ML17296A815
| ML17296A815 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/24/1980 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML17296A814 | List: |
| References | |
| ANPP-15714-JAR, NUDOCS 8007210546 | |
| Download: ML17296A815 (3) | |
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'JJ IFtUIE3EaII(Q P. O. BOX 2I666 PHOENIX) ARIZONA 65036 June 24, 1980 ANPP-15714-JAR U. S. Nuclear Regulatory Commission Region V Walnut Creek Plaza Suite 202 1990 North'alifornia Boulevard Walnut Creek, California 94596 Attention:
Mr. G.
S.
- Spencer, Chief Reactor Construction and Engineering Support Branch
Subject:
NRC I&E Inspection of April 15-18, 1980 File:
80-019-026
Dear Sir:
This letter refers to the Inspection conducted by Messrs.
J.
H. Eckhardt, G. Hernandez and P. V. Joukoff on April 15-18,
- 1980, as documented in your letter of May 23, 1980, of activities authorized by the Nuclear Regulatory Commission (NRC) Construction Permit Nos.
CPPR-141, 142 and 143.
During this Inspection, one (1) item of noncompliance was identified.
Our response to this'tem of noncompliance (Deficiency) is presented in the enclosed Attachment A.
Very truly yours, EEVBJr/JAR:skc Attachment E. E. Van Brunt, APS Vice President Nuclear Projects ANPP Project Director CC:
D.
Bo R. L.
J.
M.
A. C.
B. S.
W. E.
A.
C.
i W. H.
W. J.
J.
E.
R.
M.
D.
R.
Fasnacht Robb Allen Rogers Kaplan Ide Gehr Wilson Stubblefield Bashore Grant Hawkinson 800~><0
APPENDIX A
Docket Nos.
50-528 529 Construction Permit Nos.
CPPR-141 142 Notice of Violation Based on the results of the NRC Inspection conducted on April 15-18, 1980, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC Construction Permit Nos.
CPPR-141 and 142, as indicated below:
Paragraph (2), states that, "The holder of a Construction Permit shall within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notify the appropriate Nuclear Regulatory Commission Inspection ciency."
Additionally, 10CFR50.55(e),
Paragraph (3),
states
- that, "The holder of a Construction Permit shall also submit a written report on a reportable deficiency within thirty (30) days to the appropriate NRC Regional Office...."
Contrary to the above, on February 7, 1980, you.notified the NRC Inspection and Enforcement Regional Office Resi-dent Inspector at Palo Verde that a otentiall re ort-able deficiency had been identified wherein a visual examination was specified and performed on certain Class 3 pipe welds rather than magnetic particle, liquid penetrant or radiographic testing as required by the governing Section IIIof the ASHE Boiler and gional Office on April 10, 1980, which was not within the required thirty (30) day reporting period.
This is a Deficiency.
~Res onsa It appears that this deficiency is more of a misunderstanding than an actual omission on our part of not reporting a reportable condition of 10CFR50.55(e).
Arizona Public Service Company (APS) informed the Resident Inspector on February 7,
1980 of the deficiencies discovered in our inspection procedures at Palo Verde.
Arizona Public Service Company informed the Resident Inspector and Inspectors from Region V
Appendix A Notice of Violation Page 2
that this si.tuation was a "potentially reportable deficiency",
meaning that we were not sure that this deficiency "which were it to have remained uncorrected, could have affected adversely the safety of the operation of the nuclear power plant....",
as stated in (1) of 10CFR50.55(e).
This action was taken to inform you of a "potential reportable condition", but we did not have sufficient information to make a definite statement at that time as to the affect of the deficiency on the safety of the operation of the plant.
Because we recognized that these investigations sometimes take months to determine the actual affect of a deficiency, a Deficiency Evaluation Report (DER) was issued by Bechtel on'March 27, 1980 and APS issued a Possible 50.55(e)
Reportable Condition to NRC, Region V, dated April 10, 1980.
Paragraph IV, Anal sis of Safet this deficiency cannot be fully evaluated until the results of our reinspection of these welds are available.
These results will then be evaluated as to the defects potential affect on the safety performance of the piping system 'involved."
In addition, as was discussed with your Inspectors during their Inspection of January 21-25,
- 1980, we felt that because of the long investigation time required to evaluate some DER's, Arizona Public Service Company was revising its internal procedures to require that upon the issuance of a DER, a decision would be made within fourteen (14) days as to the potentiality of the deficiency.
If this deficiency was determined to be reportable or potentially reportable, we would notify'NRC and issue a report within thirty (30) days, even if we could not determine the affect of the defi-ciency on the safety of the operation of the plant.,
Subsequently, NRC Guidance on 10CFR50.55(e)
Condition Deficiency Reporting, dated April 1; '1980;.was received by APS on Hay 13,.1980, essentially agreeing with the actions already taken by APS.
These procedures have been and are in use at this time.
The results of the investigation of this "potentially reportable deficiency" has now been completed.
Bechtel has reinspected the 201 field welds in question and found 'three minor surface repair-able indications.
These have been repaired and our final report of our Possible 50.55(e) Reportable Condition relating to the inspection of ASHE Section III, Class 3, Piping System fields, dated April 10, 1980, will be issued to NRC indicating these results.
Therefore, it appears that this Notice of Violation, a Deficiency, is more of a misunderstanding than an actual omission on our part of not reporting a reportable condition of 10CFR50.55(e).