IR 05000528/1985002
| ML17298B946 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/11/1985 |
| From: | Miller L, Narbut P, Sorensen G, Sorensen R, Wagner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17298B945 | List: |
| References | |
| 50-528-85-02, 50-528-85-2, 50-529-85-02, 50-529-85-2, 50-530-85-02, 50-530-85-2, NUDOCS 8503130188 | |
| Download: ML17298B946 (16) | |
Text
U.S.
NUCLEAR REGULATORY COHHISSION
REGION V
Report Nos. 50-528/85-02, 50-529/85-02 and 50-530/85-02 Docket Nos. 50-528, 50-529 and 50-530 License No. NPF-34 Construction Permit Nos.
CPPR 142 and 143 Licensee:
Arizona Public Service Company P. 0.
Box 21666 Phoenix, Arizona 85036 Facility Name:
Palo Verde Nuclear Generating Station - Units 1, 2 and
Inspection at:
Palo Verde Site, Wintersburg, Arizona Inspection conducte
January 2 -25, 985 Inspectors:
R.
C Soren ct Inspector ner, cto nspector P.
P Narbut ro ect Inspector Approved by:
L.
. Hiller J
, Chief Reactor Projects Section
~Summar:
g-/t-Fs Date Signed z-//-5 Date Signed Q5 Date Signed Z.-lj-8'~
Date Signed Ins ection on Januar 21-25 1985 (Re ort Nos. 50-528/85-02 50-529/85-02 and 50-530/85-02 of IE Circulars, craft training (TI2512/11),
QA program surveillance responsibilities, and program directed inspection of operational staffing in Unit 2.
The inspection focused on Units 1, 2 and 3 and involved 94 inspector hours onsite by three NRC inspectors.
Results:
No violations or deviations were identified.
8503130188 Bg0P13 PDR ENDOW 0S000Sa8 PDR
Details 1.
Persons Contacted a.
Arizona Public Service Com an (APS)
"W AJ Al
"-C.
"R
"-R.
AJ D.
T.
S.
Ide, Director, Corporate gA/gC Allen, Operations Manager Zeringue, Technical Support Manager Russo, Manager, (}uality Systems
& Engineering Kimmel, Transition Representative Hamilton, equality Monitoring Supervisor Bloom, Licensing Engineer Smith, Compliance Engineer Hackbert, (}A Engineer White, Supervisor, equality Audits Penick, Supervisor, Document Review b.
Bechtel Power Cor oration (Bechtel)
"H S.
D.
Hawkinson, Project gA Manager Foster, Project (}C Engineer Nichols, Project Superintendent Hess, Document Control Supervisor
"Denotes those persons attending exit meeting, January 25, 1985.
The inspectors also talked with other licensee and contractor personnel during the inspection.
2.
0 erational Staffin of Unit 2 The inspector reviewed the qualifications of selected non-licensed plant personnel assigned to Unit 2, with respect to ANSI 3.1-1978, which governs these qualifications.,
ANSI 3.1-1978, which is a revision of ANSI N18.1-1971, is a Final Safety'nalysis Report (FSAR), commitment of APS.
It quantifies educational and work experience requirements for persons filling key positions in nuclear power plants.
First, the qualifications of'the Instrumentation and Control Technicians (IRC) Supervisor, Radiation Protection Supervisor, and Chemistry Supervisor were reviewed.
No deviations were identified, In addition, the qualifications of a sampling of Instrumentation and Control technicians,'aintenance mechanics, maintenance electricians, auxiliary operators and radiochemists were reviewed.
No deviations were identified.
However, the experience records of several individuals could not be readily located by the inspector, and still must be examined.
This will be carried as a followup item (50-529/85-02-01) until a future inspectio I
, R)
m I
l
3.
Craft Trainin (TI 2512/ll)
The inspector examined the area of craft training for construction craft at the Palo Verde site.
This was accomplished through review of applicable regulations, standards, and the licensee's implementing procedures and records.
Additionally, the inspector reviewed the initial results of a special investigative report (performed by the licensee)
to examine the training of construction crafts personnel.
a
~
~Back zonnd There are few specific regulatory requirements regarding general craft training.
While there are specific qualification requirements in codes and standards for certain special processes (such as welding or nondestructive examination),
there are no specific requirements for general crafts such as pipefitters, boilermakers and electricians.
One general requirement is contained in 10 CFR 50 Appendix B Criterion II, which requires that the quality assurance program provide for indoctrination and training of personnel
"as necessary to assure that suitable proficiency is achieved."
Since these requirements are not specific, the inspection philosophy generally has been to determine whether suitable craft proficiency had been achieved through an examination of the final product; i.e.
the hardware.
For those specific skills which require qualifications, (e.g. welding), the inspection program has examined those qualifications regularly.
For this inspection, the inspector did not reexamine the area of specific qualification requirements, but rather examined the area of general craft training.
2.
cindiaa The inspector determined that the licensee's system to assure that suitable proficiency is achieved by crafts primarily depended on the craft union to provide skilled journeymen, and on the (}uality Assurance (l}A) program to inspect the work (using Field Engineers and (}uality Control inspectors).
There has been very little training at Palo Verde to initially indoctrinate new craft journeymen.
They receive an initial briefing by construction management, and view a video tape by the APS Chief Executive Officer.
This initial session has provided the basic instructions that the achievement of quality was of the utmost concern at Palo Verde, and was fully supported by upper management.
The craft workers do not receive any initial specific training, but were instructed on specific "do's and don'ts",
and other requirements through on-the-job-training by their foreman and fellow craft workers.
Additionally, they received occasional, special, formal training in problem areas identified by construction management, the quality trending program, or formal gA audit results.
The inspector determined that neither the craft, their foreman or the general foreman were required to read applicable work
t
procedures.
Their knowledge of procedure requirements was achieved informally through verbal instruction and experience.
Likewise, the craft superintendents, although required to read the work procedures, were not required to read the specifications which, in some cases, had additional requirements.
(Field Engineers were held responsible for procedural knowledge, however).
yl The inspector informed licensee management at the Exit Interview that the lack of reading assignments for craft workers (at the foreman level and above)
was considered abnormally weak compared to other construction sites.
The inspector reviewed the records for craft superintendents'eading lists.
The Unit 3 Superintendents were selected as a
sample.
All superintendents had records on file of having completed their reading assignments.
The inspector reviewed the licensee's initial investigative report on craft training, (}A Document 84-CA-331, dated December 17, 1984.
The inspector noted at the Exit Interview that, although the report. had a stated goal to evaluate the effectiveness of the craft training program, the report lacked recommendations to management for improvements.
The report concluded that the requirements were met, and identified no deficiencies.
The report was addressed to the Corporate (}A/QC Manager.
At the exit interview, the Corporate gA/QC Manager stated he had received and reviewed the report and was not satisfied with it.
He stated he would order further investigation to determine if craft personnel were, in fact, knowledgeable of requirements.
He stated he was not concerned whether they achieved their knowledge through formal training or informal training provided that they were, in fact, knowledgeable of requirements.
Conclusion The inspector found that there was very little formal craft training required at Palo Verde.
However, in field discussions with craft workers during the conduct of previous construction hardware inspections, the inspectors have found these personnel to generally be knowledgeable of requirements.
By virtue of hardware inspections, the inspectors have concluded that craft persons were suitably proficient at their craft.
No further examination of this area is considered warranted at this time, based on the licensee's planned action to perform further assessments of craft proficiency and knowledge of requirements, and based on the lack of specific requirements for craft training.
This section of TI2512/ll, "QA Initiatives", is closed.
No violations or deviations were identifie I
\\
4.
Surveillance of Contractor QA/
C Activities a
~
The inspector reviewed the licensee's implementation of their Quality Assurance Program responsibilities relating to surveillance of contractors.
The following Quality Assurance Department Procedures (QADP's) prescribed the licensee plans and activities relating to the attainment of overall contractor surveillance objectives; this included scheduling, planning, conducting, and documenting auditing and monitoring activities:
(1)
QADP 18.0, Revision 3 of May 6, 1984, "Quality Auditing" (2)
QADP 18.1, Revision 1 of August 27, 1984, "Quality Auditing" (3)
QADP 16.1, Revision 1 of May 6, 1984, "Corrective Actions" The inspector reviewed the audit schedule for 1984 which addressed the full scope of the QA Program elements.
All audits were accomplished as scheduled.
b.
Pro ram Im lementation Date (1984)
The following audit reports were reviewed for evidence of implementation in accordance with the Quality Assurance Program procedures (QADP's):
Audit No.
Activit Audited 84-002 84-015 84-016 Subcont'ractor/Vendor Control March 8-April 13 Test Control August 16-September
Training 6 Qualifications July 5-19 84-028 3echtel-Jobsite Activities October 17-November
84-032 Bechtel-Norwalk November 12-16 Review of the records associated with these audits indicated that the audit team sizes were adequate for the activities being audited, the audit team members included assigned specialists, all auditors were properly qualified, and the audit checklists were completed.
Documentation of audit findings included the use of Corrective Action Reports (CAR's), Quality Assurance Observations (QAO's) and Management Corrective Action Reports (M-CAR's).
For the audits selected during this inspection, eight CAR's, four QAO's and one M-CAR were reviewed for evidence that the findings were reported to upper management.
The inspector was satisfied that not only were these audit findings reported to corporate management, but management aggressively provided 'the necessary degree of attention to assure prompt action by the responsible contractor.
All audit findings received the necessary followup by the Quality Assurance
L II,
Department to assure, that the corrective actions were properly implemented.
The majority of contractor surveillance was performed by the equality Monitoring Group.
The monitoring activities were performed in accordance with a monthly schedule; unscheduled monitoring activities were also performed, as needed, to support project quality requirements.
The following monitoring reports were reviewed by the inspector to assure that monitoring activities were performed in compliance with gADP 18.1:
Monitoring Date Department
R~e ort No.
Performed Activit Monitored SM-84-0431 10/23/84 Bechtel-Hanger Installation Unit 3 SM-84-0537 12/19/84 Bechtel-Weld Rod Room SM-84-0535 12/15,18, Viking Fire Protection Subcontract 19/84 SM-84-0503 12/1/84 Combustion Engineering Unit 2 RCP Disassembly SM-84-0287 8/23/84 Bechtel-Cable Pulling SM-84-384 9/29/84 Bechtel-Pipe 8 Valve Installation (Primary)
SM-84-0186 7/31/84 Bechtel-Raceway Installation SM-84-0314 8/25/84 Bechtel Unit 1, RCP-2B Zurn coupling bolts/nuts replacement SM-84-0354 9/12/84 BISCO SM-84-0228 8/10/84 Bechtel-Field Nondestructive Examination SM-84-0124 7/6/84 Combustion Engineering-Mechanical Equipment SM-84-0159 7/24/84 Bechtel-Piping 8 Valve Installation (Nonprimary)
The inspector verified that personnel assigned to perform these monitoring activities were qualified and certified as auditors in accordance with gADP 18.0.
A monitoring checklist was used by the monitor when reviewing objective evidence or observing in-process activities.
The results of these monitoring activities performed by the banality Audits and Monitoring Department were issued monthly to management.
The inspector reviewed the report for December 1984, issued January 9,
1985, (}A Document No. A-85-011-CNR.
This report was addressed to the Director, Corporate equality Assurance and provided a quick review of monitoring result During this inspection, the inspector was aware of a past weakness in the licensee,QA Program.
The NRC Region V SALP Report for the period March 1, 1983 to March 31, 1984 had pointed out that not enough emphasis was placed on, QA surveillance of hardware.
The licensee responded
'by committing, to put more emphasis on surveillance of hardware installation.
Therefore, the inspector looked for objective evidence that surveillance activities performed by the Quality Audits and Monitoring Department included hardware.
The following documents 'indicate that the. licensee has satisfactorily met their commitment in this area:
(1)
Monitorin Re ort No. MD-84-050 erformed 10/15/84 to ll/26/84.
This monitoring activity was to verify whether or not commitments made in response to the SALP Report were satisfied.
The report stated that Bechtel's daily surveillances had focused more on hardware, and that the licensee monitoring group monthly schedule and the prewritten checklists required increased hardware checks.
This was also verified by the inspector during review of the monitoring reports.
(2)
Monitorin Re ort No. MD-85-20 erformed 1/16/85.
The report states that Bechtel has increased their surveillance efforts for HVAC and fire protection, and that more detailed and hardware oriented checklists were issued for use in fire protection audits.
(3)
Bechtel Pro ect A Audit Re ort dated 1/8/85 File No. UA-S-84-5
.
This was an unscheduled audit conducted jointly by the licensee and Bechtel QA organizations on 11/28/84 through 12/21/84.
This audit was hardware oriented and was performed on portions of the Low Pressure Safety Injection System (LPSI).
(4)
Procedure Chan e Notice (PCN) No. 84-11 of 12/4/84.
PCN No.
84-11 was issued to revise QADP No. 18.0 "Quality Auditing,"
making it a requirement to "tie an audit to hardware".
(5)
Monitorin Checklist'..
The inspector reviewed the prewritten checklists used for the monitoring activities inspected during this audit and found that all the checklists contained an item for hardware surveillance.
For example, Checklist No. N-5, Revision 0 of 5/18/84 item 2 states
"Verify that the piping/valve installation configuration conforms to the project drawings."
The inspector concluded that the licensee has a strong Quality Assurance Program in the area of"QA surveillance activities.
No violations or deviations were identifie \\
II l"
tlI
5.
Review of Licensee Res onses to Circulars (Closed) Circular 79-21 Prevention of Un lanned Releases of Radioactivit Previous Ins ection The licensee responded to all aspects of this Circular except for the recommendation to hydrostatically test new permanent and temporary systems that could cause an inadvertent release.
This Ins ection The inspector verified that the licensee plans to leak test any modifications to liquid radwaste piping in accordance with ANSI 8 31.1-1980 which has been committed to in the FSAR.
The affected portion of the system will be leak tested prior to first use.
This completes the licensee's response to this Circular.
The inspector found the response acceptable, and this item is closed for Units 1, 2 and 3.
6.
An Exit Heeting was conducted with the licensee personnel indicated in Paragraph 1 on January 5, 1985.
The scope and findings of the inspection as described in this report were discusse,