a chronology of which is provided in Attachmen": A.
The NRC cover lecter transmitting Inspection Report 90 25 notes that emergency lighting has been the subj ect of communications between APS and the NRC for some time.
Although this is true in a very general sense, the nature of the problems identified has shifted over the years. While it is clear that all issues involving emergency lighting must be addressed promptly and dispositively, we do not view the his to ry_o f_thi s,
matter as artexampleafApersistentsingle_ problem _of a_ continuing For example, the 1986 Licensee Event Report (LER 86 059) nature.
addres' sed problems involving testing acceptance criteria which were corrected and have not recurred. The Enforcement Action in 1989 (' A E
89-88) involved the identification of plant areas requiring Appendix R emergency lighting and the inappropriate waivers of preventive maintenance tasks.
Emergency lights were added to the areas where needed, prior to restart of the Palo Verde Units following the March 3,
1989 event at Unit 3.
APS has also taken actions to assure preventive maintenance tasks are completed and not inappropriately waived. Obviously, NRC has been a major stimulus in connection with many of these corrective measures.
This document discusses each of the apparent violations, and includes attachments consisting of a chronology of inspection activities and meetings (Attachment A); a collection of comments and corrections on Inspection Report 90-25 (Actachment B); a summary of Impell's report on emergency lighting (Attachment C); an analysis by Impell of.APS' responses to NRC concerns and APS resolution of Impell recommendations (Attachment D): and an updated failure summary resulting~
from furtter research and evaluation (Attachment E).
With respect to the apparent violations, APS concludes in summary :
8 (1) Annarent Violation 90-25-01:
It is t to_ issue _a.
y ppropriate citation based upon, the alleged " u n ro l i ab ili ty " of_the_. cme rge nc %
lighting.
This is not the applicable regulatory standard and in_
any event, Is ~ based on a flawed statistical ana lys_is,
While m
improvements are needed t'6 sss~ ure continued adequacy of service, the
'A more complete analysis of the rationale for APS' position on each Apparent Violation will be found in Section II of this Enclosure.
1
.V L
lighting meets applicable regulatory requirementi.
Analysis shows that the FfgEtfii'has generally attained high availability factors, g
F although it is-acknowledged that vi orous NRC oversight and 6
enforcement have been a major factor in this regard.
(2) 6poarent Violation 90-75-02:
QA requi_r_ements_for_e_mergem l_ighting were incorrectly applied by APS owing in part to internal inconsist.ncies in the UPSAR.
NevertiIele s s, ot_her measures, as documented in APS' July 20, 1990 letter, haye_b_ gen _applici to e
emergency lighting since April 1990 such that most of the g requirements of BTP APCSB 9.5-1 have been satisfied.
_ fthough a f ew A
deficiencies remain, none compromise the ability to achieve and maintain safe shutdown in the event of a fire.
(3) Annarent Violation 90-25-03:
Certain misunderstandings are reflected in the Inspection Report concerning the annual update of the Pre-Fire Strategies Manual as documented in Section II.C.
In fact, the 1988 review of the manual did include operator actions.
(4) Annarent Violation 90-25-04: This apparent Yinlation_MDget_co a_jiU.f.erence_ between APS and NRC_in intypr_eting the requirements of Branch Technical Position (_BTPL 9J.l._and the National Electric y e.
Regar31ess of this interpretive difference, APS is replacing the lights in question _because the company is not satisfied with -
their maintainability and performance.
(5) Annarent Violation 90-25-05:
For reasons set forth in Section II.E., citing. APS for failing to report the identified Apparent Violations in Inspection Report 90-25 is inappropriate in light of the reporting criteria of Technical Specification 6.9.3; it is also inconsistent with NRC policy.
APS appreciates the opportunity to respond in writing to the Inspection Report. In some areas, issue is taken with - certain factual matters and conclusions.
We believe, however, that the information in this enclosure will facilitate a better mutual understanding of these matters, 2
)-
l
- IIsA, ADEOUACY OF EMERGENCY LIGHTING Summarv of NRC Findinc:
InspectionReport90-25,onpage3,describebanNRCconcernthat high-failure rate of installed emergency lights indicates the a
lighting units had not been properly designed or maintained. The report goes on to deceribe data APS previded to the NRC that indicated a number of light failures. On pages 4 and 5, the report presents some numerical percentages characterized, on page 8, as demonstrating a high failure rate. The Inspection Report concludes that " failure to provide reliable emergency lighting as required by the Facility Operating License to support safe shutdown in the event of a fire is considered to be on apparent violation of Facility Operating License Nos. NPF-41, NPF 51 and NPF 74."
Summary of APS Position:
With the limited exceptions discussed below, the emergency lights at PVNCS.have complied with applicable regulatory requirements, admittedly owing in significant part to corrective measures resulting from vigorous NRC oversight and enforcement.
The system used to assure emergency lighting when required depends on implementation of applicable design, procurement, installation, maintenance (both corrective and preventive),.cesting and corrective action programs, rather than assessments of equipment " reliability."
As with most equipment, neither reliability nor availability is normally quantified at PVNGS nor, to our knowledge, at other commercial nuclear power plants. APS has evaluated the availability of the Holophane, Exide and Emergi Lite systems.
The cyalpati.oxt shows that this equipment has generally _had_ligh_ availability _over t_hci_ pas t_y.c a rdhe re fo reJPSyks_that apparent--vicla ti on1035 -
01 be withdrawn.
~
Outline of' Presentation:
Section II, A.1 of this response explains regulatory requirements applicable to PVNGS emergency lighting and describes the PVNCS program for meeting regulatory requirements applicable to emergency 1
lighting.
Section II.A.2 indicates results of availability calculations applied to emergency lighting; and Sections II.A.3, and II.A.4 provide corrective actions and conclusions based on the preceding sections, l
l II.A.l.
APPLICABLE REGULATORY REQUIREMENTS i
Introduction
)
The adequacy of PVNCS emergency lighting is not assured by imposing l
quantified reliability standards, nor do NRC regulations establish such requirements.
Rather, adequacy is assured by implementing regulatory requirements for design, procurement, installation, maintenance (both corrective and preventive), testing and corrective action. These requirements are documented in PVNGS UFSAR Section 3
J l
9.$; PVNGS unit license conditions which cover the Fire Protection Program; and, in plant procedures which comprise parts of. the approved Fire Protection Program. APS has implemented many meas.ures in an eff ort to meet its commitments for emergency lighting and additional measures are being taken, several in responne to NRC observations and findings.
These measures are described in subsequent sections of this report.
They provide reasonable that emergency lighting performs its intended function, assurance a conclusion borne out by the availability analysis in section II.A.2.
Desinn. Procurement and Installation Renuirementa The APS program for equipment design, procur: ment and installation is established to assure that equipment installed in the plant meets design and functional requirements for the affected system (s).
Additionally, a design control program is established to ensure that: (1) equipment is readily maintainabic, and (2) that changes to the equipment design are made in a way which assures that system design and functional requirements are maintained.
APS' review of the Unit 3 March 3,1989 unusual event indicated the need to improve emergency lighting in selected areas. These changes added Emergi Lite units to address Appendix R requirements in certain areas, to enhance lighting in other areas, and to replace one Dual-Lite model identified as having undesirable failure frequencies.
Since that event, with minor exception (see letter dated Juno 19, 1990), the design, procurement and installation process for emergency lighting at PVNGS has been generally effective.
Maintenance and Testinc Reouiremental The purpose of the PVNGS Preventive Maintenance (PM) Program is to provide _ assurance that structures, systems and components are maintained in a condition to perform their design func tions and ensure adequate equipment reliability and availability. Preventive Maintenance at PVNGS encompasses periodic and planned maintenance activities, performed with the intent of maintaining equipment operable. The PM Program applies to emergency lighting.at PVNGS.
The PM Program fo emergency lighting also includes requirements for testing the lighting as part of the periodic PM activities.
PM testing of emergency lights prior to Jun:: 1990 provided for completion of various PM tasks prior to testing. The reasonableness of that approach is discussed further in this section and in response to Apparent Violation 90-25 02, in response to concerns expressed by the NRC during the inspection, APS is revising PM procedures to require that the E-hour discharge tests of Appendix R emergency lighting be tests of the "as found" condition.
While preventive maintenance cannot preclude all equipment malfunctions, frequent preventive maintenance can increase the likelihood of natisfactory performance during operation.
The preventive maintenance frequency for certain emergency lights in 4
..a selected areas has therefore been increz. sed following special tests
(
in March 1990 A pilot teating program is being developed to (l
determine whether additional improvements in preventive maintenance
~ '
tasks will further enhance lighting availability:
Corrective Action Reautrements System engineers provide technical support for plant activities that monitor the performance of emergency lights and other plant systems and equipment, and identify the need for corrective actions.
One important information source used by the engineers to assess emergency lighting performance is the Failure Data Trending (FDT) system.
FDT is a computer based summary of corrective and preventive maintenance data designed for use in identifying tcends in equipment failure.
When deficiencies in emergency lighting are identified, they are required to be documented and corrected. Changes in the applicable pracedures during the past year, previously described to the NRC, further increased the level of controls which assure that conditions adverse to the quality of emergency lighting are promptly corrected and that the root cause of significant adverse conditions is determined and actions are taken to prevent recurrence.
In the past, the backlog of corrective taintenance work may have contributed to lower than desired emergency lighting unit availability. Corrective action to address this problem required reduction of the backlog of work orders and work requests relating to' Fire Protection.
In addition, corrective action has included an interim action to raise the priority of work on the emergency lighting system.
The non-conformance reporj;.irg_proce ss has be en._ applied-to-the-sys tent since April-1990__.
Conclusion The activities invol_ving_ design,_procur:ement.
ins _tallation, maintenance (preventive _and_correctiveL,_tes ting _and_ corre_ctive_.
action, while not always_p_roperly;impleme_ntep have generally _been e
sufficient 1v effective in assuring that the emergency _ lighting, system was capable of performing its intended function.
Of ten, h'owever, thiThWE~requirerth~o~sElisilus of NRC observations and findings.
The results of these efforts, if effective, should be apparent in high availability factors.
The analysis performed to establish the effectiveness of these programs is described in the following section.
5
II.A.2.
ANALYSIS OF LICllTING AVAILABII,ITY f
II.A.2.a.
purpose Thin section describes a method of evaluating the availability of standby equipment and provides the resultu of such an evaluation for emergency lighting.
II,A.2.b.
Method of Evaluation An availability indicator was developed to quantif y the readiness of Emergi Lite, llolophane and Exido units t.o respond to situations in which they would be required. The availability indicator for each component (or group of components) is calculated for a specific period by dividing the number of available days by the number of days in the pe ri od. Thus, an availability value of one for a component means the component was always available. A value of zero means a component was never available. This method is basically the method employed by INpo to monitor the readiness of important safety systems to respond to off-normal events or accidents.
pages five and six of the Inspection lleport provide failure data on llolophane, Exide and Emergi Lite unit.s. The data is presented as a reliability indicator, e.g., ILpf _4 llolophane unit s_fbiled irt1988___
which made tho llolophane units appear 100h," unreliable". While the t@c ts_a re accurate, tiifs metlioil'5T por.t raying]a ilure s_i s misleading. Unrel_tabili t;y_is a useful measure for continuously.
f uncAioning_sys teng, where there is no possibility of repair. In that limited circumstance, the unreliability measure predicts the likelihood that a system will fail to fulfill its design basis requirement.
for standby _ systems, such as emergency lighting, diesel-generators, auxi l ia ry f oodwa tn r aisf~siire ty 11nj ec tTon7sys tiiinii'~Talie re rout _ine maintepange_an(Ltost.ing can enhance pd?To rm.anc e, the avaiHbili,ty measure is _ a more appropriate p red i.g t or_of_the_.ac tua l likelihood that the component /sys_ tem __wil l_ wo rk.
l'or example, consider an emergency light that is subjected to 20 demands during a year, and experiences 19 succour.,ful burns and one failure. The unavailability may be calculated to be 5%, while the unreliability, as that term is used in the Inspection Report, would Lc 100% (calculated using a failure of a single unit in the year). The actual likelihood that the light is not going to burn on demand is 5%, not 100%. ApS analyzed the emergency lighting failure data and presents the results below in terms of availability.
This analysis requires the development of known and estimated unavailable periods. Tha(known unavailable periodd are the times a
~
component is not available for servic6TalisiItAilieginning and ending times of the unavailability are known. ThcTieiltmsitail unavailablel
/
periodr, are the average times a component was in a fallid~Etli E
(^
before discovering a failure during preventive ne.intenance or demand. This time is estimated as one -halfitha_timea l nce the 6
A,4tu 7.ws o m L a y 4 3 w,ktm
.J ca w m
SMLw.p$' IIC a y>$d hk b CO%chtO djd$.(
$UUh-IQ f
.Q IK
\\
?
k l
component was host known not to be in the failedstatedThus,for L
~-
a component wh f'ch-fa i l e d'~a rMWr3s chsde ~Ee s~ t tee estimated
!]
a unavailable time is one half the time since the last successful noirr~ dis ~harge test for that component. A Iic5Ie recent preventive
(~
c maintenaEcTdste woul'cfbe used if a TeteEntnation could be made that the specific failure mode would have been detected at that time through maintenance. The unavailable times described earlier are l
only those stemming from events judged to be system failures. De analyj.is includes a light as having_ failed the 8-hour discharge _ test; if the light burned for less than 8-hours, or if it burned for the I.
8,WrJsYr6d bdE~dfd not meet the acceptance _crftedokfo[niinimu[
vol_tage_al_the end of the discharge _ testu The data used to determine unavailable periods is based on a review of available corrective and preventive maintenance work orders for the Holophane, Exide and Emergi-Lite units. This r_eXiew_.inv.olle51 ret,rieving a complete copy of each_ work _om.ler_and_rexteving_itao_.
de te rnilWE~what problem was corrected and its effect on the_
c_aQ_1Ttf 6flie_ equip 3ent to function. PM tasks were reviewed to
~
iden_tify new failures that may not have been reported previouslyj Examples of the results of this review are described in greater detail in Attachment E.
The availability evaluation extends from, p
June 29, 1989 to June 30; 1990. Although selection of this period y
is based on time and resource constraints a one year peribd3s_
bWlise d7o b's r e p r e s e n t a t iVi~o flfi ghii ng h,p e r f o rm a n_cleidu r in g_ the
~
~
inspection and its current condition.
Preconditioning, A question has been raised concerning the ef fect of preventive maintenance performed prior to the 8-hour functional tests.
It was postulated that this practice biased the results of the 8-hour testing, making the results appear better than they were.
A corollary question was raised concerning APS' ability to reconstruct the facts as to what work had been performed under Preventive Maintenance work orders because of a perceived lack of a requirement to document the work.
If a PM task required adding electrolyte to a battery when the level was low, it is correct that there may have been no way to determine from the records whether the level was low.
The technician would perform the step and sign it off as completed. If the step required recording the as-found level first, it would be recorded as required.
The salient point is that plant personnel are required to follow procedures, Lf additional work is performed under the PM work order, the work order must be amended to7eflect the addEional~
lj Ecope..
11_is then_possihle to determine whether additional work was pe ri c rme.d_by_ reviewing _t he_wo rk_o rde r.
~
The effect of this PM activity or " preconditioning" on the 8-hour tests varies for the different types of lights.
The Emergi-Lites haye._no_ possible_pdjus.tments and use dry _ cell batteries that do not require maintenance,.
Any preconditioning would minirElly~1mpacI fi the test.
7
'i, (
0 The llolophane and Exide batteries are in controlled _environmenta_ag
(
have a monthlyJi_ task that requires _ inspection _of the_ batteries and
- 1he_inYtri.pls,.
These tasks are_f tequent_qnough to ensure good condition of the _equipment wi_thout_ relying 76nL precondition.ing.
Specifically the llolophane PM allows cleaning of battery terminals and adjustment of float voltage before an 8-hour test.
The flgat, yoltage -is also adjusted >onthly,_ which_1.s_ mote _than suffic4nt-to.
stay within the specification.
The test procedures for Exide units were revised during the period of concern. The initial version did not require adjustments to the units prior. to discharge, but did require checking the charging current to verify the batteries were not subject to a high charging A high charging current is indicative of a problem and current.
would have to be corrected prior to the test.
This corrective maintenance would be documented in the PM work order, or as a
. separate Corrective Maintenance (CM) work order and would be
. identified as a failure.
The more recent version of the test provides for adjustment of the float voltage, but neither directs nor precludes an additional charging period prior to discharge.
We also note that the independent study by Impell indicatas that
"[t]here are no formal NRC requirements to perform 'as found' testing "
61though _precondi.tioning may_have_.affected test results, we believe, 2
{(
the results_are_nove rthelesu-representative _and lii the absence of t
k any_other_. analyses constitute. the _best_. evidence of the actual availability _of-.the lighting,.
'-~
-II.A.2.c.
Results The following table presents the results of the evaluation. The numbers. pr(vided are calculated average availabilities using the method described above.
UNIT 1 UNIT 2' UNIT 3 PIANT L
EMERGI-LITE 95%
88%
100%
94%
EXIDE 93%
40%
88%
74g l
HOLOPilANE 99%
94%
87%
93g i
The results fall into two ranges. The Emergi-Lites and llolopnanes are in the range of 93% availability, while the Exides show roughly 74% availability.
The lower _gvailability of the_Exisle_Uninterruptible Power Supplies (UPS) is due to a problem with the low voltage disconnect relay, L
setpoint_ which_ was___. discussed in._ previous H o'Eresppndence _and_,
j(
b L
corrective ac_tlon_is being_taken. A failure in the Unit 2 inverter O
L QDN-F01 that had not been reported previously, was discovered during
]@J this work order review. This failure resulted in the UPS tripping l
after 71/2 hours of service during a January 1990 test. Even though t
the availability was low in Unit 2, the UE would have provided 7, ll2 hqurs of light during most of the__unavailakle p e riod.a.
8
s Corrective action for this type of failure has been developed and the setpoints for_all'_1_ow voltage disconnect relays for_Edde_yP.Ss, will be lowered.
~
Functionally, the emergency diesel generators provide the control room lights with a redundant power source.
In most Appendix R events (loss of eftsite power and fire), the emergency diesels and the Exides may be assumed to be available to provide emergency lighting in the control room.
APS views the cause of the_ low ayall_ ability _ ort _the._ Unit _2_Exide UPS as being a failure to_takE g/
prompt _ correct,1yp J ction, Further information regarding the methodology of this analysis and related data is provided in Attachment E.
II.A.3.
CORRECTIVE ACTIONS APS is taking further action to ensure the continued availability of the Emergency Lighting System at pvt 1GS including:
Changes to design:
Emergi Lites will be replaced with lloloph:4ne Modular Power Stations (MPS) anu fluorescent fixtures. This modification is expected to be complete in August 1990 Holophane MPS's will be upgraded to larger capacity units by the end of Octohar 1990. See additional discussion in the APS response to Concern 10 in Attachment D.
The low voltage disconnect relay setpoint will be lowered on all Exide Uninterrupted Power Suppl, (UPS) by the end of August 1990, contingent upon material availability.
Changes to the-Test Program:
Preconditioning has been removed from the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge tests that are approved for use.
Capacity Discharge Tests will be written and implemented to measure battery capacity.
A review will be performed of the controls applied to emergency lighting to determine if additional controls are required. This review will be completed by December 31, 1990 Changes to the Preventive Maintenance Program-On selected lighting
- units, the quarterly creventive maintenar.cc (PM) interval will be changed to month?y in a pilot program to determine if further enhancements to
-(
availability result.
See Additional Dis :ussion for Concern
~(~
15 in Attachment D, which provides the results of Impell's independent review of emergency lighting.
i 9
e APS is -undertaking a major program to review and upgrade the quality of the Preventive Maintenance Program, and PM tasks.
As part of this effort, the basis for the content and frequency of PMs will be documented.
~ ~ -
l Changes to the Corrective Maintenance Program:
The priority of emergency lighting work orders has been raised to Priority 2 ' as an interim measure.
APS is currently evaluating this measure with the intent of focusing its efforts on the fire protection related work orders associated with systems / components which provide protection for safety-related areas or equipment.
Changes to Engineering Evaluations:
An on-site Fire Protection Engineering Group is being established within the new Site Technical Support organization to improve coordination and focus of fire protection engineering support.
Changes to Failure Data Trending (FDT) Program:
Changes to the content and frequency of the quarterly FDT reports end creation of a new Component Engineering Section to coordinate component performance monitoring are expected to improve the analysis of failure data informa tion and identify corrective actions.
II,A.4.
CONCLUSION The programs to ensure the availability of emergency lighting, while still subject to further improvement, have nevertheless proven their worth.
In effect, pregrams adopted by APS to comply with applicable regulatory requirements for design, procurement, installation, maintenance, testing, and corrective - action, have provided, with limited exceptions, emergency lighting that has a high degree of availability.
(
l x
10 l
l I I.__B ADEOUACY OF OUALITY ASSURANCE PROGRAM a
s 1.
Summary of NRC finding:
~ ~ ~
Prior to August 1989, the APS Operations Quality Assurance Critoria Manual (0QACM) had not been applied to all fire protection activities.
At the tiene of the inspection, emergency lighting components were classified as Quality Augmented but the QA requirements had not been fully implemented.
Consequently, the quality of design, procurement, installation and testing had not been verified.
The failure to properly implement the required QA Program appears to have contributed to inadequate corrective actions, inadequate testing and inadequate preventive maintenance intervals.
2.
Summary of APS Position:
Through an error during the tratisition from construction to operations, APS did not _ proper.ly_ classify _ the, Appendix _R_emergene,_
lighting system important-to-safety, In 1989,, APS_ reclassified ttye Appendix R emergency _ lighting as importantyto-safe,ty, and initiated
,_ t action to_make emergency ligli ilng subject to the QAG (Quality Augmented) Program. At the time of the inspection, APS had not_yet fully _ implemented the QAC program for, emergency _ lighting.
At the p{esent time, APS has identified and documented _known,QA Prpgram_
implemerit3tiori~'deficibncies ^for ernergency~ lighting and is pursuing iisp1Merita'tiorfof corrective actions to address those dificiencies.~
~
~
Where a pM iubl o~~ih tWr im~ c o rrsEt iie Te a su re s ~a re in place. ~~The s.
~
~
Inspection Report states that the classification error apparently contributed to three deficiencies, inadequate corrective actions, tes'ing and preventive maintenance intervals.
II.B.1 APS RESPONSE The NRC, during review of tha application for Operating Licenses, for PVNCS Units 1, 2 and 3, asked APS Question 260,10 to clarify an apparent inconsistency between FSAR Tables 17.2-1 and 3.2 1.
Table 17.21 indicated that the Fire Protection Quality Assurance Program is met as part of the Quality Assurance Program under 10CFR Part 50, Appendix B.
Table 3.2-1 indicated that the Quality Assurance Program did not apply to the Fire Protection systems.
In response to this question, APS amended Tabic 3.2-1, Section 17.2.2.2 and Table 17.2-1 and provided the following answer to NRC Question 260,10:
Amended table 17,2-1 indicates that the Quality Assurance progran during the operations phase complies with the Quality Assurance Program guidelines of Appendix A to (BTP) /PCSB 9.5-1.
Application of the Quality Assurance Program to Fire Protection Program activities is described in amended
(
pertinent requirements are applied to Fire Protection Program paragraph 17.2.2.2.
Amended table 3.2-1 Indicates that the activitia during the operations phase.
11
V
.r.
-Amended-Table 3,2 1 listed certain fire protection system cornponents, but did not include ernergency lighting components other than supports and hangers, in the design and construction phase, PVNGS used a classification system ' of "Q",
"R" and "S" to de fine the application of Quality Assurance Program requirements.
Items classified as "Q"
were considered safety related and required full application of the 10CFR50, Appendix B, QA program.
Class "R"
was used to identify those items considered innportant to reliability and certain quality ar orance controls were applicabic.
Class "S"
identified the rem dning iterns which were designed, procured and installed in accordance with industry practice.
The Emergency Lighting System was classified as quality class "S"
during the design and construction phase of Palo Verde.
During the transitton from construction to operations, the APS Operations Quality Assurance Program w.:s implemented and the quality classification system was modified to allow proper application of the QA program to operations phase activities.
Items previously classified as "Q" becarne "SR" and were subject to the full 1GCFR50, Appendix B, QA program. Items previously classified R" or "S" were reclassified Important-to Safety
("ITS")
only if a specific commitment was identified in Table 3.2-1 requiring application of the QA Program. When developing and implementing this methodology for reclassification, it was not recognized that other UFSAR commitments (e.g. Sections 9.5 and 17.2) should also be used when classitying plant components.
As a result, the emergency lighting system (except supports and hangers) was classified as non-quality related (NQR).
As operational experience increased, APS recognized the need for a more detailed classification for systems, structures and components that documented the classification basis.
In 1988, a new classification procedure was adopted and a proj ec t was initiated which provided for a detailed evaluation of major components in the PVNCS equipment -database. The component contribution to safety was defined and the basis for classifying the item as safety related
("Q"),
quality augmented (QAG). or.non-quality ' related (NQR) was established, The new classification process ultimately determined
.that the emergency lighting required to meet 10CFR50, Appendix R,-
should be classified QAG.
Corrective Action Report (CAR) 90-10, initiated on March 19, 1990, identifies deficiencies in the tirneliness of corrpleting procedure changes and other. implementing document changes associated. with classifying the system QAC, Tho. CAR also specifically cites failure to include maintenance and procurement activities associated with emergency lights under the QA program, Following completion of the corrective actions prescribed by this CAR and 1ssociated corrective action documents, the QA program will be applied to the Emergency Lighting System to the full extent required by ApS commitments.
12
c' l
At the enforcement conference on July 10, 1990. APS was asked to prepare a Justification for Continued Operation (JCO) addressing the application of the QA Program to fire protection equipment, ineluding Appendix R emergency lighting.
Th'e JCO, which was transmitted to the NRC by letter dated July. 20, 1990, compared the QA requirements of BTP APCSB 9.5.1, Appendix A with the administrative control procedures implemented by APS. As documented in the JCO, the review concluded that the controls provided for systems such as Appendix R emergency lighting, which had until recently been classified as NQR, had some of the elements of those for QAG equipment.
The APS Qualit:r Assurance organization had performed periodic audits and monitoring of NQR portions of the Fire Protection Program.
These audits nerally confirmed that the administrative controls were effective and properly executed.
Based on the results of the review, the.J C0 concluded that the fire-protection systems and equipment (including the Appendix R emergency lighting) are adequate to support continued safe operation of PVNGS.
The Impell independent review concluded, on the basis of the language of the PVNGS license conditicni, and UFSAR QA commitments,
'that emergency lights could be logically required to be classified QAG.
Impell recommends that the implementing procedure be revised to ensure QA commitments are being sa':isfied.
APS will implement these recommendations.
(See Attachment C, at pages 1 and 2.)
The Inspection Report states that the f ailure to properly implement the required QA Program appears to hava contributed to:
a)
Inadequate corrective actions APS recognizes that in hindsight it should have been more, e f fec tive in_i Q n t ifying_the_ne eCfo r_c o rre_c,t ive _ac tions;nd
._ timely in_their_implementatio.p.
Nevertheless, APS did more implement correctivo actions, including actions - to prevent recurrence of various failures of emergency lights. Examples of such actions are presented in Attachment B on page 1.
t b)
Inadequate testing The NRC concern regarding the adequacy of testing relates to l
the use of' preconditioning' prior to testing.
However, the testing of emergency lights was a part of the Preventive Maintenance Program, and not considered to be surveillance testing. Since it is not improper for testing to be included as _ a final step in a preventise maintanance task, U j.s, 4
W un_1_ikely_,.that_QA' review would have identified anyJroblem with
/
the use of preconditioning,.
However, proper. implementation h
l 7
of QA criteria governing tests / test control would have
- resulted in a formal test program for emergency lighting.
In any event, as shown in the response to Apparent Violation 90-25-01, the preconditionin u is unlikely__to_ have_ had a
significant effect on the overal:. test results.
13
l c
c)
Inadequate Preventive Maintenance intervals
(-
As discussed in response to Apparent Violation 90 25 01 the
,[
preventive maintenance intervals were - based on vendor
' f]-
recommendations, and have been largely demonstrated to be successful.
During_the_ inspection, based on_the_results of g
speqial_te s ts, APS did de c i de _to_ s ho r te n_the_ p reve n t ive j
maintenance latervals for the Emergi-Lite _ units u II.B.2.
CORRECTIVE ACTION As stated earlier, emergency lighting has been classified as QAG and the QA Program for the emergency lighting systems and equipment is in the process of being implemented as discussed in Reference 2.
Known deficiencies have been documented on appropriate corrective action documentation. Interim corrective actions, where necessary, are in place and resolutions are being tracked by QA.
Plant personnel have been made aware of the changed quality classification and the actions to be taken have been outlined in a letter from the Vice President-Nuclear Production to all plant personnel.
II.B.3.
CCNCLUSION The failure to fully apply IJS QA Program to emergency lighting can be traced to an ambiguity and inconsistency ir application of the PVNGS UFSAR when developing the quality classification for certain plant equipment. As described in our July 20, 1990, JCO, many of the QA requirements which would have otherwise been applied were in fact compensated for by other procedures and programs and none of the QA Program implementation inadequacies on emergency lighting compromised the ability of PVNCS to achieve and maintain safe shutdown in the event of a fire.
14
l II,C.
PRE-FIRE STRATEGIES MANUAL REVIEW AND UPDATE Summary of NRC findinn:
The Inspection Report states that, although a formal engineering review + of the Pre-Fire Strategies Manual (PFSM) was performed in 1988, this review only addressed fire fighting concerns, it concludes that APS' failure to perform an annual review of the Pre-Fire Strategies Manual is considered to be an apparent violation of Technical Specification 6,8.2 II.C.1 RESPONSE TO INSPECTION REPORT CONCERNS A careful review of Apparent Violation 90-25 03 indicates that there may be some misunderstanding as to the actions taken by APS to fulfill the requirement that the PVNGS PFSM be reviewed every 12-months, in 1988, as part of the resolution of a Corrective Action Report (CAR CE86-0203), APS performed a complete review of the PFSM and included the requirement for annual review of the manual in Procedure OlAC-0AP02.
Procedure 01AC-0AP02 requires review of the PFSM to assure that plant design changes and operating practice revisions made in the period since the previous annual review are captured in periodic revisions. Annual reviews are not required to encompass technical re-evaluation of the design basie.
There may also be some misun_derstanding concerning the scope of the PFSM review performed in\\l988'.-
That review was accomplished over the time period from aboUEFebruary tE April'1988.
Tliis was a not ]EsF]hi~fiHfQhtingico_ncern_s,l.
comple_te_rjEicw of"'the PFSM, with participacion~ff5iirthe onsite Fire Department personnel and the offsite Nuclear Engineering Department (NED).
__A s _part o f _ the, review, and contraryJo the statement in_ Inspection _Repor_c_90-25_,
iPage _11), NED did re51 ewZths'if fe c t_o L d e s i gn_ change s _o n_t h e_
Spur _ious Actuation Evaluation Concerns section_of.the PFS11-Du-ingthJi9hannualreview,whichwasconductedduring_a_ period,,
e from_Myg July 1989, potential questions were identified with thTsfrginal Spurious Actuation Studies which are the respect to basis for the Spurious Actuation Evaluation Concerns section of the
- PFSM, As a result, the annual update and resolution of these questions were included as a task under the Fire Protection Design Basis Review (DBR).
When the DBR task is completed, the results will be incorporated in a
future revision of the PFSM.
Discrepancies that impact operator actions are corrected as they are -
identified.
In summary, (1) a procedure requirement for annual reviews was implemented in 1988; (2) these annual reviews are updates and do not require technical re-evaluation of the design basis of the PFSM and; (3) as a result of questions raised in 1989, such a re-evaluation task is now underway as a part of the Design Basis Review Program.
(t 15
=
The Inspection Report discusses several specific concerns identified by APS regarding the PFSM (paragraph nos, 2 and 3 on page 11),
As the following discussion demonstrates, those concerns were self,,
identified by APS and appppriate actions were' takqn_19_torrect thra.
'to the extent h_at. the Inspection Report implies from these concerns that the 1988 review of the PFSM was of inadequate scope, it is mistaken.
The concerns do no t_a tin _ f rom _any_de s i gn or operational change _m_a_de_ prior to the 198.8_ review._ Rather.__they_are based on the questions identified concerning the original Sputious Actuation SEdfeT,7h~1ch are now b~eTri]Jandled_undet_the___DBR.
S The concern listed on page 11, paragraph number 2, of the Inspection Report is associated with the accessibility to perform manual operator actions as described in the PFSM for fire zones 42B and 47A. This item was ideact.fied by_APS.._on_12/J9L89.,, as ~i result of re sea rc h _(un re l a t ed_to_ annua l_ revi ews ) being performed to support the Fire Team Advisor training program. The PFSM was found to c on ta i n_a n_ e r ro r_ in_ tha t__ an.. ope ra.t o r action was_ required _
be; to performed within the fire zone fire i s._ pos tul ated,
This action was included in the_in which the orihinal,iSpurious _Ac,tua and thyrefpre would not, have lycen_identi,ficd during a nor, tion Study mal annual revfew_of_ plant _ changes _which_could_ affcct_the_ PFSM, A Quality Deficiency Report (QDR 89 0125) was initiated on 12/19/89.
Corrective Action for this item was to revise the PFSM and to identify operator actions remote from the postulated fire.
Subsequently, a revision to the PFSM was issued on 2/23/90 (approximately 60 days after initiation).
As interim corrective action, prior to PFSM revision, the onsite Shift Technical Advisor was advised of the concern by phone and also through a. Problem Resolution Sheet (PRS).
The PRS was issued by Engineering which provided the corrected actions for fire zones 47A and 42B to PVNGS Unit Operations.
The following chronology, which was requested during the Enforcement Conference, provides completion dates for actions associated with resolving QDR 89-0125:
12/19/89 Problem initially identified by Corporate Fire Protection Engineer.
Fire Department-Supervisor notified by meeting and NED fire protection engineer notified by phone.
12/20/89 (1)
STA group contacted by phone to advise of problem.
(2)
PRS (PRS No.
573) issued by NED Mechanical Engineering with alternate compensatory measures identified in the immediate corrective action section.
(3)
QDR-0125 issued by Site Fire Department to track resolution of deficiency.
16
/
l l
i (4)
Fire impairments issued by Site Fire Department against pre fire strategies manual for aff mted fire zones in all units. Impairment for'r, require Shift Supervisor or Assistant Shift
>crvisor approval. Additional fire hose station t pability provided for each zone as compensatory measure.
12/28/89 Letter issued from NED to Emergency Planning and Fire Protection Department which provided corrections to the pre-fire strategies manual.
Corrections requested were consistent with initial corrective action.
Copy provided to each plant manager.
02/23/90 Revision to fire zones 42B and 47A issued to revise manuals.
The second concern identified on page 11 of the Inspection Report (paragraph number 3) relates to fourteen (14)_other_APS._ identified _
, concerns with respect to accessibility to perform operator actions.
TIAs~cioncerns were identified by the Nuclear Engineering Department durirg the course of the Design Basis Review (DBR) review of the Spurious Actuation Studies and documented in QDR 90-0175.
As mentioned previously, this review was, initiated by_APS_in connection -
with the 1989 annual PFSM update, not as a result of this, NRC, insp.ectionUIt~ should~ be ~ kept'"in mind ' that~these concerns arose from questions concerning the original studies and do not reflec t on the adequacy of the required annual review; that is, it does not suggest that the review failed to capture design and operational changes issued between the original studies since the 1988 annual review.
The concern will be resolved as part of the review and update of the Spurious Actuation Studies.
Another matter mentioned in the Inspection Report (second paragraph of Section C,
page 10) relates to "an apparent inc onsis tency
between the PFSM and the Spurious Actuation Study for Fire Zones 42E and 47A.
APS has reviewed the Spu'eious Actuation Studies and the PFSM for Fire Zones 42B and 47A and found that, notwithstanding differences in the wording, the meaning and intent are the same.
The Impell independent review concluded that APS was responsive to the NRC Concern on this matter.
II.C.2.
CONCLUSION
,A_t the,_ti_me of_theJRC_ inspection, APS was_perf orming_ annual _ reviews and_ updates _of_the_PFSM_in accordance_with Administrative _Proceduta OlAC-0AP02 and _therefore in_c omplianc e _wi th._.Te chnical was Specification _6,8 2 The discrepancies discussed in the Inspection 1
Report regarding the Spurious Actuation Evaluation Concqr_ns Section of the PFSM, were Mentified by APS and appropriate corrective ac.tions were_taken.
The actions to address the remaining PFSM daficiencies mentioned above are documented on CAR 90-014, which will track these issues to resolution.
)
l 17
h AQllE1ENCE TO DESIGN CODE REQUIEJEENIS Summary of NRC finding;
~ ~~
Section 4 of the Inspection Report (page 11) states that Appendix R Emergi-Lite units installed in an outdoor, damp location were not tested and approved for use in outdoor wet or damp locations as required by Article 410 4 of NFPA 70 1975 and the facility operating licenses.
Appendix A of the Inspection Report implies that PVNCS license conditions, interpreted in conjunction with NFPA 70-1975, require that emergency lighting used outdoors be tested by a nationally recognized testing laboratory, The Inspection Report concludes that " Failure to provide eniergency lighting of approved design for outdoor use to support safe shutdown is considered to be an apparent violation of Facility Operating License Nos. NPF-41, NPF 51 and NPF-74."
Summary of APS Position:
The Emergi-Lito units were designed, purchased and installed in accordance with NFPA 70-1975.
NFPA 70-1975 does not, by Article 410 4 or any other article, require that emergency lighting be tested by a nationally recognized testing laboratory. NRQ_1TLR. A -
1,_,yh e n read in conjunction with NFPA 70-1975 and other PVNGS Ticensing_yoiidifisiie3ts,
does not indicate thTt
~
~ 'e's tingilifld_
t natipna11y, recognized testing laboratory _is required, or_ recommended, Q u megggucy lighting. The selection of the Emergi Lito units was g.w), based on careful consi,deration of the environmental conditions, the I
applicable code and regulatory requirements and the characteristics h@#
of the lighting units. Af ter receipt of the Emergi-Lite units, APS 4 wws nb,\\;7 - decided to replace them with a centralized ir,verter sy dt'.
c gg
.o e
concerns aboutgessive maintenance that would be required over che g
long term.
The replace dnE~is expected to be completed by the end of August 1990.
II.D.l.
APPLICABLE REGULATORY REQUIREt1ENTS The sections of the UFSAR which provide design criteria for the emergency li hting system required by Appendix R are 61ven below:
S Section 9.5.1.1.1.R. " Safety Design Basis Eighteen"
" Emergency lighting systems shall be provided in accordance with the guidance provided in NRC Branch Technical Position APCSB 9.5-1 (revised February 2,1977) and 10CFR50, Appendix R, Section III.J (issued September 1, 1982), in areas needed for operation of safe shutdown equipment and in access and egress routes thereto."
18
l 0
Section 9.5.3.1.3
" Codes & Standards"
" Design and Installation of the plant lighting systems use guidance provided by the National Electrical Code (NFPA No.
70 1975/ ANSI Cl 75) and the llandbook of the Illuminating Engineering Society."
Thus, APS chose to use industry guidance (the NEC and the IES llandbook) to design and install the emergency lighting system.
This is consiatent with the NRC staff guidance in NUREC-0800, Section 9.5.3., which states that emergency lighting systems are acceptabic if they conform to the IES 11andbook as related to system design and illumination levels "as recommended for industrial facilities."
The NEC provides guidance to ensure the " practical safeguarding of persons and property from hazards arising from the use of electricity" (NEC 1975, article 90-1.(a)).
The guidance for emergency lighting systems is found in Article 700 3 of the NEC, which requires that the equipment be approved by stating that "all equipment shall be approved for use on emergency systems." Article 410 4 of the NEC provides guidance as to wet location applications by stating that " fixtures installed in wet or damp locations shall be approved for the purpose and shall be so constructed or installed that water cannot enter or accumulate in wireways, lampholders or other electrical parts." Article 100 of the NEC defines " approved for the purpose" as " approved for a specific purpose, environment, or application described in a particular Code requirement." Article 100 defines " approved" as " acceptable to the authority having jurisdiction."
In applying the NEC, APS looked to the NRC as the
" authority having jurisdiction" _over PVNCS 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> emergency lighting. The NRC guidance in Branch Technical Position APCSB 9.5-1 concerning acceptable emergency lighting provides considerable latitudo in tne design of emergency lighting.
It-provides:
1.
Section C 4.e.
" Suitable fixed and portable emergency lighting... should be provided..."
2.
Section C.4.e.(1) - " Fixed self-contained lighting...
with individual 8-hour minimum battery power supplies should be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas."
3.
Section C 4.c. (2) - Suitable scaled beam battery powered-l L
hand lights should be provided for emergency use by the fir 2 brigade and other operations perconnel required to l
achieve safe plant shutdown. "
4.
Section C.2.e.(1)-
" Successful firefighting requires testing and maintenar.cc of...
There are no other requirements for testing or labeling, given in the BTP for emergency 1ighting.
19 l
l l
d l
l Section 4 of BTP 9.51 states "For the user's convenience, some of
(
the terms related to fire protection are presented below with their definitions as used_in this BTP."
The BTP defines " approved" as:
" tested and accepted for a specific purpose or application by a nationally recognized testing laboratory."
llowever, the sections describing the requirements for the emergency lighting system do not use the term " approved", but rather, that term is used in other sections of the BTP. For example, Section C5.b.(1) requires that sectional control valves be " approved." By express use of the term " approved" in some sections of BTP 9.5-1 and conspicuous omission of the term in the section for emergency.
lighting, the BTP 9.5-1 indicates clearly that testing for a specific purpose by a nationally recognized testing laboratory is required or recommended for emergency lighting, not APS applied the UFSAR commitments, the BTP guidance, and the NEC in providing suitable Appendix R emergency lighting.
The NEC also requires that units used in wet environments be marked
" suitable for wet locations" (NEC 1975, article 410 4 (a)).
The Emergi-lite Units are marked with an industrial code that signifies I,s-7 that the unit _ vill _ perform _in_a wet _ environment. The lighting _ units are _ marked _ witit_the_ NEMA.__4X_ coda Eme rgency_ light _i ng un Es manufactured to NEMA 4X standards are su.i t_abl e_f o r_ use_in_ye t_and_
outdoor focations, f!5H,i.ng the units with the NEMA 4X code informs personnphKt'he_ units _are.."sultable_for_ wet locations."
ThTs marking G sufficient to_me e t._the_ int e nt_o fLN FPA 70T1975~,~ait ib l e slQ-X(a),.
The Impell independent study concluded that the Emergi-Lite units are suitable for use in outdoor " wet" locations.
Impell's review also found no requirement to perform laboratory testing of emergency lighting.
II.D.2.
DESIGNED FOR ACTUAL ENVIRONMENT At the enforcement conference, APS was asked to describe the process used to design, purchase and install the Emergi-Lite units.
Envfronmental Conditions The Emergi-Lite Units are located outdoors in the Turbine Building bree cway and on the outside wall of the MSSS.
For the MSSS application, the lamp heads are located remotely from the battery / charger units inside the MSSS to illuminate the ADV's.
The Emergi-Lite units were procured ba. sed on a maximum outdoor temperature per UFSAR Table 3E-1. The. temperature specified in the UFSAR for outdoor use is 116 degrees F.
For conservatism, the ba-sis for acceptance of the Emergi-Lite units was 120 degrees F. The units also had to be of an outdoor weather resistant design.
20
Determlnnt en of Suitable Vendt.
8 f
Addition of Omergency lighting was among the Units' restart items f ollowl.ng the March 1989 event. An aggressive schedule was. assigned to $nstall suitabic 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> lighting prior to restart of the Units.
Due to these schedule restraints. APS initially ruled out complex designs, to provido the required additional lighting. It van determined that self contained battery units that could be fed by th, available local essential power were the only fixtures that could meet our schedule and the appilcable technical requirements.
APS contacted tu, ant' ors which were recommended from industry con-tacts. Emergi Lito was the only vendor that could_ provide a light wi dt.a n_8 hoiiiCdg ra t i onE120 'de g r.c e sTF3mlif fn t _ fo r..ou tdo o rm us s ity a NEMA 4)Leab,ine,0. Tl e.
i grC -Lite units used high temperature batteries and ternperatut
~pensared chargers,luitable'~for Thiri^
which provided APS oi.
iidQijToifaf~c nfldelicItr.x Ufe~ unl~t T were'~
appKeat.ign.
At.tho_ time-the Emergi.-Lite Unes..wcre_ procured
,c o
u k sco;,e._o f_the t
N" UL 924_ sta.ndard_,for_tes ting _and..J is t_.inD emergency light integral A"
~
Units _did_ not,inc1ude_ outdoor.jpplicabill ty' __]!cncei_UU' approved integrol, lighting y Qts _could_not be obtained.for_ outdoor use.
On 2/27/90, UL informed APS that t. hey had now started listing outdoor integral emergency lighting units, lloweve r, UL 924 had not been revived. The outdoor listin6 is done only on specific request by a vendor.
When initially received in 1989, to confirm the vendor's claim of 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> duration at 120 degrect. F ambient, APS placad an Fmergi Lite unit in an o,en at 120 degrees F and then allowed the unit to d 4.e c he rge. Although this test was not formally documented, the discharge time exceeded the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement.
Banis fn_ Ren1ncement of Fmergi.-Li te Un,1.im After receipt of the Emergi Lite.unita, it was evident that the quality t,f the workmanship of the units was less than desirabic.
Maaufacturing problems, noticed at the time of roccipt, required initial Installation repair work to return the units to their as designed state. To avoid excessive maintenance during xtaded long term-service, a picnt design change was initiated to
.r.
see the-Emergi Lite units with a centralized inverter system.
II.D.3.
CORRECTIVE ACTION The PVriCS Emergi-Lite units are bcIng replaced with a centralized system tot which inverters will be located in a mild environment in the Auxiliary Duilding, and which will have hf gh temperature outdoor l
fluorescent fixtures located along the breezeway and sithin the
- MSSS, I
All replacements are expected to be completed by August 1990.
i 1
21 l
r y
g-
.aw
-v m
U--+-aev-e-
e
'T Tur.
si II.D.4.
CONCLUSION APS reasonably deterrnined that testing or listinc by an independent laboratory for emergency lighting was not reqtitred by the National Electric Code, the UFSAR, or BTP 9.5 1.
APS procured, tested and installed suitable eine rgency lights for the MSSS and Turbine Building Breezeway envirotunental conditions. To avoid significant reaintenance expense, APS is replacing the Ernergi Lite units with a centralized inverter sys tern, which will also racet the design requirements.
22
e.'
1 1
IR I@lQETABILITY REQUIITMJliTS FOR FIRE _ PR07f&IION FOUIPMENT Spynry of NRC fitgling:
Apparent Violation 90 25 05 identifies five items as reportable under Technical Specification 6.9.3; the items identified as Apparent Violatlons 90 25 01, 02 and 03 and two occasions in which inverter EQBN004 was out of service.
II.E.1.
ApS RESP 0NSE ApS did not file reports on these items. ApS has reported emergency lighting problems in the past (LERs 86 59 and 89 12) but did not, and does not believe the matter cited in this apparent violation are reportable or that it should be cited with a vio?stion for failing to report them.
ApS has reviewed the NRC policy and practice regarding the citing of a licensee simultaneously for violation of a technical requirement and for failure to report the same violation.
Our review concludes that licenseen are nor normally cited for failure to report i violation unless the licensee had been aware of the underlying technical violation or clearly sheuld have been aware of the violation.'
The importance of the state of the licensee's water ess as a factor in determining whether it is appropriate to issac a citation for both the underlyint violation and the failure to report takes on special significance in the light of the lant;uage of Technical Specification 6.9.3.
Awarenens, in the context of Technical Specification 6.9.3 requires that the licensee knew or c1carly should have known that: (1) the condition cons.tituted a violation of the Fire Protection program (i.e., the fire protection provisions of the 1:
.), and (2) the condition would adversely affect the ability te achieve and maintain safe shutdown in the event of a fire.
Unless this two pronged test is met tbc reportability requirements of Technica) Specification 6.9.3 are not triggered.
These principles, as applied to the Apparent Violaticns in the Inspection Report 90 25, make it clear that none are reportable.
2This is the result one would expect in light of NRC enforcement policy as expressed in loCFR Part 2, Appendix C:
"A licensee will not noriaally be cited for a failure to report a condition or event unicas the licensee was actually aware of the condition or event which it failed to repert." (emphasis added) 23
s,'
l In the following discussion we assume, for purposes of argument that the apparent violations are valid and address only their report ability.
1.
Apparent Violation 40 25_Qh The facts underlying the viointion were developed during the inspection; moreover, the conclusion drawn from the data that the lights were unreliable" has been the subj ect of continuing discussion and disagreement between APS and the NRC.
Under the ciretastances, APS cannot be charged with prior knowledge (" awareness") of either the operative facts which underlie the apparent violation or the ultimate conclusion which is the thrust of the violation (i.e. the lights were " unreliable').
2.
Aponrent Viointion 90 25 07-APS believed in good faith, if however wrong, that applicable QA requirernents were being inct.
APS had not determined that a violation existed, it may be argued that APS should have been aware of the violation, but even if this were so, the violation is not one which meets the second prong of the test of reportability under the technical specifications (i.e. a condition that would edversely affect the ability to achieve or maintain safe shut:10wn).
The potential availability of diesel backed essential lighting and required availability of portable hand held lights would have been sufficient for the limited number of operator actions necessary to achieve and maintain safe shutdown in the event of any postulated fire.
3.
Annarent Violacion 90-25 03:
Even if one assumes that the deficiencies noted in the Inspection Report establish a violation of the requirement for annual review of the Pre-Fire Strategies Manual (PFSM), the violation entails _only an.
administrative requirement.
With respect to the specific deficiencies in the PFSM identified by APS, even in the period before they were corrected, these deficiencies would not have adversely affected safe shutdown because the PFSM is only used by operators as an aid.
Required operator actions are sufficiently described in existing evmf rom based emergency operating procedures' and abnormal operating procedures, which provide adequate operator _ guidance for the limited number of actions which may have been inadequately treated in the PFSM.
Therefore, the ability to achieve and maintain safe shutdown would not have been adversely affected.
Again, the second prong of the reportability test under Section 6.9.3 of tt.c Technical Specifications is not met.
24 h
,.a-gr-
b; 4.
01her Reportability Items:
Finally, wit' respect to the two examples of inverter EQBN004
(
being out os srvice (EER 88-QB 003) and NOV 8') 08 V01), the facts do nc.'.upport the conclusion that the condition would have adversely affected the ability to achieve and maintain safe shutdown.
Emergency lighting failures of the type involved in the failure of inverter EQBN004 would not be regarded as a condition that would " adversely affect the ability to achieve and maintain shutdown". Available portable lighting would have been adequate to perform the safe shutdown related activities in the affected area in the event of a fire.
A further clarification of the facts associated with these items is included in Attechment B on pages 6 and 7.
25
t' t
ATTACHMENT A
(
CliRO.'10 LOGY OF INSPECTION ACTIVITIES INSPECTION REPORTS 90-02 AllD 90-25 l
l l
y a
i 1
Cl!RONOLOGY OF INSPECTION AC'l VITIES
({
INSPECTION REPORTS 90-02 and 90-H 01/08-4/12/90 Routino inspection activities conducted for Inspection Report Nos. 50 528/90 02, 50-529/90-02 and 50 530/90 02, 01/26/90 NRC/APS Exit Meeting PVNCS (Inspection 90 02).
02/09/90 NRC/APS Exit Meeting - PVNCS (Inspection 90 02).
02/23/90 NRC/APS Teleconference.
03/23/90 NRC/APS Exit Meeting - PVNCS (Inspection 90 02).
03/30/90 NRC/APS Meetirg Region V (Inspection 90 02).
04/16/90 NRC/APS Teleconference.
04/24/90 Inspection Report Nos. 50 528/90 02, 50 529/90 02 and 50-530/90 02 issuance.
05/16/90 NRC/APS Meeting Phoenix (Inspection 90 25).
k 05/17/90 NRC/APS Exit Meeting Phoenix (Inspection 90 25).
06/14/90 NRC/APS Meeting PVNCS (Inspection 90 25).
06/15/90 NRC/APS Exit Meetin3 Phoenix (Inspection 90 25).
06/19/90 APS submittal to NRC; Emergency. Lighting (161 03288).
06/23/90
(
APS submittal to NRC; Emergency Lighting Exide Power Supplies (161 03294).
06/24/90 APS submittal to NRC; Emergency Lighting Exide Power Supplies (161-03295).
06/2.9/90 APS submittal to NRC; E.nergency Lighting - Failure Data Update (161 03305).
07/05/90 Inspection Report Nos. 50 528/90 25, 50 529/90 25 and 50 530/90 25 issuance.
07/10/90 NRC/APS Enforcement Conference - Regior. V.
- (m 1
vr s'
ATTACHMENT B ADDITIONAL COMMF.NT5/ CORRECT 10NS ON INSPECTION REPORT 90-25
.,r ADDITIONAL COMMENTS / CORRECTIONS k
ON INSPECTION REPORT 90-25 p
we--
In addition to the cominents and corrections in the body of the report, the following additional rt 'tters may require revision of the Inspection Report.
Paragraph 3.B.1.a (nnte 7)
This paragraph states tlpat APS did not appropriately evaluate the nwserous, documented ernergency lighting system failures and did not troplernent appropriate corrective action to preclude recurrence of those failures, Examples of Ernergency Lightin6 System failures that have been evaluated, and where corrective actions have been taken include:
(1)
Replacement of Exide battery banks in Unit 1 (1988) and one battery bank in Unit 3 (1987).
(2)
Replacement of the Dual Lite 4 X 7 fixtures due to their high failure rate.
Every failure in the turbine building of a Dual Lite-fixture
-referenced in the June 29, 1990, letter occurred on this type of light (1989).
(3)
Modification of the relamping PM tasks to ensure that correct lamps are installed. (January 1989) - SLO {etus -)tjew g )qgc (4)
Acceleration of the plan to replace the Emergi Lites alter testing in March 1990.
\\l i
f c M, S % m
< jw % ( cP)9 jw l p
(5)
Lowering the Low Voltage-Disconnect setpoint in Exide UPSs to prevent early disconnect of the batteries.
The design is complete.
Implementation is scheduled for August 1990, l
(6)
Increase the capacity of the llolophane modular power station units in response to concerns regarding temperature capacity.
These actions were a combination of self initiated corrective actions, and corrective actions resulting ! rom NRC questions and activities, Section 3.B.1.C (nfre r)
Paranrnnh 2 (ogge 8)
NRC Stater _ejn; At.the time of the inspection, APS preventive maintenance schedules were based on an opetating teroperature of 77 degrees F instead of actual field conditions, 1
d l
Comment Although the existing PM frequency was based on 77 degrees F., at the time of the inspection, the FDT program did not indicate a need to increase the PM frequency; It is true that higher ambient tempetatures will increase water consumption due to higher evaporation and charging rates, but evidence of a detrirnental rate of electrolyte loss (i.e., faster than the quarterly PM could replace it) would have manifested itself by high failure rates in lights located in the varinest locations of PVNGS.
There was no such manifestation.
Paragrnnh 3 (pnge 8)
NRC Statement The discussion it. the paragraph is centered on the availability of empirical data fron battery vendors to datermine the adequacy of batteries in high temperature environments. The incpector determined that, lacking this information, there was not an adequate basis to determine a preventive acintenance (PM) frequency to ensure reliability. The inspector concluded that APS failed to recogni.:e the need to increase PM frequency since field conditions were different tnan vendor assumptions.
Comment The vendor published battery curves are based on a combination of empirical data and theory, Altnough no empirical data could be obtained from the vendors to support the curves, APS has a high degree of confidence in these curves based on that fact that:
The curves are consistent for the same type of battery amon6 different vendors.
The industry general.ly uses vendor' curves for si::ing class 1E batteries.
The curves follow the. basic theory for batteries.
Based on the combination of vendor provided curves and data from the FDT program, the PM frequency has been set and determined to be adequate in all cases except for the Emergi-Lites.
Section 3.!L 2 (page 8)
This Section of the inspection Report relates NRC concerns based on inspector observations. While many of the observations are factual, the significance of those observations is subject to question.
APS comments on these matters follow:
l 2
-- - ^ " ~ ~ ~ - - - ~ ~ ~ - ^ -
. i' e'
Paragraph 1 (nare 8)
NRC Statement
~~
This paragraph refers to a problem found in the lighting fixtures inside containment, i.e., electrolyte evaporation.
The report states that APS missed an opportunity to apply this information to the safe shutdown ?ights in areas outside of containment.
Comment Although the lights inside containment are the same as those outsido the containment, the accessibility for Preventive Maintenance (PM) is much different due to AIARA concerns.
APS is able to perform routine PMs on the lights outside of containment.
Therefore, the NRC premise that electrolyte level from lights inside the plant would be useful input for evaluating problems in lights outside of containment is incorrect.
fararraph 2 (tiare 9)
-NRC Statement The inspection report discussed two canceled Plant Change Requests that were written to replace fixtures in Containment and the MSSS. The quoted justification for cancelation of the PCRs provided in the inspection report only applied to the containment fixtutes, not the MSSS fixtures.
, Comment PCR 87 13-QD 004 was written to replace the existing Dual-1.ite units in the MSSS with a different type of Dual-Lito designed for outdoor use. This PCR was later canceled based on:
(1) Innses on existing units were replaced with high temperature lenses, (2) circuit board failures could not-be attributed to MSSS environment, and -(3) the recent burn test had passed.
PCR 87-13-QD 007 was written to replace the containment (non Appendix R) lights with-an inverter based _ system.
This PCR was canceled due to the following: (1) high cost, (2) all recent (October 1987) burn tests had passed. (3) no ALARA concerns, checks of dosage data showed-very low dowages for electricians performing PMs, (4) few man hours to perform PMs, and (5) EER 87 QD 004 disposition (i.e., adjusting float voltage and adding mineral oil) should mitigate any further electrolyte loss.
EER 86-QD 007 was found to be unrelated to this issue.
3
faranraph 3 (pane 9) mig Statement The Inspection Report also discussed EERs written to adjust float voltages on Dual Lite fixtures and questioned the advisability of performing the adj us tment.
Comment These EERs were written to drill a hole on the side of the Dual Lite cabinets to allow easy access to the float voltage adj us tment potentiometer.
This modification was made for AIARA purposes to avoid dismantling the cabinot in high radiation areas.
Epranraph hin) (ones 9) b'JtC Statement The NRC expressed a concern, based on a vendor's letter, which stated that the warranty on the battery would be void if APS adjusted battery float voltages.
Cprrection The Dual Lite technical manaal provides the acceptable float voltages, and these values are used for adjus tment of the float voltages.
The notification from the vendor was a commercial issue and not the basis for the decision on adjustment of the float voltagen.
Paranraph 4(b) (nane 9)
NRC Statement The NRC expressed a concern about adding mineral oil to battery electrolyte.
Comment APS contacted Dual Lite in 1987 and used the vendor's recommendation to rupport adding mineral oil.
On October 24, 1989, a Dual Lite letter provided a recomme.:dation concerning the questionable uso of mineral oil.
Ilowever, further discussions with Dual. Lite on April 30, 1990, indicated that mineral oil was only a problem with lead acid batteries.
To clear thi, issue, APS contacted the battery vendors directly.
They supported APS' original position that mineral oil did not cause a problem when used to top off the electrolyte.
In addition, ApS inspected all the Dual Lite cir,ht (8) hour batteries and found no evidence of mineral oil addition.
4
Section 3.0 (nage 10)
This section of the Inspection Report concerns the apparent failure to perform an ennual review of the Pre Fire Strategies Manual.
Paratraph 4. Concern 1 (page 11)
EBC Statement The NRC states that, at the time of the inspection APS had not reviewed the Pre-Fire Strategies Manual in accordance with lechnical Specification 6.8.2 and procedure 01AC.0AP2.
G2illett The correct procedure number Js 01AC 0Ap02 and, as noted in the enclosure, APS has met those requirements.
Section 4.0 This section of the Inspection Report concerns the apparent failure to provide emergency lighting of approved design for outdoor use to support safe shutdown.
Perneraph 3 (nare 12)
NRC Statement The NRC states that EER-QD 007 concludes that the Emergi Lite units were poorly constructed and were not tested and approved for outdoor use.
Comment l
ApS alsagrees with the third sentence.
EER 89-QD.007 did not state that the lights "were not apptveed for outdoor use. "
The EER documented an apparent paperwork problem with labeling and poor workmanship.
The EER's disposition was that the units were suitable for outdoor use, i
l Paragraph 7 (page 12)
NRC Statement l
The NRC-states that because the Emergi Lites are in NEMA 4X enclosures, i
APS considers them installed indoors.
Comment APS disagrees with the words "in easence installed indoors" found in the third sentence.
It is APS's position that the units are cuitable for outdoor use.
5
o '.
l e
Diagraph 8. Iten 2 (pag t n I
NRC Statettent NRC states that AFS altered the design of the Emergi. Lite units.
Comment APS did not alter the Emergi. Lite units.
They were advesrtised by the [}\\
vendor as suitable for outdoor use and APS purchased a complete unit.
UIAtr.0.01t L_hrm 4 (ppe 111 NRC Statement The NRC states that APS did not sufficiently evaluate the potential for short circuits in the Emergi 1.ite units installed in the MSSS breezeway.
Comment APS disagrees with this item.
The vendor manufactures and markets units which comply with the NEC to preclude short circuits.
A review of work orders has not indicated any failures due to short circuits at PVNGS.
Section 5.0 This section of the Inspection Report concerns the apparent failure to report violations.
Pararrach 2 (pane 13)
NRC Statement; I
The NRC indicates that inverter 3EQBN004 was inoperable for a period of greater than 30 days in January 1990.
l Comment As stated APS' April 20, 1990, response to NRC violation 530/90 08, this
\\ gy inverter was bo11cved to be operable from January 7 until troubic shooting f (K' work began on February 8, 1990.
The inverter was inoperable only from February 8th until February 16th during the period trouble shooting and I
- b. 7,
\\,
repair work was in progress, 1
6
2 Paragranh 3 (pare li).
E.P.I_1 tat eeren t The NRC indicates that inv,rter 3EQBN004 was inoperable for more than 30 days during a period starting in August 1988.
Comment The inspeetion report should be corrected to indicate that rather than being inoperable for more than thirty (30) days as stated, the auxiliaty building lightinB unit (30QBN004) power supply failure occurred on August
?h[' ')
29,1988 (refer to EER 88.QB 003) and was repaired the same day on August 5
g 1
29, 1988 (refer to the failure evaluation summary provided by ApS letter r
dated June 19, 1990 (#161 03288), Appendix A, page 4.
Batteries were
}
replaced on September 1, 1988.
MPENDIX A Srptien 1 Parngrnnh 3 (pngdl The PVNGS UFSAR does not contain table IV.J in Appendix 9B nor can it be located in other sections applicabic to emergency lighting.
Section 1.
P.araprop) 4 (nnge 151 Line 1 references UFSAR Appendix B, Safety Design Basis 18. Safety Design Basis 18 is listed in current FSAR Section 9.5.i.1.
(There is no FSAR Appendix B.)
Section 4 Paragrneh 5 (nnge 1]l As stated previously, Appendix 9B Tablo IV.J does not exist in the PVNCS UFSAR.
1 7
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ATTACllMENT C
SUMMARY
OF INDEPENDENT REVIEW 0F EMERGENCY LIGHTING BY ABB IMPELL
J
SUMMARY
OF ABB IMPELL INDEPENDENT REVIEV 0F EMERGENCY LIGilTING
'k in the interest of obtaining an independent evaluattori of the status of the Palo Verde emergency lighting systern, APS contracted with ABB I npell Corporation, whose expertise in nuclear plant fire protection was judged to be valuable for such a review.
Under this contract ABB 1mpell was requested to:
(a) determine which Np.C requirements are applicabic to the PVNCS emergency lighting system, (b) sample work done on the ernergency lighting system to determine whether work done by APS meets these require: tents, (c) survey other nuclear plants to determine what actions they are taking or have taken to n.eet requirements applicable to their emergency lighting systerns, (d) evaluate the concerns raised by the NRC in Inspection Report 90 02 and other concerns raised by the NRC and others subsequent to January 1, 1990.
(e) judge whether APS has been responsive to those concerns, ABB 1mpell ideatified four issues as a result of the NRC requirernents and the status of APP's implementation.
These issues are:
(a)
Quality Classification of Emergency Lights.
(b)
Emergency Lighting Design.
(c)
Emergency Lighting Placement, (d)
Emergency Lighting Aiming.
APS is currently completing its review of the Impe11 Study.
During this review, APS will evaluate and disposition each recormnendation and will ensure that appropriate actions are taken, Quality Classification of Emergency LiEhts
. ABUmpd1 concludeLthat_NRC_re&ulations, APS_Jegulat.ory c_ommitments_and t
license conditions _ require _thrit_tbe PvNCS emergency _11ght_ityg_ system be treated as_ quality: augmented. ABB Impell also concluded that procedure 81AC 0CC06, " Quality Classification for Structures, Systems, Components,
[
Spare Parts and Activities." is inconsistent, such that it can be
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interpreted to limit the applicability of the BTP 9.5 1, Appendix A, QA criteria to only those itemt explicitly delineated in itert.16 of the UFSAR.
This is not consistent with sections 17.2, 9.5, 98, the Operations Quality Assurance Criteria Manual Criterion 2 and Appendix 1,~ UFSAR Tables 9B.3-1 and 17.2 1.
i ABB 1mpell made the following recorteendations:
(1)
Proceduro 81AC 0CC06 and related procedures should be revised to remove any source of confusion that structures, systerns and cornponents and activities described in UrSAR Section 9.5, which tropicment commi ttaen t s inade to BTP 9.5 1, Appendix A, are 1:nportant to safety and should be classified QAG.
(2)
Classify the structures, systerns and components and activities which innplernent commitments made to hTP 9.51, Appendix A, as QAC.
P (3)
-Implement the operations Quality Assuranco Criteria Manual for the items thus classified QAG.
Emergency Lighting Design ABB Irnpell reviewed the einorgency lighting systern to determine if the overall design was adequate to fulfill its intended function. The battery supplies for ernergency lights credited for inec ting the requirements described above woro evaluated in particular, to determine if their sizing a 1d capacity are adequate. Their review consisted of the following steps:
(1)
The different vendors that provide eight hour, battery backed emergency. lighting to PVNGS were identified.
(2)
The installation locations of emergency ~1ighting batteries credited for-cornpliance with the requirements of 10CFR50, Appendix R Section III.J were deterrained.
(3)
The sizing, capacity -and suitability of the subject batteries (vendor and manufacturer's documentation) were reviewed with rerpect to the worst case ternperature environments and outdoor applications.
The results of ABB 1mpell's review are suunarized as follows:
Dual Lite Emerrency Lichtinn Units The review demonstrated that there was sufficient battery capacity available at the design temperatures to provido eight hours of einergency lic.hting.
l 2
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s 4
Holochnne UPS l'mergency IJghtinn Units The review determined that the original Globe 6VilC96 96 amp hr. batteries are not capable of providing eight hours of emergency lighting at design temperatores of 50 degrees F.
for emergency lighting loads greater than 800 watts. There was no readily available vendor information for the replacement Dynasty UpS 12 300 88 amp hr. and Dynasty CC12V100 73 amp br. batteries, llowever, even without being compensated for design roaximum/minirnurn temperatures, these batteries are incapable of providir.g cight hour emergency lighting to loads greater than 800 watts.
It should be noted here that a load analysis on the llolophane UpS emergency lighting was not perforrned.
The above mentioned loads are the maxirnum allowabic cinergency lighting loads without taking other tangibles into account.
Dtergi Lite The review deterrnined that the emergency light batteries manufactured by SAPT had enough capacity to provide over eight hours of operation and were appropriate for outdoor use.
Exide Since these batteries are located in controlled ternperature environments of 85 degrees F., their full capacity is expected to be available.
The life expectancy of the batteries dixussed above is not cons
- lered a concern since the preventative Maintenance activities should detect any propensity for failure and the batteries replaced prior to becoming inoperable.
ABB Impel) provided the following recommendations:
(1)
QDR 90 0193 identifies the probicas related to the replacement of llolophane emergency lighting batterica with batteries that do not have enough capacity to meet the requirernents. The root cause for this specific problem has been identified.
Since the emergency lighting system is QAC, all replacement items for the system should fall under the QA requirements applicable to QAC classified systems.
ApS should determine whether additional verification or documentation is required as a result of the quality classification change.
(2)
ApS MNCR 90-QB.0004 and MNCR 90 QB 0005 correctly identify the problems related to insufficient capacity of the Holophane batteries to provido night hours of emergency lighting at 50 and 60 degrees F.
Ilovever, the dispositions of the above MNCRs should state that the new replacement UpS units should be able to provide eight hours of ernergency lighting for the design teroperatures as specified in the UFSAR.
This can be achieved by greater inverter efficiency in the new units and/or greater battery capacity in the batteries supplied with the units.
3
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(3)
All necessary vendor and manufacturers' documentation needed to verify the adequacy of any battery type installed for emergency lighting applications should be complete and mair.tained in a controlled manner for case of availability (i.e. VARTA and Dynasty batteries).
(4)
Haintenance Procedures for batteries should be revised to provide an " Action" value for battery minimurn voltage to assure that batteries are replaced before they are no longer capable of providing an eight hour dischart.e under adverse conditions.
Emergency Lighting Placement in order to ascertain if the emergency lights were installed as requi;ed.
ABB 1mpell conducted the following evaluation:
-(1)
Was the action identified in the Spurlous Actuation Study specific?
(2)
Was a light provided for each manual action?
(3)
Were lights provided for the access /cgress paths to each manual action?
(4)
Was the action in the fire arca/ fire zone of concern?
If the action was in the fire area / fire zone of concern a)
Would the equipment to be operated be " free of fire damage?"
b)
Was there sufficient time to extinguish the fire and then complete the action?
(5)
Did the operator have to trsvoi through the fire aren/ fire zone of concern to complete the action?
If the access /cgress path was through the fire area / fire zone of concera a)
Were the time frames for the action sufficient to ensure the fire was extinguished and the action-completed?
b)
Were there alternative actions outside the area / zone?
ABB Impell reviewed the Spurious Actuation Study 13 NS-110 and the Pre-i i
l' ire Strategies for all actions identified for fire areas I and XV, ABB Impell reviewed Procedure 42AO 2ZZ44 " Shutdown Outside the Control Room due to Fire and/or Smoke" to ascertain any additional information regarding
[
the actions in fire areas I and XV.
Emergency lighting drawings (13 E-(
ZPL 001 through -004) vers rev1wed to determine if lights had been provided for all actions and access /cgress paths.
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en_,.....
.m-,
l ABB Irnpoll also c.onducted a walkdown of fire area XV to deterraine 1) the I
accurar.y of the emergency lightin6 drenings, 2) the feasibility if the actions and 3) the orientation of the lights,
~~
The results of ABB In:pell's revlew indf cated that:
l (1)
The operator actions identified in the review can be shown to be acceptabic based on 1) alternato actions available, 2) actions required after eight hours or 3) rnechanical cornponents shown to be free of fire damage, lloweve r, the current analysis, the existing QDR 90 054 and the Essential / Emergency Lighting Analysis do not contain this evaluation for all fire.
areas.
(2)
Based upon conversation with ApS personnel, the action to
" ensure the condensate transfer pump is not running" would take place in a fire zone which has croorgency lighting and therefore is acceptable.
(3)
Based on conversations with APS personnel, the Train A dicsol
- aay be tripped by removing DC power from the breakers which feed the 4160V A bus from the A diosol. (Emergency lights are provided in this zons.)
Furthe rrno re, if the train A diesel is already running wFen the operators arriva to reinovo the DC power, they will trip the 4160V breaker first.
Therefore, ernorgency lighting is not required at the Train A Diesol.
According to QDR.90 054, an enhancement light will be added to this area.
Based on conversat'.ons with APS personnel, the action to trip the turbine at the turbine stand is for equipment protection only because the trip of the MSIVs (at a location where emergercy lighting is provided) will accomplish the. same results.
The re fcere, emergency lighting is not required for the action at. the turbine stand. According to QDR.90-054, an enhane.cnt light will be added to the turbino stand area.
As a result of their review of emergency lighting placement,~ABB Impell made the following recommenJations:
(1)
The spurious actuation studies'should be reviewed in detail to ensure that all manual = actions are feasibic.
The draft action plan for closure of CAR 90-014 was reviewed and the plan appears :o address the manual action ' issue for a fire in any fire ares / zone.
(2)
The spurious actuation studies should be revised to clarify the specific operator actions for such vague action statements as "ensute" or "stop."
-5
e (3)
For alternate actions (e.g., enhancement lights) for a fire in the control room, moving the " nice to have" actions to attachments in procedure or identifying them in the procedure optional actions would add clarity to the procedure and as inform operators of those actions required for safe shutdown.
(4)
For those alternate actions resulting from a fire in any other fire area. APS should also consider identifying the actions in the pro-fire strategies as other actions which may be taken if time permits. This is consistent with what is done at other utilities.
(5)
Th
'ilesel Generator A Actions should be clarified in the spurious actuation study and in the pre fire strategies.
Emergency Lighting Orientation Orientation of emergency lights has been identified as a concern by APS several times (for example, Monitoring Report MR90 0741 and EER 88-QD.
007).
During the walkdown of fire area XV, Emergency Light SAL 72C 03100 01 in fire ::ono 42B appeared to be misdirected.
Without a blackout test, however, it was difficult to tell whether the lighting would have been adequate.
Also, the emergency lighting drawings 13 E ZJL 001 through -003 do not adequately describe the orientation of the lamps.
ABB Impell concluded that emergency lighting units are susceptible to repositioning.
To ensure that the lights are positioned properly, orientation verification should be included as preventive maintenance or in an operator round sheet.
Also, during discussions with APS personnel, it was determined that drawing l
13 E ZPL 004 had been issued. This drawing identifies the equipment which will be operated and the lights which will provide illumination.
- Also, ABB Impell was informed that the orientation verification will be added l
to affected preventive maintenance tasks.
Based on this review, ABB Irupell concluded that APS should complete the action to reviso preventive maintenance tasks to include emergency lighting orientation verification.
ABB Impe11 Review of Identified Concerns In Inspection Report 90 02, the NRC identified a number of emergency lighting concerns.
Subsequent to that, the NRC and APS identified additional concerns.
ABB Impell evaluated these concerns to determine whether the APS discussion was responsive to those concerns.
APS has evaluated ABB 1rr.pell 's review of these concerns and has documented significant items following this summary.
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Utility Survey ABB 1mpel'1 conducted, at APS's request, a survey of nuclear utilities to determine their arproach and status of implementation regarding a number of the issues tetsed relative to emergency lighting.
The results of the utility survey are summarized for the following issues:
Battery Sizing Preventive Maintenance Quality Assurance Requirements Operability / Compensatory Measures Orientation of Emergency Lights Illumination Levels Training Batterv sizing Of the seven utilities asked questions relating to battery sizing, two utilities stated that temperatures were taken into account in sizing the batteries.
The remaining utilities indicated that they understood that temperature had an effect on battery capacity and life expectancy.
Ilowever, they anticipated any degradation to be identified during regularly scheduled maintenance activities.
Preventive Maintennneo of the'seven-utilities asked the mainte ance questions, all had some sort of testing program in place. The major.,y of the utilities have an annual discharge test in addition to a more frequent visual examination.
None of the seven contacted did any pre-conditioning of the batteries pr'or to testing.
Ouality Assurance Requirements of the seven utilities contacted, two did not consider emergency lighting included in the fire protection augmented quality assurance program.
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i Ope rab i l l t v/Comne ns a t 2rv fic a su re s Eight utilities were contacted regarding this issue. Two of the eight hold CL 8610 license conditions similar to PVtJCS.
One utility has defined operability requirements for not only emergency lighting systems but also for safe shutdown equipment which is not currently in the technical specifications.
The other utility does not have any special reportability/ compensatory measures in place for emergency lighting, although this utility does take credit for hand held portable units.
Orientation of rmerrency Ligitta One utility has operators verify orientation as part of their weekly round sheets.
All the remaining seven utilities contacted verify orientation as part of their monthly, quarterly or semiannual visual examinations.
1110minntion 1.evels All utilities responded that t.he emergency lighting provided was done so in accordance with the guidelines of CL 86 10.
Some utilities did, however, have quantitative illumination criteria for specific areas (for example, the control room, the remote shutdown panels and some committed to tJFPA 101 for egrecs routes.)
Traininr.
Five of the eight utilities contacted maintain separate procedures for fires outside the control room. Each of these utilities provides some type of refresher training for these procedures.
The other three utilities believe their shutdown for a fire outside the control room is encompassed by existing Emergency Operating Procedures.
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ATTACHMENT D DISCUSSION OF Tile CONCERNS LISTED IN THE ENCLOSURE TO INSPECTION REPORT 90-25 I
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,i DISCUSSION OF Ti!E CONCEPJ1S LISTED IN Tile ENCLOSURE TO INSPECTION REPORT 90-25 COMMENTS TO 1NSPECTION REPORT 90 25._ATTACitMENT 1 APS reviewed the attachment to the Inspection Report, which was material provided to NRC staff in the May 17, 1990 meeting by APS personnel.
The attachment listed 25 concerns and APS responses. As part of an independent review, Impell reviewed each response by APS.
This attachment provides updated responses based on the review by Impell, Concerns where Impell provided " additional discussion" are also provided in this attachment.
Concern No. 2:
The various battery manufacturer's literature state that the manufacturer's warranty is invalidated if the batteries are operated in ambient temperatures above 110 degrees F.,
or if the batteries are not maintained in accordance with the National Electrical Code.
FSAk Table 9.4.2 speelfied the maximum operating space temperatures for certain areas.
(E.1.a. p, 4)
Original Discussion:
There are four emergency lighting vendors which supply Appendix "R" required lighting in various applications throughout PVNCS.
These applications, including the worst case temperature environment from UFSAR Table 9.4.2, are as follows:
Vendot hilldings EfEAR Temperature Dual Lite All Areas 122 F (Turbine Bldg) 140 F (DG Bldg /DG running) llolophane Control 120 F (Aux Bldg)
Auxiliary Emergi 15te MSSS 120 F (MSSS)
Breezeway Exido Control Room 85 F (Battery rooms) 1
1 1
Dunl Lite The Dual-Lite ernergency lights are wall mounted, scif contained, battery powered emergency lighting units.
These units are located in every building at PVNCS.
They are used in both 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 1-1/2 hour applications.
Each emergency lighting unit has a long life Nickel Cadiniurn battery.
Emergi-Lite Emergi Lite wall inounted units are used in the MSSS at the 140' elevation for the ADV's and in the Turbine Building Breezeway.(the access / egress path for the MSSS).
Each Emergi Lite unit is supplied with a scaled Polytemp Nickel.
Cadtniurn battery rnanufactured by SAFT. These batteries are designed specifically to Bive long life under high ternperature environments.
SAIT has recently provided to APS a curve showing that at a continuous ternperature of 120 F, the cell life of the battery would be four to five years.
This capacity, per SAPT, would be capable of delivering 8-1/2 hours total run tirne at 120 F.
In addition, the Emergi-Lite chargers are ternpe ra ture compensated to automatically adjust float voltages for high ternperatures. This will avoid over-charging of the batteries and hence extend the life.
Holonhane In the Control Building and Auxiliary Building where a broader source of light was needed to illuminate switchgear and relay panels, a
modular AC power station was used. These power stations supply numerous fluorescent fixtures from each power station.
The units each contain their own lead calcium battery enclosed in a separate compartment of the power station.
In the Auxiliary Building, these units are exposed to a worst case temperature of 120 F.
Recent correspondence from the vendor has shown that at that higher temperature, continuously, with an uncompensated charger, as used at Palo Verde, the expected life of the battery is 9 months.
This is the absolute worst case, since we know in actual application the temperatures are not near this value continuously year round.
It should be noted that the capacity of these batteries would increase by 10% at this higher ternporature.
I 2
4 Exide The Exide units have their batteries located iti the Class 1E battery rooms. Since this is a very controlled envirotunent with an absolute maximum temperature of 85 F.
The temperature concern is not a factor.
Additional Discussion:
The Irnpell evaluation of the APS response recommended that the temperature dorating effect on battery capacity be included in the desi ;n criteria for the replacement Holophane lighting units.
APS concurs with the recomtnendation.
Concern No. J_0:
0 There does not appear to be sufficient rnergin in the GC 12 100 battery capacity to supply power to the lighting fixtures for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Further, it appears that two of the batteries installed in Unit 2 with the lower load profiles have nevet been tested, and one other failed the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge test on March 6, 1990.
(E.1.a. p. 6)
Original Discussion:
The statement "... two of the batteries installed in Unit 2 with the lower load profiles have never been tested..." is a misinterpretation of the APS self imposed testing report.
The two UPS' in question, 2EQBN002 and 2EQBN003, were unavailable for testing for not passing the monthly acceptance criteria for open circuit voltage of a battery. The defective batteries were replaced and 8-hour discharge tests were performed and all acceptance criteria met. UPS 2EQBN001 did fail its 8-hour discharge test, the batteries were replaced and the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge test re-performed and all acceptance criteria were met.
Additional Discussion:
ABB Impell recommended evaluation of the Unit 2 llolophane replacement batteries for adequate capacity at lower temperature.
APS has evaluated the capacity of the batteries that were installed prior to restart from the last refueling outage and have found them to be acceptable. The batteries were installed in all four Holophane lighting units in Unit 2.
3
Concern No. 11:
At the time of the inspection, it appeared ' that appropriate corrective actions had not implemented to preclude emergency lighting battery failures and recurrences as evidenced by emergency lighting battery failure data shown in a February 20, 1990 Failure - Data Trending cor:puter printout for the period 1988 through 1989, and a high volume of new battery usage as shown in a March 20, 1990 procurement Materials Managemene Informatiun System computer printout for the period 1986 through 1990. During the period of May 1987 to Octohet 1989, 70 of uproximately 480 emergency lighting unit Nt,. ries had failed. Approximately fifty of the failed batteries vera required to support safe shutdown.
Ilowe ve r, appropriate evaluation of the failures to determine cause and prevent recurrence apparently had-not been initiated or documented.
(E.2, p. 6)
-Original Discussion:
There were 79 incidences involving some type of corrective action per the Failure Data Trending (FDT) database since 1987. There vere only 13 battery failures for AppendLx R emergency lights and 12 battery for Non-Appendix R emergency lights. To compensate for component replacements under the 'rM ' pr ogram, the MMIS Material Activities Rem rt dated March 20, 1990 was used to extract battery failuren no; ide u find in the FDT databsse for Dual-Lite st.pplied batteries.
Jero an additional 24 Appendix R..ittery failures and 12 Non+
dix R battery fail res. Of the 24 Appendix R hattery
' failures,. h ere batter:es used in the NEMA 4X Dual-Lite fixture which piec' ncated the issuance of DCP 1,2,3FE-QD-022 (Emergi Lite units),
de remaining 9 Appendix R failures per MMIS = and the 13 battery ic.ilures in FDT represents only a.5% failure rate for-440 Appendix R emergency lighting units for a 30 month time period.
RCF EER are generated whenever the System Engineer identificc sufficient increase in failures.
RCF EER 90-QD 002 was generated based en the fourth quarter FLT report due to the increase in failures of chargarg cards.
Additional Discussion:
The above discussion is superreded by Section II.A of this letter.
In addition, the ABB Impell Report recommerded that:
" Corrective Action documentation should be dispositioned and completed for the following ft.ure rndes:
[
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1)
Battery failures 2)
Charging Card failures w--
r y
e
--..-p-A
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Enture the Corrective Action QA criterion is implemented for Emergency Lights. "
.a 'urs with the recommendation to implement the Corrective Action QA criterion.
This action is accomplished through the classification of this system as QAG.
APS is completing an equipment maintenance history review and will pursue corrective action to the equipment as a result of this review, w rn No. 12:
SER No. 87 -QD 004, dated Ianuary 28, 1987, identified and documented nroblems associated with batteries for the em?rgency lighting units
- a. follows: "High temperatures inside Containment during operation cause loss of electrolyte in all fixtures; total loss in many, varying amounts in the rest. Salt accumulates on battery posts and vent caps and is discarded during PM cleaning.
Continual repeated electrolyte loss with domin water replacement will cause premature battery failure", The same batteries (Dual-Lite Model EKE-30) used for Containment emergency lighting are used for safe shutdown emergency lighting in the Auxiliary Building, Control Building and Diesel Generator Building.
(E.2.a. p. 6-7)
Original Discussion:
EER 87-QD-004 identifies a concern with repeated replenishment of electrolyte by adding demineralized water to the batteries in Containment.
Temperatures in containment and excessive float voltages ar3 only some of the contributing factors of electrolyte loss.
The major ause af electrolyte evaporation is the lack of quarterly PM's for the Containment emergency lighting. For emergency
'ights in Containment, PMs are carrently performed only once per fuel cycle (during refueling outage). Access to Containment is restricted during plant operation for the performance of other than the cycle PM's.
The time between the performance of the cycle PM's can vary from 1 year to 2 years.
Varying amounts of electrolyte loss is expected with total loss of electrolyte expected if the last performance of the cycle PM's is over a year.
ts installed N
outside Containment are not subject to the same env
'nt and have PM's performed on a quarter ly basis.
The performai., of the PM's ensures that the light will perform its intended function.
No battery plates have been uncovered for units outside of Contahent if quarterly PM's were performed.
The only exceptions W re lights that were inadvercently 1cft out of PM's (non-Appendix R lights),
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The quarterly PM's for outside Containment emergency linhts are adequate to ensure that the lights are maintained in accordance with Dual Lite's recommended maintenance criteria?
The lights in Containment are not required for safe shutdown and have their cycle PM's performed during the refueling outage.
Additional Discussion:
Impell recommended evaluating replacement of the emergency light batteries in containment (not Appendix R lighting) with a type that does not require maintenance between fuel cycle reloads.
APS concurs with the recommendation.
t fancern N,p J :
Certain barteries have demonstrated a continuing failure history (Failure Data Trending).
For example, 15 percent (70 failures of approximately 480 Appendix R emergency -lights installed !a all 3 units) failed over a 30 month per.iod (May 1987 to October 1989).
The NRC is concerned that Appundix R emergency lighting preventive maintenance - tasks hs.ve not been designed to optimally assure a continued capability of Appendix R lighting taits to operate for the required eight hears.
Furthermore, apparently, timely preventive maintenance completion has not been aggressively pursued because,.
In about 84 instances, the required annual capacity test and quarterly electrolyte level ch ks were overdue in Unit 3 as of March 23, 1990.
(E.2.d, p. 7).
Original Discussion:
Refer to Concern 11 discussion for Failure Data Trending information.
PMs.are developed based upon manufacturers' recommendations.
Schedule dates are establi-hed based on the periodicity of the PM, PMs may be delayed past their due date without management approval under the following conditions:
Meets criteria for delaying specified in procedure 30AC-9MP02.
Does not exceed the grace period (25% of maintenance interval).
PMs can. be delayed p,st their grace period with the written concurrence from the Maintenance Manager (or designee) on the Preventative. Maintenance Task Disposition Report.
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The grace period has been tabulated below for the different periodicity of PMs:
4W
+7 days 12W - + 21 days 24W - + 42 days 48W - + 84 days 1Q
+ 23 days
- 1M
+8 days is
. + 46 days 1A
+ 92_ days 1R No firm due date, must be completed during the refueling outage (Ref. 3.7.1.2 of 30AC-9MP02)
Majority of the PMs have been performed prior to the due date or during the grace period, as allowed by procedure 30AC 9MP02.
All discharge PM tasks were performed prior to the overdue date (prior to end of grace period). Manpowor restraint caused by having 3 units in an outage along with the Unit 3 Main Transformer event (January 1990) depleted the available manpowar resources to perform emergency lighting PM tasks. Currently there are no PM tasks past their grace period.(5/8/90).
Additional Discussion:
The-Impell report ' recommended that APS address the isrue of adj ustments to the PM frequency to identity degraded -performance prior to failure of the light.
APS has agreed to institute a program of capacity discharge testing and trending of rasult to preclude failure. APS has also agreed to shorten selected PM incervals and monitor electrolyte evaporation to determine appropriate maintenance intervals.
Concern No. 24:
Thirtaen lighting level readings were taken at various locations outside the control room in Unit 3 with a photometer (Spectra Photometer Model FC-200, Serial number 476,. NRC Equipmenc Number 000393, with the next calibration due date of 7/26/90).
The locations were the stairwell outside the control room, the essential chiller surge tank level and v.1ves, the ch.'11er room stairwell exit, and the Emergency Diesel Generator rooms.
The photometer readings ranged from 0.03 to 0.75 foot-candles with an exception of 1.3 foot.
candles at the emergency diesel control panel.
(E.6.b, p. 11) 7
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Original Discussion.:
p For Appendix R lighting, APS used the guidance of Generic Letter 86-10, which statec-that-illumination, levels shall be sufficient to perform the shutdown function.
Emergency lighting has been walked
'down to confirm this.
Additional Discussion:
The Impell report recommended clarifying the UFSAR on illumination criteria and consider recording baseline illumination levels for future use.
APS. agrees with the recommendation.
-Concern No. 25:
Orientation of the lamps on a lighting unit in the stairwell outside the'-control room were found to be not directed toward the access / egress pathway.
(E.6.b, p. 11)
Original Discussion:
Incorrect. lamp orit.itation noted during recent NRC inspection was an isolated occurrence due to construction work on the adjacent Unit -
- 3. Operation Support Building. Adequate lighting for access / egress existed _ even thought: the ;1 amps were not directed toward the access / egress pathway.
Inspection team members were able to access / egress the stairvell.
' LampL orientation is verified when performing quarterly: preventive maintenance (PM). Quarterly PM's provide instructions to orientate the lamps, i
Drawings are -being developed to provide specific information to facilitate the orientation of lamps by the electric' 'n during the L
performance of the PM.
j -.
Additional Discussion:
The previous response on this issue was not accurate.
The modificat?on of PM tasks to. provide instructions to properly aim t
the lights has not been made. Drawing number 13-E-ZPL-004 was issued L
Jin June nud identifies the equipment to be illuminated by each light.
A review was mado.in June of all Dual-Lites in all three Units to verify proper orientation. of the If ghts.
This direction will be incorporated; into PM tasks.
This action is consistent with Impe11's recommendation of this topic.
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4 ATTACHMENT E UPDATED LIGHTING FAILURE
SUMMARY
AND AVAILABILITY EVALUATION
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UPDATED LIGilTING FAILURE SU)D(ARY AND AVAIL \\BILITY EVALUATION This attachment presents updates to the information provided to the NRC in the letter dated June 29, 1990; and examples of the methodology used to calculate the equipment availability.
Included in this attachment, as Table 1, is an evaluation of the llolophane component failure data promised in the July 10th meeting.
llolophane Work Orders identifying a component or equipment deficiency from 1987 t, June 1990 are discussed in this table.
Tables 2 4 are revisions to the June 29, 1990, data based on the completed review of the Exide,llolophane, and Emergi-Lite work orders for the period June 29, 1989, to June 30, 1990.
This work order revieu was completed since the July 10 meeting.
Any differences from previous information arise as a result of the June 29, 1990, letter data coming from various computerized (and therefore summarized) sources, while the current data comes from a detailed review of hard copy work orders.
Figures i 6 illustrate the methodology used to arrive at the availability figures presented in Section II. A.4,C.
These figures are presented for selected pieces of equipment and show the maintenar.ce history, periods of availability and periods of unavailability.
The figures for the ba1.ance of the equipment is available in APS offices, o
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Old tic \\/- MS 29dce ll0LOpilANE TAILliRE EVALUATION bd
~
i The following deficiencies found during the review of 1987 through present Work Order hard copies are identified by date.
The date represents the earliest known time the deficiency existed, as found by the review. The dates shown in parentheses are the dates the deficiency was referred to in the June 29, 1990, correspondence to the NRC.
Deficiencies with an asterisk are deficiencies identified in the WO review which have not been noted in previous correspondence to the NRC.
UNIT 1 1 E-QBN-001 1-8 88*
Ba t;te ry_1 B_d i 1_ no taac e_t_the_.m i n i mum _I BV_ c ri t e r ie.
With this 7
one deficiency the Inverter is capabic of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
1 28-C8 Input breaker tripped due to 4 batteries being defective.
(4 13 88)
This condition prevents the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
12 17-89*
_BBTV was _found. to b.o_helow the minimum _ criteria., With this condition this inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
_(
discharge. The successful 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge with an initial BBTV of 25.3 on WO 405060 demonstrates this inverters capability.
12-27 89*
BBTV was f_ound to exceed Jhe faximum jr_1teri_q.
This condition does not prevent the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
12-27 89 8 bnur discharge._was_ voluntarily _ terminated due to a faulty (12-27-89) baHast,.
Evaluation indicates the inverter would have T(
N
~~
provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> dischargo if the test had not been terminated.
2-21-90 ILB'OLwa n_f ound_t o_ b e_b e l o w_th e _ min i mum _c r i t e r_i n_
With this r]
(2-21-90) condition this inverter i capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
!~
discharge. The successfu.
hour discharge with an initial a
BBTV of 25.3 on WO 405060 amonstrates this inverter's capability.
l l
i y0TE: '** indicates the_ deficiency was not reported in the June 29, 1997 letter.
~
i.
TABLE 1 Il0LOPilANE FAILURE EVALUATION 6-15-90*
Battery SA did not meet the minimum IBV criteria.
With this 7
ohe~deficierf ~thi inverter irdu iAblu Ef proviaing an 8 r
hour discharge.
(Note: This testing was a post modification retest) 1 E-QBN 002 2 28-87 Battery 3B did not meet the minimum _IBLcriteria._With this 7
(1 7 88) one deficiency the inverter is capabic of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
a 10-17-87*
One battery was found cracked and smoking.
With this condition the-inverter would not. have been capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
~ ~ ~
3 11 89*-
Battery 3A was found with a cracked post.
With electrical coneinuity being maintained, this inverter would have continued to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
8-18-89
,Baty rL A did not meet the minimum IBV_ criteria.
With this 7
I (3-26 90) one deficiency the inverter 's capable of providing an 8 i
hour discharge.
12-27-89 This 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> d_isgharge test was voluntary _ terminated because (12-27-89) of a defec.tive_ light _bal.last.
Review of the work document 7
has determined that the inverter would have successfully completed the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge if not terminated.
This is supported by the successful 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge of 3/26/90 (WO 405061) 5 8 90 Battery bank was replaced due to the batteries not meeting (5-14-90) design configuration.
This corrective maintenance does not constitute a failure since the batteries being replaced had passed a previous 8 hour-discharge.
5-9 90*
It t
determined the inverter was not capabic of providing its u.cended function since the new batteries failed the k
post maintenance 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discha_rge_tes,t_.[ ~
NOTE: '*' indicates the deliciency was not reported in the June 29, 1990 letter.
TABLE 1 Il0LOPIIANE FAILURE EVALUATION 1 E-QBN-003-2-25-88 3BTV did not meet minimum criteria.
The inverter _would_no,t (3 1 88) have been capable _of_ pro g g an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge,.
5-26-88 Battery 2A appeared to be leaking.
This description was not (6-27-88)
-a problem and no action taken.
Discussion with the vendor on this issue is documented on WO 298166 9-14-88*
LED indicator was not' functioning properly. This condition does not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
2-6-89*
BBTV did not meet minimum criteria.
The inverter would not have been capable of providing an 8 hou Fdischarge. " ~ ~~
1-E-QBN 004-l 1-9-87 Batteries 2A and 2B were isolated from inverter because of l
(1-15 88) one battery be_ing_shonted, This inverter vould_haye p-o 7
continued to support _an_8 hour _.dischnrge_ based._on_the_1_o.Ld j
and capac_ity_ study.
L 9-14-88*
LED indicator was-not functioning properly. This condition does not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discherge.
L 11-P-88*
LED indicator was not functioning properly. This condition l--
does not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
i 11-1-89
_ Battery _2A_did_ no_t_nleet the_ minimur IBV criteria. With this 7
l.
(11-1-89)-
one deficiency along with the load and capacity study this
~
L-(3-2-90) inverter would continue to support an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
Note: Deficiency dateu 11-1-89 was /
previously reported twice. '
b.-
/
-Ahct 4u/A- -m' J,, /g, -
a s
i NOTE: '*' indicates the deficiency was not reported in the June 29, 1990 letter.
l
'Y
_p.
TABLE 1 Il0 LOP 18ANE FAILURE EVALUATION UNIT 2 2 E-QBN 001 10 25-88*
. Graphic display board (LED) was replaced.
This condition does not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
,W 3-89 B.attery_,3B did not_peet the minimwn IBV criteria.
With this (7 j (2-22 89) one deficiency the !nverter is capable of providing an 8 Q/
hour discharge.
1 31 89*
Batteries 2B and 3B did not meet the minimum IBV criteria.
With two batteries in this condition, evaluation has determined the inverter would not have prov_ided_an_8_ hour, discharge.
2-13-69*
Four-batteries were replace, but not 2B, With only 2B in a, 7
low IBV condition the invertar would-continuedro provide-an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
3-29 89*
Af ter a successful 8 - hour discharge, the IBVs on all batteries failed to meet minimum-critoria within a Y
reasonable period of time, Duting this deficiency the inverter would not have_prov_ided an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge u
6-24-89 Battery 4B was found-.with a cracked post.
With electrical
-(8-15-89)-
conti uity still-being maintained, the inverter would have continued to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />' discharge.
3-5-90 Inverter failed an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge which. indicates the (3-16-90)
--inverter was not capable of providing-an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
2-E QBN-002.
3-1-87.
Inverter was providing inadequate charger output as a result (3-10-87) of=a loose connection.
The_ capability _and_rell_ ability _of, the--inverter en_ provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge is indeterminat n and'dispeiident on the connection status.
9-9-87*
8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge failure due to a. defective transfer relay.
g Tl e inverter was not capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> l
discharge.
~~
~
5-5-88
'u
-(5 12-88).
8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge f ilure.
T,h Q veg er was not capable of
- providi_ngJm_8_ hour d_ischarge.
~
_-h
~
NOTE: '*' indicates the deficiency was not reported in the June 29, 1990 letter.
i TABLE 1 Il0LOPilANE FAILURE EVALUATION 10 25-88*
LED was providing faulty indication.
This condition does not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
1-6 89 Battery 4B did 1BV_ criteria.
With this one deflil_ency_not meet the minimunttl.e inverter is capable of pr (2 15 89) hour dischargo.
s 1-23 90
_ Battery 2B did not meet the minimum IBV criteria, With this
~p i (4 19 90) one deficiency the inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> dischargo.
3-14 90*
LED was providing faulty indication.
This condition does not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> dischargo, (Defective termination block) 6-29-90*
LED was providing faulty indication.
This condition does impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
not (Loose connection) 2 E-QBN 003 7 6 87 Batteries were replace because the installed batteries would (7-8 87) not come up.
The, inverter would not have provided an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
9 1 87 LED graph was providing faulty indication, This condition (10-1-87) does not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
12-7-88*
LED needs recalibration, This condition does not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge, 2-15-89 Battery termination on battery 48 indicated the bolt was (4-18-89) pulling through the terminal, With niectrical continuity still being maintained, the inverter would have continued to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge, 6-6 89*
BBTV was found to be to be low at -the time the PM was worked. This condition should not be considered a failure
-since it is expected to see a low BBTV the day following an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> dischargo.
.8 16-89 LED was providing faulty indications.
This concition does (8-25 89) not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
-(Termination problem)
NOTE: '*' indict.tet the deficiency was not reported in the June 29, 1990 le t te r.
.__-m_..
TABLE 1 Il0LOPilANE FAILURE EVALUATION
__h 12 29-89 Battery 2B did not mett_the> inimum IBV criteria. With this (3 13-90) one deficiency the inverter is capable of providing an 8
/
hour discharge.
3-16 90 New batteries provided an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge but bat ;.e_ry_311 J
(3-17-90) did not meet the minimum IBV criteria coming out of_the_24
,[NJ hour _Jharf,e.
With this one deficiency the inverter is a
capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
5-11-90*
BBFV was found not to meet the minimum criteria. The
.inverte.r would not have been capab1_e o_f.providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
. discharge. Correction was made by adjusting th~e' float
~
voltage during performance of the PM and prior to PM closure.
-2 E-QBN 004 9 7-87.
Battery 4A did not meet the minimum IBV criteria. With this (10 1 87)
We~Be^fElency tee ~ inverter is capable of providing an 8
(/3 'N hour discharge.
8-31-88 LED display was not providing proper indication. This (9-12-88) condition has no-effect on the inverter to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge. -(Loose contacts) 10-25-88*
LED display was not providing proper indication.
This condition has no effect on the inverter to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
(Replaced PC board)
'6-4-89
. Battery _2A did not meet the minirrum IBV criteria.
With this (6 4-89) one deficiency the inverter is capable of~provMing an 8 7, ].
hour discharge.
8 16 89 LED-displaf was not providing proper indication.
This (8-25 89) condition has no eficct on the inverter to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
(Looso contacts)-
rm 9-5-89 Battery 3A did_nqLinectJ.he_.minimumJBV criteria.
With this (9 5-89) one defTclency the inverter is capable of providing an 8
}j}
hour discharge, 12-29-89*
BBTV did not meet minimum criteria. This condition _ prevents th_e inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
1-24 90*
B BTV e x c e e d e d_!;.b eunni munte r i t e r i a. This condition will not
~ 4 Qi; prevent the inverter from providing'an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
]
NOTE: '*' indicates the deficiency was not reported in the June 29, 1990 letter.
M TABLE 1 Il0LOPilANE FAILURE EVALUATION 4-3 90*
LED display was not providing proper indication. This condicion has no effect on the invertar to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
(Loose contacts) 5-11 90*
BBTV did not meet minimum criteria.
This condition preye,nts g,.
the inve _rter_from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> dischayge,,
d NOTE: '** indicates the deficiency was not reported in the June 29, 1990 letter.
,s TABLE 1 Il0LOPilANE FAILURE EVALUATION UNIT 3 3 E-QBN-001 7-8 87 BBTV did not meet minimum criteria. This_condi tion _ prevent;s (1 17-86) the inverter from.providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> d_ischarge.,
12 9 88*
LED dis. play need rncalibration. This condition has no effect on the inverter to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge, n
2-2-89 Battery 1A did not_ meet the minimum IBV criteria. With this (3-22-89) one deficiency the inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
6-8 89 Battery 3A was found to be drawing excessive current. As a (6-8-89) result batteries 3A and 3B wera isolated from the inverter unti. the deficiency was corrected.
The 1.nyerter_was not capable cf,providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
3 11-90*
BBTV was low af ter coming out of an 8 discharge.
The inverter was not capable of providing a full 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge for 2 shifts, which is expected after a discharge.
6 16-90*
After the installation 01 new batteries, battery _2A_did not meet._the_ minimum IBV criteria. With this one deficiency the e'
inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
(Note: This testing was a post modification retest) 3-E-QBN 002 9-12-87*
Battery 3A did not meet the minimum IBV criteria. With this 7
one deficiency this inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
2-5-88*
All batteries failed to meet the minimum IBV criteria. The inverter would not have been capable of supporting an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> _
. dis _cl arge..
3 4-15-88*
Input breaker would not open.
This condition would not have impaired the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge as proven by WO 247190.
8 30-88 LED display was not providing proper indication.
This (9-29 88) condition hr.s no effect on the inverter to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
NOTE: '*' indicates the deficiency was not reported in the June 29, 1990 letter.
TABLE 1 Il0LOPilANE FAILURE EVALUATION 12 2 88*
Battery 2B did not meet the minimum IBV criteria, With
~
this one deficiency this inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
11-17-89*
LED display was not providing proper indicatioa. This condition has no effect on the inverter to proside an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
3 E-QBN-003 8-16-87 Batteries were missing from cabinet. With any batteries (4-14-88) missing from the inverter, the inverter is not capable of
~~~
~~~
providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
5 8-89 BBTV was high because of_a_ defective, charging card., This 7
(5-11-89) condition does not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
4-3-90*
Battery 4B was found with a split in the post.
With electrical continuity still being maintained, the inverter would continue to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
5 3-90*
Faileo an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge indicating the inverter cannot s.u.pport an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
3
~
3-E-QBN-004 10-28-67 New transfer circuit was installed.
With a deficiency of (11-21-89) the transfer circuit the inverter would not support _an 8 ho.u t ischarge d
q 10-29-87*
LED display was not providing proper indication. This condition has no effect on the inverter to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
)
8-29-88 Batteries were found in a low and uneven condition, This
{
(11-21-89) deficiency would have prevented _the inverter from providint
,an_8_. hour _ dis cha r ge,
f a
3 17-59 Battery 3B was found with a cracked post.
With electrical (5-24-89) continuity still being maintained, the inverter would continue to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
2-7 00 Inverter was providing a high output voltage as a result of (2-16-90) a defective power supply.
This would.have p~revented the
-inv.e rJe r_f rom _providing an_8_ hour dis c'lia~G,~e.
~~~~
y K
~~--
NOTE: '*' indicates the deficiency was not reported in the June 29, 1090 letter.
l
TABLE 1 Il01DPilANE TAILURE EVALUATION 4390 LED display was fluctuating. This condition has no effect (3 30-90) on the inverter to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
(Loose contacts) 5 4-90 Led display was not functioning properly.
This condition (5-4-90) han no effect on the inverter to provide nn 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
(Bad elect rical connection) 4 1
NOTE: **' indicates the deficiency was not reported in the June 29, 1990 letter.
I l~
TABLE 2 EXIDE DATA UPDATES UNIT 1 1-E-QDN F01 6 1-E-QDN N01 02/28/90*
Low e1_ectrolyte_ specific _ gravity _was.found_ af ter--an_8-hour _ discharge _.was. performed, and several attempts
-f,.
were required to restore the battery. This_conditio_n would have prevented the light from burning for 8 h6urs. In addifibn~a~ float 7equs11ze switch require'd
~
~
replacement prior to performing the equalize charge.
Batteries were placed on equalize charge until electrolyte specific gravities were acceptable.
1-E-QDN F02 6 1-E-QDN-N02 02/28/90*
Low _clectrolyte_ specific grav.ity was _found_af ter_an_8._,
hour._ discharge _was_performe,d, and several attempts I/
were required to restore the battery. This._ condition, would have prevented the light from burning _.for 8,
[hfu'[s~ ~ Batteries were placed"6Ti~ equalize charge until
~
~
electrolyte specific gravities were acceptable, c
l NOTE: * *' indicates the deficiency was not reported in the June 29, 1990 letter.
_-_________-w
i
.3 TARLE 2 EXIDE DATA UPDATES UNIT 2 2 E-QDN F01 6 2 E-QDN-N01 01/03/90*
The inverter input breaker _ tripped af ter taking battery bank terminal voltage readings at 7 1/2 hours, 77 of an 8_. hour _ dis.pbarge_t. cst. Voltage readings were acceptable at that time. After 7 1/2 hours of discharge the batteries had low cicetrolyte specific gravity. Batteries were placed on equalize charge until electrolyte specific gravitics were acceptable, This condition would have prevented t.he UPS from b!'f"B I[ T 8_I'""Tb
'^
~ ~ ~ ~ ~ " ~
04/05/90*
Low electrolyte _ specific _ gravity was found after.an.8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> _ discharge.wak performed, and several attempts y
were required to restore the battery..This condition would have prevented the light from burn for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Bait.t' cries "werellac' d on equal"lio cluirge und~~
'~
e
~
electrolyte specific gravities were subsequently found acceptable.
06/03/90*
A fuse (FI) blew when reset button was depressed and the inverter shut down. This condition would have prevented t he UPS from burnliip,Tfor 8 hoira.~ Fuse' was t Q 1 Ace fhnd~the~ unit was restoredT ^(OEcu' red after r
l the cutoff date for the 6/29/90. letter,)
i i
I l
NOTE: * ** indicates the deficiency was not reported in the June 29, 1990 letter, i
~ __
j-3-
TABLE 2 EX1DE DATA UPDATES 2-E-QDN F02 6 2 E-QDN N02 12/04/89*
Low electrolyte specific gravity was found. This
..)^
condltlon yould have_ prevented th.e_ light _from_ burning,
)
for 8_ hours., Batteries were placed on equalize charge.
01/04/90*
Lew electrolyte _ specific _ gravity was found_after an 8._,
I ur discharge,,_and_several attempts were required to F.
jy restore the battery. Batteries were placed on equalize charge until electrolyte specific gravities were acceptable.This condition would have prevented the light f rom b'uriiling ~for' 8'houi s"
~ - ~ ~
~
03/21/90*
Lowelectroly[fundaftoran8hourdischarg te specific _ travity and,indhidual_ coll v1 s[w e
e test and
.,,y an excessive amount of recharging was required to the battery, Batteries were placed on equalize restore charge until electrolyte specific gravities and individual cell voltage's were acceptable..Th i s,,
condition would have prevented.the. light _ from burning' f[of8lh'osrs l.
i I:
l I
l i
I l
g NOTE: *** indicates the deficiency was not reported in the June 29, 1990 letter.
.. ~
s TAliLE 2 EXIDE DATA UPDATES UNIT 3 3-E-QDN F01 & 3 E-QDN N01 NO CitANGES 3 E-QDN F02 6 3 E-QDN-N02 08/03/89*
Elec trolyte_speci fic gravity _ was_. low af ter _an_8 hour
'3, d_ischarge was performed and several attempts were required to restore the battery. This. condition woulst have prevented the, light frora_ burning for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
15atterieswere placed on equalize charge until electrolyte specific gravities were acceptabic.
03/31/90*
Low electrolyte specific gravity and low individual cell voltage were found and an excessive amount of recharging was required to restore the battery.
This.
condition would have prevented the light from burning, for 8jlioursi liatteries were'placed on equalize charge until electrolyte specific gravities nnt individual cell voltages wore acceptable, i
i l
l l
l t
NOTE.
,dicates the deficiency was not reported in the June 29, 1990 letter.
TABLE 3 Il0LOPilANE DATA UPDATE we t$% i UNIT 1 1.E-QBN 001 12 27 89 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge was voluntarily terminated Jue to a faulty (12 27-89)-
ballast.
Evaluation indicates the inverter would have provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge if the test had not been tetiinated.
2 21-90.
BBTV was found to be below the minimum criteria. With this (2 21-90) condition this inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge. The successful 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge v'th an initial BBTV of 25.3 on WO 405060 demonstrates this ix<erter's capability.
1-E-QBN-002
['
2-28-87 Battery 3B did not meet the minimum IBV criteria. With this g
(1-7-88) one deficiency the inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
10 17-87*
One battery was found cracked and se.oking. With this condition the' inverter would not have been capabic of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
5-9-90*
It was determined the inverter was not capable of providing its intended function since the new batteries failed the post maintenance 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge test.
1-E-QBN 003 5-26-88*
Battery 2A appeared to be leaking.
This description was not (6-27-88) a problem and no action taken.
Discussion with the vendor on this issue is documented on WO 298166.
2-6-89*
BBTV did not meet minimum criteria.
The inverter would not have been capable of'providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
NOTE. '*' indicates the deficiency was not reported in the June 29, 1990 letter.
5 TABLE 3 110LOPilANE DATA UPDATE l E-QBN-004 1-9-87 Batteries 2A and 2B were isolated froin inverter because of (1-15 88) one battery being shorted.
This inverter would have continued to support an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> dit. charge based on the load and capacity study.
NOTE: '*' indicates the deficiency was not reported in the June 29, 1990 letter.
TABLE 3 110LOPilANE DATA UPDATE UNIT 2 2-E-QBN-001 1-3-89 Battery 3B did not meet the minimum IBV criteria.
With this (2-22-89) one deficiency the inverter is capable of providing an 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> discharge.
1-31-89*
Batteries 2B and 3B did not meet the minimum IBV criteria.
With two batteries in this condition, evaluation has-determined the inverter would not have provided an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
3 29 89*
After a successful 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge, the 1BVs on all batteries failed to meet minimum criteria within a reasonable period of time.
During this deficiency the inverter would not have provided an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
6 24 89 Battery 4B was found with a cracked post.
With electrical (8-15.-)
continuity still being maintained, the inverter would have continued to provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
2-E-QBN 002 9-9 87*
8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge failure due to a defective transfer relay.
The inverter was not capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
1-6-89 Battery 4B did not meet the minimum IBV criteria.
With this (2-15 89) one deficiency the inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
1-23-90 Battery 2B did not meet the minimum IBV criteria.
With this (4-18 90) one deficiency the inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
2-E-QBN 003 2 15-89 Battery termination on battery 4B indicated the bolt was (4 18-89) pulling through the terminal. With electrical continuity still being maintained, the inverter would have continued-to-provide an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
12-29-89 Battery 2B did not meet the minimum IBV criteria.
With this (3-13-90) one deficiency the inverter is capable of providing an 8
!!OTE: '** indicates the deficiency was not reported in the June 29, 1990 letter.
TMI.E 3 H014PilJE DATA UPDATE hour discharge.
3-16 90 New batteries provided an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge but battery 3B (3-17-90) did not meet the minimum IBV criteria corning out of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> charge. With this one deficiency the inves.ar is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
2-E-Q3N-004 9-7-87 Battery 4A did not meet the minirnum IBV criteria. With this (10 1-87) one deficiency the inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
6-4 89 Eattery 2A did not meet the minirnum IBV criteria. With this (6-4-89) one deficiency the inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
9-5-89 Battery 3A did '?.ot meet the minimwn IBV criteria.
With this (9-5-89) one deficiency the inverter is capabic of providing an 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> discharge.
12-29-89*
BBTV did not meet minimum criteria. This condition prevents the ii.verte-frorn providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge 5-11-90*
BBTV did not treet minimum criteria.
This tuudition prevents the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
I NOTE: '*' indicates the deficiency was not reported in the June 29, 1990 let ter.
1 TABLE 3 Il0LOPilANE DATA UPDATE UNIT 3 3 E-QBN-001 2-2-89 Battery 1A did not meet the minimum IBV criteria. With this (3-22-89) one deficiency the inverter is capable of providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> d!scharge.
3-E-QBN-002 2 5-88*
All batteries failed to meet the minimum IBV criteria.
The inverter would not have been capable of supporting an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> direharge.
3-E-QBN 003 5 8-89 BBTV was high because of a defective charging card.
This (5-11-89) condition does not impair the inverter from providing an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
5-3 90*
Failed an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge indicating the inverter cannot support an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge.
3-E-QBN 004 10 28-87 New transfer circuit was installed.
With a deficiency of (11-21-89) the transfer circuit the inverter would not support an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge, d
NOTE: **' indicates the deficiency was not reported in the June 29, 1990 letter.
t TABLE 4 EMERGI-LITE DATA UPDATES TAG NUMBER DATE EVALUATION lESTL74 COP 090 06 2/28/90 Although a work order was written against this component, the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge test was successful. The work order was not applicable to this component.
This would
-not have prevented the unit from burning for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
This was reported as a failure in the 06/29/90 letter.
1ESCL72A14 140 20 4/9/90*
Light bulb was broken. This_would_have-prevented the unit from_ burning for_8 hours.
~_
2ESTL74C09 110 07 3/8/90*
Lights stayed on after test switch was released. It was determined that the circuit would not provide illumination and maintain battery BBTV,.L.igt ts would not have burned for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
2ESTL74C09 140 09 9/7/89 The charging card was replaced due to the blinking of the.lghts following the completion of a PM. Pushing the test button stopped the blinking. The card was replaced as a preventive measure when trouble shooting could not duplicate the condition. This condition would not have prevented the lights from burning for eight hours. This event was reported as a failure in the 06/29/90 letter.
NOTE: '*' indicates the deficiency was not reported in the June 29, 1990 letter.
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PLEA 9E DELiVEM Tl4E FULLOWlNG PAGED toi NAME
__14.
440NG b
DEPT t JECT I i 1. Clit EF
- MRuluN V EXT t 3733 NAMEt_
Pato Verde Nuclear Generating 9tation (PVNOB)
Resident inspector's Of fice EXT t--(602) 39.6-3650 or 396-3638 BUBJECTt SCO M
9 PA 9
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total pages transmitted
-(Total thcludet this et$v5e page)
This message is being sent f rom a UF-600-PAHAFAX automatit machine, if there area any questions, pleast catt (602) 386-3650/3639.
Pato Vuede Nesident thspector's automatic fascimlit humber it (602) 306-2739.
4
- 9. FAX 007,7XT
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mwa e.a l
6 nt2 0tLA m a u e st:ImpacoMPANY t -
- _ entnGENcyLIgggNG INDEMENDMTRmWW
(
EXECUTIVE
SUMMARY
At the request of Arizona Public Servico Company, ABB Impell Corporation performet an independent review of the Pale Verde Nuclear Generating Station (PVNGS) emergency lighting system. In this rolo ABB Impell:
1)
Determined the NRC requirements applicable to the emergency light!ng
- system, 2)
Determined on a sample basis, whether APS work dono to dato meets the applicable requirements, 3)
Determined what selected other nuclear power plants are doing to meet requirements applicable to their emergency lighting systems, and 4)
Evelucted the emergency lighting concerns raised by the NRC in Inspection Report 90 02 and by the NRC or others subsequent to January 1,1990, and determined whether the APS discussion was responsive to those concerns.
ABB Impell reviewed the Code of Federal Regulations, NRC guidance documente, NRC Inspection Procedures, PVNGS Licensing documents and correspondenco,
[
Regulatory Commitmont Tracking (RCTS and RCTS2) output, design basis documents, and industry codes and standards to ascertain the NRC requirernents
(
applicable to the emergency lighting system.
ABB Impell performed a sample bs*ed review of the PVNGS emergency lighting system to determine whether work dono to date fulnlls the NRC requirements identified. The investigation by the ABB Impell review team was conducted in a manner similar to an NRC inspection. The depth of the review and the sampling methods (e.g. document review, physical verification or interview) were based upon the judgment and knowledge of the review team and were limited in scope to the NRC fire protection related requirements for omorgency lighting.
Conclusions drawn by ABB Impell are based solely on the review of PVNGS documentation, limited walkdowns and information supplied in meetings.
A survey of other nuclear power plants was conducted to determine what the industry la currently doing to meet requirementa applicable to emergency lighting systems.
Finally, ABB Impoll reviewed the concerns identified by the Nuclear Regulatory Commission in Inspection Report 90 02 and the subsequent concerns identiflod by the NRC and APS personnel to ascertain the source requirement / commitment for the concern and to determine if the APS discussion was responsive to the concerne.
l ABB ImpollNo. 0116581815 Revision 0
,. -. =..
m.o me r.e2 e
e g,mpOSEftVICE COMPANY EhUmOENCYL1GImNG INDaardaNr tEV)EW ABB Impellidentified four issues as a result of the review of NRC requironients and APS implementation. These issues were 1) Quality Asadrance Requirements,2) Design Adequacy,8) Li hting P ocement, and 4) Maintenance.
Those findings have also been identified APS through their internal review process. APS has indicated that the follo ng actions are to be completed:
PVNGS emergency lighting is now designated QAG consiblent with the Quality Assurance Criteria Manual. Plant procedur,os will be reviewed to ensure the QAO program is being thlly implemented.
Replacement of Holophane batteries is in progress. APS will obtain confirmatory vendor data from battery manufacturers which have not as yet provided necessary data.
The action plan identifled in CAR 90 014.
The preventivo maintenance program will be upgraded to ensure that !!ghts are properly aimed.
The utility survey identified a wide range of technical positions on emergency lighting; however, the following points are ofintercat:
Two of seven utilities produced evidence that temperatures other than 77' f(
had been considered in battery sir.ing.
Five of the seven utilitle contacted considered emergency lights part of their augmented quality program for fire protection.
Three of the eight utilities contacted regarding operability /reportability issues had some sort of compensatory measure for an out of service emergency light.
ABB Impell determlaed that the discussions developed by APS in response to the NRC and APS generated concerns, were generally responsive.
I l
Recommendations are provided for a number of the concerns.
In conclusion, APS has, over the years, identified the individual issues regarding i
emergency lighting at PVNGS. Corrective actions to address the identified issues I
focused on the immediate concerns with limited attention to the underlying i
.programmat c issues.
Rocont correctivo actions identified / reviewed during ABB Impell's independent evaluation appear to address the broader programmatic issues. In ABB Impell's opinion, these issues represent the source of the individual deficiencice.
1 1
Ii ABB Impell14.01-16581815 Revlalon o
tw m t.oo r.ua gJNA PuaunmmVICE COMPANY J }._tg ng M Q y M g [ g g INDTENDMTRMEW Completion of the APS correctives actions and the implementation of the ABB Impell recommendations in this report will estabilah a program for continued compliance with the fire protection emergency lighting requiroments.
t 4
p Ik iti ABBImpsilNo.0110631815 Revision 0
h mm-
. e..
g@NA PUBMONtVICECOMPANY I
((
DDULODiCYDGIfr!Ngg INDEPT.NDENTRBYUnY
[
5.0 Conclusion
(
As documented in this report ABB Impell performed en inkopendent review of the PVNGS emergency lighting system. In the course of this review ABB Impell found that the major issues regarding emergency lighting had boon formallyidentified by APS, Emergency Lighting Battery Sizing identified in LER 86 59 Emergency Oghting Placement identified in LER 8912-01 Emergency Lighting QA Classification -identified in APS Letter 167-02588 MFH/ JAB, dated July 25,1988 and in QA Audit Report 89 018 Emergency Lighting Maintenance in LER 86 50 and in internal APS Memo 191-00012 RRB, dated April 18,1987 i
Corrective actions to address the identifled issues focused on the immedia concern (s) with limited attention to the underlying programmatic issues.
Recent corrective actions identified / reviewed during ABB Impell's independent evaluation appear to address the broader prograrranatic issues.
In ABB Impell's opinion, these fasues represent the source of the individual
(
deficiencies.
Completion of the APS correctives actions and the implomontation of the ABB Impall recommendations in this report should establish a program for continued compliance with the fire protection amergiacy lighting requiroments.
- i.,
54 ABB !mpeu No. 0146584815' Reiston o
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