ML17298B478
| ML17298B478 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/18/1984 |
| From: | Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| Shared Package | |
| ML17298B479 | List: |
| References | |
| NUDOCS 8411090133 | |
| Download: ML17298B478 (14) | |
See also: IR 05000528/1984038
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION V
1450 MARIALANE,SUITE 210
WALNUTCREEK, CALIFORNIA94596
Docket No. 50-528
Arizona Public Service
Company
P.
O. Box 21666
Phoenix,
Arizona 85036
"Attention:
Mr. E. E.
Van Brunt, Jr., Vice President
Nuclear Production
Gentlemen:
Subject:
NRC Inspection of Palo Verde Unit
1
k
This refers to the'special
team inspection
conducted
by Region
V on August 27
thru September
15,
1984, of activities authorized
by NRC Construction Permit
No.
CPPR-141,
and to the discussion of our findings held by Region V with
Mr. Donald Karner and other members of your staff at the conclusion of the
inspection.
Areas
examined during this inspection are described in the enclosed
inspection
report.
Within these
areas,
the inspection consisted of selective
examinations of procedures
and representative
records,
interviews with
personnel,
and observations
by the inspectors.
The staff conducted
a Construction Appraisal Inspection between
September
6
and November
1,
1983.
That inspection concentrated
on hardware
and
was
intended to assess
the quality of Unit
1 construction.
As indicated in
Inspection Report No. 50-528/83-
there were indications of weakness
in
quality assurance
and/or
a lac
of management
control by the
APS Operations
and Startup
Groups.
This inspection
was intended to assess,
primarily, whether the Startup
Organization
was accomplishing their activities in accordance
with quality
requirements
and established
procedural controls.
The interfaces
between the
Startup,
Construction
and Operations
groups were, likewise, examined.
These
examinations
were conducted to assess
whether
APS actions to increase
the
level of management
control, taken
as
a result of the Construction Assessment
Inspection,
were effective.
Accordingly, the method used in this inspection
was to select
a safety-related
system for vigorous in-depth examination.
This approach further required that
the system be of high safety significance
and generally representative
of the
'ork
controls, procedures,
documentation,
and methodology of system
organizational responsibility turnover and testing,
applied to other
safety-related
system work performed at the Palo Verde Nuclear Generating
Station.
In keeping with these criteria, the Auxiliary Feedwater
System
was
selected for extensive
examination.
The low Pressure
Safety Injection System
was also examined using
a reduced inspection
scope.
841i09QI33 84iQ18
ADOCK 05000528
8
~ ~
~ The team's
approach
was to direct 90 percent of its effort on work controls,
I
test results, test results evaluations
and quality assurance
applied to the
system
(AFWS) while this system is/was under the control
of the Startup
Group.
This included the licensee's
control of technical work
and an in-depth examination of a large number of elements
related to this
system,
including:
application of QA/QC; component testing;
maintenance;
resolution of NCR's and CAR's; evaluation of test procedures;
evaluation of
testing; evaluation of test results;
and other.
The remaining
10 percent of
the team's effort was focused
on inspection of other important areas,
including AFW support
systems
and the
QA/QC program for operations.
Overall Conclusions
r ~
The team found the startup work controls associated
with maintenance
and
testing activities to be generally satisfactory.
Although some weaknesses
were identified, the
teamL concluded,
with consideration
given to recent
regional
and resident inspection findings as well, that the corrective actions
implemented
by APS as
a result of findings from the
NRC Construction
Assessment
Team Inspection
(NRC Inspection Report 50-528/83-34)
and internal
audits appear to have been effective in assuring
adequate
control of quality
related activities under startup jurisdiction.
The implementation status of
the operations quality assurance
and quality control program readiness,
for
the operational
phase
was also reviewed
and considered satisfactory.
It was
noted during the inspection that
a significant amount of work remains in
prioritizing, tracking and dispositioning punch list items prior to fuel load.
Areas Ins ected
and Results
A.
Desi n Control for and
Im lementation of Modifications to the
AFWS
Engineering design activities reviewed were those
done at the site.
- These consist primarily of design for modifications
and changes
to the
AFWS system which resulted
from problems that were found during
. acceptance
walkdowns
and startup testing of the system.
The inspection objectives in this area
were to assess
the effectiveness
of administrative controls, including those governing the accomplishment
of startup
phase modifications
and changes
to the auxiliary feedwater
system.
To accomplish
these objectives,
the inspector evaluated
the licensee's
design control procedures
for conformance with regulatory requirements,
examined selected
design process
documents,
field inspected certain
modifications
and changes
to the
AFWS for conformance to applicable
design drawings,
conducted
a walk-down of the
AFW system to assess
as-built condition/drawing configuration conformance,
reviewed
QC records
relating to modifications of the system,
and examined applicable
inspector qualification records.
The inspector
concluded that the licensee's
system for design control and
accomplishment of modifications
and
changes
to the
AFW system,,under
the
jurisdiction of startup test group, functioned to effectively accomplish
these objectives.
j
In the area of engineer training,
an inspector identified
a particularly
disconcerting situation.
The inspector
found that 30 out of 160 Bechtel
project engineers
did not have training records to substantiate
compliance with a requirement to complete certain project specific
training within 60 days of assignment
to the project staff.
This was
compounded
by the inspector's
finding that this situation had been
previously identified by Bechtel
and documented in an Interoffice
Memorandum,
dated October
18,
1983.
Apparently, Bechtel
had not promptly
brought this situation to the attention of the licensee's
management
.and
gA organization,
or to sufficiently senior levels in the Bechtel
organization, with the end result that the situation
was still not
resolved,
almost eleven months later.
Discussions with several
Bechtel
engineers
indicated that all were experienced
engineers,
assigned
to the
Palo Verde Project from other Bechtel projects.
All were trained in and
familiar with the standard
Bechtel engineering
systems
and criteria but
some
had not completed the
APS required project specific training.
This
is an apparent violation of regulatory requirements.
Licensin
Commitment and
0 en Items Trackin
S stem
The licensee's
administrative control systems
programs
used to identify,
assign
closure responsibility,
and maintain status of open items
and
commitments to the NRC, requiring resolution prior to the issuance
of an
operating license,
were reviewed.
The team found that, while APS appeared
to be accomplishing
these
activities, the development of the administrative control program
description
and sub-tier implementing procedures
had not been
completed
and issued.
The licensee
agreed to expeditiously prepare
the necessary
program documents
and procedures.
The above finding is viewed as
an indicator of a less
than desirable
degree of management
attention because
without an administrative control
system
(1) the duties
and responsibilities of certain job functions are
not defined;
(2) the criteria for additions to the Unit
1 Punch List are
not defined;
(3) the criteria used to prioritize Punch List items are not
defined.
This lack of firm definition may result in inconsistent
updating of the Punch List and inconsistent
completion prioritization
assignments
because
the duties
and responsibilities of job functions, in
this area,
were not clearly defined.
Measurin
and Test
E ui ment
Aspects of the quality assurance
program for control of Measuring
and
Test Equipment
(MME) were reviewed.
Areas
reviewed included work
controls for performance of MME calibrations,
control of MME in the
field, method of recalling and controlling MME in need of calibration,
calibration records,
evaluation of calibration data,
issuance
of out of
tolerance notices
and evaluation of impact of out of tolerance
conditions
on tested
equipment.
No violations of NRC requirements
were identified.
However,
weaknesses
in the administrative controls for calibration of
MME done in accordance
with a manufacturer's
specification or vendor's
manual
and the evaluation of out of tolerance notices
were found to
exist.
The licensee
committed to take corrective action in these
areas.
(
Surveillance Testin
and Calibration Control
Aspects of the program for ensuring accomplishment of required technical
specification surveillances
were reviewed.
Areas reviewed included:
the
assignment
of responsibility for performance of surveillances;
the system
for scheduling
and tracking surveillances;
and the means of accomplishing
surveillances
and method of reviewing results of surveillances.
No
violations of NRC requirements
were identified.
The inspector did identify three problems requiring attention:
(a) use of
the plant computer for performance of certain Technical Specification
required safety-related
channel
checks in lieu of using available
qualified plant instrumentation,
(b) the lack of a preventative
maintenance
program for mechanical
and (c) the status of
procedure verification of surveillance test implementing procedures.
These problem areas
Must be functional prior to plant operations.
Review
of surveillance test implementing procedures
is planned for future
inspection activity.
Maintenance
Performed
on the
AFWS
The inspector
reviewed
a sample of maintenance
actions performed
on the
AFWS while the system is under control of the Startup
Group.
The work
packages
were reviewed for technical
adequacy,
proper review and
approval, proper equipment classification,
and proper initiation,
disposition and documentation.
The packages
examined
appeared
adequate
in the above areas.
Thermal Ex ansion Testin
of AFWS
The thermal expansion testing program for the
AFWS was
examined to
determine
the adequacy of performed testing
and test results.
The test
procedure,
test guideline
and test results
were reviewed
and discussed
with licensee
representatives.
No discrepancies
were identified.
Desi n Chan
es
and Modifications durin
Plant 0 erations
The inspectors
reviewed the operations quality assurance
program relating
to the control of design
changes
and modifications for those activities,
which will commence after plant operations
begins.
This review verified
that the program contained provisions for control of design
and
modification requests;
that procedures
and responsibilities for design
control were established;
and 'that administrative controls were
established
for design
document control and records collection and
storage.
The program also est'ablished
methods for assuring that the
proposed
changes
do not involve an unreviewed safety question;
and that
these
changes
are reported to 'the
NRC in accordance
with 10 CFR 50.59.
Proper implementation of the program
was not verified during this
inspection since
no safety-related
design
change
or modification record
packages
have been turned over to APS by Bechtel.
i
V
0
Startu
Work Controls
and
S stem Testin
The inspection of startup work controls
and system testing
was
a
concentrated effort directed to assessing:
work control; test results;
the effectiveness
of the licensee's
test results
review;
and test
conduct.
The effort was directed
toward two systems;
and low pressure
safety injection.
To this end
an in-depth examination
(essentially
a
100 percent
sample)
was conducted of: system maintenance;
component testing; resolution of SFRs,
NCRs and
CARs; evaluation of gest
procedures;
evaluation of test activities and evaluation of Test Working
Group activities.
The inspector
concluded that sufficient work controls
exist to effectively control startup work activity and test conduct.
Document
and Records
Control durin
Plant 0 erations
Inspection in this area
involved review of documents
and records control
procedures
applicable to the operations
phase.
Licensee
document,
and
records control programs
were evaluated for compliance with implementing
procedures
and licensee
commitment to ANSI N45.2.9-1974
"Requirements for
Collection, Storage,
and Maintenance of (}uality Assurance
Records for
Nuclear Power Plants."
Licensee
record keeping controls evaluated
included quality related record transfer,
storage,
receipt, withdrawal
safekeeping,
and audits.
Controls over issuance
and distribution of
station procedures,
Technical Specifications,
Final Safety Analysis
Report,
and design
documents
were also evaluated.
This inspection identified
a minor problem with licensee
control over
design documents,
in that two Piping and Instrumentation
Diagrams
were
found to be missing
a total of three Design
Change Notices.
The total
sample size
was
376 checkpoints,
of which three were found deficient.
This is considered
to be an unresolved
item.
Startu
Field Re orts and Nonconformance
Re orts
The licensee's
administrative
programs for control and disposition of
startup field reports
(SFRs), startup
nonconformance
reports
(SFR/NCRs),
and
APS nonconformance
reports
(NCRs) issued against
the auxiliary feed
water system
(AFWS) installation in Unit 1, were examined to assess
the
effectiveness
of the startup test group in maintaining the quality of the
AFWS while under startup control.
All available applicable
SFRs,
SFR/NCRs
and
NCRs were examined
and no violations of NRC requirements
were identified.
However,
some documentation
weaknesses
were identified
in the
SFRs,
SFR/NCRs
and
NCRs. dated in 1983 prior to the
CAT inspection,
the
APS audit and the
APS preoperational
testing "Stop Work Order.",
No
documentation
problems
were identified since testing
was
resumed in March
1984.
A/
C Administrative Controls
and Audits
The inspector
reviewed the procedures
specifying requirements
for
administrative controls
and audits to ascertain
whether established
programs
conformed to applicable regulatory requirements
and commitments.
The inspector also reviewed completed audit packages
to determine
the
degree of program implementation.
The inspector
concluded that the
V
.
administrative control and audit programs
were adequate
and, further,
that the audit program was being implemented properly.
L.
Maintenance
The inspector
reviewed numerous Station Manual Procedures
for maintenance
and maintenance
training to ascertain
whether:
(1)
a maintenance
program
had been developed for corrective
and preventive maintenance;
and (2)
personnel
performing the maintenance activities were adequately
qualified.
The inspector
concluded that the maintenance
program appeared
adequa'te.
Even though there is an absence
of regulatory requirements
in this area,
an apparent
weakness
was identified in the program for maintenance
personnel training and qualification.
The licensee's
practice
has been
to hire only journeyman crafts-persons;
however,
the system by which the
licensee
examines
and selects
those qualified for employment
has not been
fully proceduralized.
Further,
the licensee's
practices
regarding the
determination of the need for and providing of necessary
training,
following employment,
and the criteria used to establish
when
a
crafts-person is fully qualified to perform their job functions
has not
been fully proceduralized.
The licensee
agreed
to proceduralize
the
basis for qualifications of maintenance
personnel.
M.
Inde endent
Ins ection
(1)
Audit Review
During review of the licensee's
audits of Bechtel's onsite design
activities the inspector noted that
a licensee's
finding indicated
that Bechtel apparently did not update their design criteria to
comply with Regulatory
Guide 1.143 to reflect a licensee
commitment.
The licensee
stated that they complied with the regulatory guide in
May 1981, through Amendment No.
4 to the
FSAR.
The regulatory guide
requires certain technical
and quality assurance
requirements
be
established
for the Radwaste
and Steam Generator
Blowdown Systems.
This issue
has
been referred to NRR for evaluation
and resolution of
the degree of licensee
compliance with the commitment.
(2)
Worker Interviews
During the course of the 'inspection,
50 interviews of both APS and
Bechtel personnel
were conducted.
The primary objective of these
interviews
was to assess
.communications
between workers
and
management.
Personnel
interviewed included craft workers, quality
assurance/quality
control inspectors,
and first level supervisors,
including engineers.
The interviewees
indicated that they have not
felt intimidated,
harassed
or in any way restricted in the
performance
of their jobs.
Two individuals, however,
acknowledged
that there
was
a high degree of schedular
pressure
and mandatory
overtime requirements.
Even so, these
persons
did not feel that
these pressures
had caused
improper quality situations.
These
~
v
I
,
issues
were already
known to the
NRC and
APS and will be reviewed
during subsequent
NRC inspection activities.
An area of potential concern dealt with the thoroughness
of
training, both general administrative
and maintenance-related.
This
area will also be evaluated
during
a subsequent
inspection.
Based
on the results of this inspection, it appears
that one of your
activities
was not conducted in full compliance with NRC requirements,
as set
forth in the Notice of Violation, enclosed
herewith as Appendix A.
Your
response
to this notice is to be submitted in accordance
with the provisions
of 10 CFR 2.201
as stated in Appendix A, Notice of Violation.
Xn addition,
please
address
your plans for evaluating
and resolving the identified areas
of
perceived
weakness.
Xn accordance
with 10 CFR 2.790(a),
a copy of this letter and the enclosure
will be placed in the
NRC Public Document
Room.
Should you have any questions
concerning this inspection,
we would be pleased
to discuss
them with you.
Sincerely,
Enclosures:
A.
B.
Inspection Report
No. 50-528/84-38
T. W.,Bishop, Director
Division of Reactor Safety
and Projects
CC:
J.
Bynum, Director, Nuclear Operations
R. Frost,
Supervisor
T. D. Shriver,
Manager
W. E.
Xde, Manager,
Corporate
gA/gC
C. N. Russo,
Manager,
gA Audits
Ms. Jill Morrison
Iynne Bernabei,
GAP
Arthur C. Gehr,
Esq.
bcc:
RSB/Document Control Desk
(RIDS)
Mr. Martin
Resident Inspector
(2)
Project Xnspector
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