ML17298B481
| ML17298B481 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/16/1984 |
| From: | Ball J, Burdoin J, Clark C, Fiorelli G, Grayson M, Hernandez G, Ivey K, Johnston G, Kellund G, Kirsch D, Wagner W, Thomas Young, Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17298B479 | List: |
| References | |
| 50-528-84-38, NUDOCS 8411090146 | |
| Download: ML17298B481 (68) | |
See also: IR 05000528/1984038
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-528/84-38
Docket No.
50-528
License
No.
CPPR-141
Licensee:
Arizona Public Service
Company
P.
O. Box 21666
Phoenix, Arizona 85036
Facility Name:
Palo Verde Nuclear Generating Station - Unit
1
Inspection at;
Palo Verde Construction Site, Mintersburg, Arizona
inspection
conducted:
August
2
thru September
15,
1984
Inspectors:
R.
immerm
, Senior
(Team Le
ent
ngineer
/~-/~-8'P
Date Signed
d-/Z- F
, Reactor Inspector
K.- vey, Reactor
Insp
r
G. 'John ton,
si
t Insp ctor, Trojan
G. Fiore
,
Re
d t Insp ctor
.C
G.
. Kellund,
eactor Inspector
Date Signed
/0-lZ-fF
Date Signed
Date Signed
JO-rQ-8/
Date Signed
/c -/s-~)
Date Signed
/a-e-r'P
Date Signed
/u /p-R
. Clark
React
Ins
or
Date Signe
5 . Grayson
84ii090i4b05000528
g~iOi~
@gal
QQOCW
p9
8
adiat
n
eciali t
/o-/ -$"
Date Signed
t
l"
l
R
I
J
t'I
1
a
ll
I
4
i
J
-2-
G. Her
ndez, s't In
ector
Da
e
S gn d
W. J
agner,
eactor Inspector
)6 /
Da
S gned
Reviewed By:
. Young r., Chi
,
E
neering Section
Da
e
igned
Approved By:
D. P. Kir c
, Chief
Reactor Projects
Branch
D
e
igned
Summary:
Ins ection durin
the
eriod of Au ust
27 thru Se tember
15
1984
Re ort No. 50-528/84-38
Areas Ins ected:
A special,
unannounced
team inspection of design,
modifications, testing,
maintenance,
documents
and records,
and
QA/QC
activities for the startup of the auxiliary feedwater
system
(AFWS).
The team assessed
the licensees
effectiveness
in the areas of work
documentation,
and methodology of system organizational responsibility
turnover and testing.
The inspection involved 819 inspector hours by 13 NRC
inspectors.
Results:
Of the areas
examined,
one violation .was identified in the area of
project engineer training (paragraph
20.A).
i
II
I
DETAILS
1.
Persons
Contacted
A.
Arizona Public Service
Com an
(APS)
V.
J.
D.
"C.
J.
G.
F
D.
C.
R.
D.
IjT.
A.
D.
J.
IJ
J.
J.
T.
G.
L.
W.
M.
W.
S.
-<e.
,S.
R.
-j)W.
L.
A.
W.
R.
"<lQ.
~'R.
'W
R.
"R.
N"-D.
VJ
Rhodes,
Supervisor,
Drawing and Document Control
Flommerfelett, Nuclear Records Analyst
Rhodes, As-Built Records
Manager
Russo,
Quality Audits Monitoring Manager
Brantley, Supervisor, Discipline Test Schedule
Control Group
Smith, Startup-Information Center Supervisor
Hicks, Training Manager
Deruiter, Maintenance
Planner/Coordinator
Braun, Principle Startup Engineer,
AFWS
Becken,
Startup
Group Supervisor
Wittas, Quality Engineering Supervisor
(Mechanical)
Shriver, Quality Systems/Engineering
Manager
Ramey, Quality Systems
Supervisor
Webster,
Iead Auditor
Tills, Supervisor for Maintenance
Engineers
Minnicks, IRC Superintendent
Stout, Mechanical Superintendent
Terry, Electrical Work Group Supervisor
Robb, Acting Supervisor,
Maintenance
Support Section
(MCC)
Olson, Electrical Maintenance
Supervisor
Curr, Surveillance Control Group Supervisor
Simko, Engineering
Group Supervisor
Keubassion,
OPS Engineering Section XI Pump and Valve Operability
Program
Roman,
OPS Engineering Containment,
Mechanical Maintenance
Program
Callahan,
Operations Shift Supervisor
Nelson,
Maintenance
Manager
Penick, Supervisor,
QA Auditing Group
Badsgard,
Vice Chairman
TWG
~
Xde, Corporate Quality Assurance/Quality
Control Manager
Souza, Assistant, Corporate Quality Assurance/Quality
Control
Manager'ogers,Manager of Nuclear Operations
Quinn, Manager of Nuclear Licensing
Ecklund, Supervisor of Operations
Support
Sterling, Supervisor of Configuration Control
Bynum, Nuclear, Operations Director
Houchen, Transition Manager
Gross,
Compliance Supervisor
Craig, Startup Administrative Support Manager
Ferguson,
Startup Engineer
Baron,
QA Engineer
'eringue,
Technical Support Manager
Earner, Assistant Vice President,
Nuclear Production
Self, Nuclear Operation Transition Represent
Kirby, Startup
Manager
4
i"
r,
u
1
t
4
"-P. Coffin, QA Specialist
Various Other Personnel
B.
Bechtel Power Cor oration (Bechtel)
J. Black, Chief Resident Engineer
D. Cole, Quality Systems
Engineer
R. Randel,
Startup/Operations
Resident Engineer,
Supervisor
H. Foster, Project
QC Engineer
H. Mear, Assistant Project
QC Engineer
I,. Bowles,
Lead Welding
QC Engineer
J. Dallam, Administration Supervisor (Training)
Various Other Personnel
$/Denotes
those individuals attending the final exit interview on
September
15,
1984.
-Denotes
those individuals attending the preliminary exit interview on
August 31,
1984.
The team's
approach
was to direct 90 percent of its effort on work
controls, test results, test results evaluations
and quality assurance
applied to the auxiliary feedwater
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 other
10 percent of the team's effort was focused
on
inspection of other important areas,
including AFW support
systems
(electrical supplies),
and the
QA/QC program for operations.
The
AFWS was selected
because
of its high safety significance
and the
presumption that it would be representative
of the work controls,
testing,
documentation,
and methodology of system organizational
responsibility turnover and testing,
applied to all safety-related
work
performed while the systems
are under the",control of the Startup
Group.
The selection
and in-depth examination of such
a representative
sample
allowed
some extrapolation of the team's'indings
to the adequacy of all
safety-related
construction,
preoperational
and startup work controls
and
testing.
The examinations
discussed. above were conducted by:
II
J
(1)
physical inspection of systems
and components,
(2)
examination of testing
and maintenance
procedures
and documentation,
and
(3)
private interviews
and discussions
with over 50 craft and inspection
personnel.
A
k
3,
The inspection involved 819 hours0.00948 days <br />0.228 hours <br />0.00135 weeks <br />3.116295e-4 months <br /> by 13
NRC inspectors.
Results:
Of the areas
inspected,
one violation was identified in the area of
training for Bechtel project engineers.
2.
~Back round
During a previous
team inspection,
conducted in the fall of 1983,
Region V made
a finding that the basic construction at U-1 appeared
to be
generally satisfactory.
This conclusion
has been supplemented
by
on-going
NRC staff inspections
and special
reviews conducted
by the
licensee (in such areas
as personnel qualifications, control of vendors,
control of design activities, etc,).
The major findings of the last team
inspection were in the area of the Startup Test Group.
The Startup Test
Group is responsible for preoperational
testing after the systems
are
turned over from construction
and before the systems
are turned over to
the Operations
Department.
In November
1983, after the team inspection,
APS performed
an audit. to verify RV's findings and assess
the generic
implication of the findings.
At the conclusion of the audit,
APS stopped
all preoperational
testing in order to effect certain corrective actions.
Therefore,
the areas
selected for this inspection primarily focused
on
systems
under the control of the Startup Test Group.
3.
Desi n Control for and Im lementation of Modifications to the
AFWS
The objectives of this portion of the inspection
were to assess
the
effectiveness
of administrative controls regarding the verification of
design modifications
and changes
to the auxiliary feed water system
(AFWS).
These modifications
and changes
to the
AFWS have normally
resulted
from problems that were found during acceptance
walkdowns
and
testing of the
AFWS, performed by the startup test group.
In order to
accomplish these objectives
the inspector evaluated:
the licensee's
design control procedures;
examined various design process
documents;
inspected,
in the field, certain modifications
and changes
to the AFWS;
conducted
a walkdown of the
AFW system;
reviewed
gC records for
modifications to the system;
and examined
(}C inspector qualification
records.
A.
Review of Desi n Control Procedures
The inspector
reviewed the following startup
and construction
group
procedures
to establish
how design control and verification is
accomplished:
(1)
Procedure
No.
90GA-OZZ19 Revision 8, "Startup Field Reports."
(2)
Procedure
No. IP-4.34, Revision 13, "Design Change
Package."
(3)
Procedure
No. IP-4.12, Revision 13, "Drawing Change Notice."
(4)
Work Plan Procedure
(WP/P) No. 3.0, Revision 18, "Field Control
of Design Documents."
, l
K
(5)
Work Plan Procedure
(WP/P) No. 20, Revision 20, 'Yield Change
Request."
(6)
Procedure
No.
90GA-OZZ08, Revision 13, "Pre-requisite/
Preoperational
Startup
Work Authorization."
These procedures
provide the administrative controls
and processes
for making technical inquires
and reporting problems identified
during startup activities, which require resident engineering
resolution to assure
proper disposition (redesign,
modification
etc.) to existing systems
as required,
and for the accurate
recording of all dispositions of such inquires
and problems.
The
following reports
and documents
are vehicles for accomplishing
design control and verifications:
Startup Field Report
(SFR)
Nonconformance
Report
(NCR)
k'ield Change
Request.
(FCR)
Drawing Change Notice
(DCN)
Design
Change
Package
(DCP)
Startup
Work Authorization
(SWA)
No violations of NRC requirements
were identified.
B.
Review of Desi n Control Re orts and Documents
The inspector
reviewed the following listed reports
and documents
to
assess
the implementation effectiveness
of the licensee's
design
control procedures.
(1)
Fifty-five SFRs, of a total of 402
SFRs closed-out to date, for
the
AFWS were examined to evaluate
the resident engineer's
resolutions of SFR's.
(2)
Twenty-three
NCRs, resulting from the 55
SFRs of item (1),
above,
were examined to evaluate
the dispositions of NCRs.
(3)
Twenty-one
DCPs, of a total of 52 completed to date,
applicable
to the
AFWS were examined to evaluate project engineering's
control of design
changes
to existing plant installations.
(4)
Eighteen
FCRs were reviewed to evaluate
the controls for
integrating field changes
into design documents,
such as
and DCNs.
(5)
Forty-one
DCNs, which resulted
from DCPs
and FCRs,
were
reviewed in conjunction with seventeen
drawings, including the
piping and instrument diagram, piping isometric drawings of the
AFWS, piping hanger drawings
and vendor drawings.
This review
evaluated
the thoroughness
of the program for revising and
updating the
AFWS drawings.
A 'i
4
l'
'
)
,
l
II
(6)
Fourteen
SWAs were reviewed to evaluate
the controls for
coordinating these
documents with other design control reports
and documents,
such
as
NCRs FCRs,
DCNs etc.
(7)
The field revision log (FRL) and daily notification list (DNL)
were examined to evaluate their effectiveness
in controlling
the receipt
and distribution of design
documents in the field.
No violations of NRC requirements
were identified.
C.
Field Ins ection of Modifications and Walkdown of AFW S stem
The inspector visually examined, in the field, modifications
and
changes
made to the
AFW system under the following design
change
packages:
ISS-AF-019, Installation of Nine Pipe Supports
ISP-AF-027, Turbine Drain/Steam
Trap Piping
ISM-AF-062, Remove
AF Pump Full Flow Recirculation Valves
ISP-AF-065, Modify Pipe Hanger
13-AF-011-H-001
The inspector
examined the quality control records for modifications
and changes
made by the following design
change
packages:
ISM-AF-062)
Shorten Piping Vents
and Drain Lines
Changes
to Limit-Torque Valves (2)
Remove
AF Pump Full Flow Recirculation Valves
Modify Pipe Hanger
13-AF-011-H-011
The field inspection included
a walkdown of the auxiliary feedwater
system piping to check the configuration against that depicted by
the piping and instrumentation
diagram,
13-M-AFP-001, Revision 16.
The
AFW system
was walked-down from the condensate
storage
tank to
where it tapped into the main feedwater piping adjacent to the steam
generators.
The pull and termination cards for 13 cables
associated
with the
AFWS were examined in conjunction with the walkdown of this
system.
No violations of NRC requirements
were identified.
D.
C Ins ector
ualifications
The inspector
examined the qualifications of 15 mechanical
and
electrical,(}C inspectors.
Seven of these inspectors
had performed
(}C insp'ections
of the modifications for which the
gC records
were
examined by this inspector
and identified above in paragraph
C.
4
No violations of NRC requirements
were identified.
The inspector
concluded that the licensee's
system for control and
verification of design modifications
and changes
to the
AFW system, while
under the jurisdiction of startup test group,
does function properly to
accomplish the objectives.
It appears
that there is adequate
design
control and verification.
Licensin
Commitment Trackin
S stem
The inspector
met with key management staff to discuss
the licensee's
program for identifying and tracking licensing related items.
The
program is comprised of a main listing of commitments extracted
from such
documents
as the Safety Analysis Reports, Fire Protection Report, Safety
Evaluation Report,
the TMI Lessons
Learned Report and
APS correspondence
with the
NRC.
Other subprograms
exist which identify matters related to
NRC inspection report findings, Deficiency Evaluation Reports
and
Operating Experience Reports.
The main program is managed
and maintained
by APS licensing staff.
Based
on discussions
with staff members
and review of documents
dealing
with commitment tracking systems,
the inspector learned that the basic
commitment data
was extracted
from the referenced
documents
by a team of
people
who compiled the information into a master list.
Subsequent
to
the establishment
of the basic list,
a program was implemented to require
that every document,
issued to the
NRC by APS, be reviewed by a
responsible
APS engineer to identify licensing commitments.
The program also requires, in addition to the identification of the
commitment,
the review of the commitment by the organization responsible
for its disposition
and the entry of the item on the list by coordinators
dedicated
to the maintaining the list current.
These coordinators
are
assigned
to the various project organizational units.
Additionally,
individuals have been assigned
in the different organizations
to follow
the progress
of item disposition
and interface with the
APS licensing
organization.
The commitments
are tracked
on computer lists.
The information
associated
with each item includes
the source
document
and paragraph,
responsible
department,
item number,
due date,
completion date,
reference
documents,
disposition documents
and item description.
The listing is
maintained current by the completion of input forms which are processed
into the computer by the coordinators.
In order to assess
the quality of information. on the lists, the inspector
reviewed the program for commitments,
documented in the testing section
(Chapter
14) of the CMSAR, the TMI lessons
learned report,
and recent
violations identified in NRC inspection reports.
No discrepancies
were noted.
Mhile confirming the identification 'of the commitments,
the inspector
was
informed that the tracking system included only the "software" as program
type items.
Hardware or installation type items were encompassed
in the
plant design program.
The licensee is currently developing
documents
to describe
the program.
To date
a company policy has been written which addresses
the total
Action Tracking System
(ATS).
A procedure
describing the Licensing
Commitment Tracking System
(ICTS) is in draft and is expected to be
finalized in two weeks.
t'l'
I
~
I
P
The licensee
was informed that in addition to finalizing the
LCTS
procedure,
that subprogram
such
as the
NRC Inspection Finding Program
should be proceduralized in a timely manner.
The inspector also
discussed
the matter of including an "overdue" statistic in the monthly
report which documents
the number of open,
closed
and totals count of
commitments.
APS responded
that it would initiate actions to finalize
necessary
program procedures
by October 8,
1984,
and include the overdue
statistic in its reporting system.
Based
on discussions
with plant staff and
a review of program documents,
the inspector
concluded that
a program was being implemented to identify
and track licensing commitments,
although the program has not yet been
fully proceduralized.
No violations were identified.
5.
0 eratin
Iicense
0 en Item Trackin
S stem
The inspector met with key management
personnel
to discuss
the program
used by APS to identify and track the status of completion of Unit
1
items requiring resolution prior to the receipt of an operating license.
The program involves the identification of open items by all Unit 1
project organizations.
The coordination of the overall list is
accomplished
by the
APS licensing organization.
Overall cognizance of
status
and schedule,
as well as the coordination of APS management
efforts to support resolving the items, is carried out by the Transition
Manager.
Each of the project organizations
has
an assigned staff member
who serves
as
a central contact
and follows the activities associated
with the tracking and statusing of the items under their jurisdiction.
Knowledge of the progress
of schedules
is maintained through weekly
meetings
between the Transition Manager
and the various Project Managers.
The category of items which are
on the lists appeared
comprehensive
and
included such types as:
a
~
b.
c ~
d.
e.f.
g.
h.
1 ~
Licensing Commitments
NRC Inspection Findings
Deficiency Evaluation Reports
Bulletins and Notices
Allegations
Startup
Open Items
Operations
Open Items
Nonconformance
Reports
Test Exceptions
The listing of items requiring disposition prior to licensing is
undergoing final review.
Resolution of the items which obviously need
closure is ongoing.
APS has identified the criteria which it intends to
use in determining which open items must be resolved prior to licensing.
This criteria has just recently been formulated and it is APS's intent to
procedurally apply the criteria consistently throughout the project.
The consistent application of criteria, by all project organizations,
to
identify and prioritize open items
was stressed
with APS management.
In
lt
addition,
management
was informed that since several organizational units
were developing lists of open items, falling within their responsibility,
it was important that such lists have project cognizance
and
coordination.
The licensee
indicated agreement with this philosophy.
While the program to manage
the resolution of items requiring disposition
prior to licensing has essentially
been developed
and is being
implemented,
the description of program activities, responsibilities
and
interface controls
has not yet been written.
Management
was advised that
the completion of this document should be expedited.
This matter was
discussed
with APS management
who committed to the development of
necessary
program and procedures
documents
by September
24,
1984.
also plans to apply the criteria consistently
and maintain project
cognizance of all Lists.
The open items list is to be finalized by
October
1, 1984.
A spot check of known problems with the Auxiliary Feedwater
System were
confirmed by the inspector to be on the'startup
open items list.
Based
on discussions
with plant staff and document reviews, it was
concluded that programmatic efforts to identify, resolve
and track the
status of items requiring resolution prior to licensing is in place
and
being implemented.
Verification that appropriate
items have been
identified, along with program description implementation, will be
addressed
during future inspection efforts.
No violations were identified.
Reactor Vessel Overfill
On August 27,
1984,
an unplanned overfill of the Unit 1 reactor vessel
occurred
because
of an incorrect valve lineup.
This event
was
one of a
series
which occurred
due to ineffective controls governing equipment
operations
carried out to support startup testing activities.
Details of
the event,
which is considered
a violation of regulatory requirements,
as
well as references
to previous operating errors are documented in NRC
Inspection Report 50-528/84-28.
Corrective actions
taken by the licensee
're documented in Inspection Report 50-528/84-33.
Because of NRC's
concerns for incidents of incorrect equipment alignment, 'this topic was
discussed
with APS management
during the exit meeting.
Measurin
and Test
E ui ment
(M&TE)
The quality assurance
program for Control of Measuring
and Test
Equipment
(M&TE) is described in Section 17.2.12 of the
and in Section
12 of the
PVNGS Operations
equality Assurance
Manual.
The inspector
reviewed the following procedures
contained in the
Station Manual in order to establish
whether the licensee
had
established
a program consistent with commitments.
(1)
Procedure
No.
34PR-OZZOl Rev.
3, "Measuring and Test Equipment
(M&TE) Control Program."
ig
p
0
(2)
Procedure
No.
34AC-OZZ03 Rev. 6, "Control of Nonconforming
Measuring
and Test Equipment
(M&TE) and Calibration Standards."
(3)
Procedure
No.
34AC-OZZ06 Rev. 4, "Calibration Requirements
for
Measuring
and Test Equipment
(M&TE) and Calibration Standards."
(4)
Procedure
No.
34AC-OZZ07, "Measuring and Test Equipment
(M&TE)
Users Administrative Requirements."
(5)
Procedure
No.
34AC-OZZ08 Rev.
0, "Measuring and Test Equipment
(M&TE) Work Control."
In addition to the above procedures
contained in the Station Manual,
the inspector also reviewed Metrology Laboratory Instruction No. 01,
"Control of M&TE Interval and Inaccuracy
Change,
"Rev. 0, which
provides
a method for evaluation
and control of calibration interval
and equipment accuracy revisions.
The inspector
concluded that the applicant's
established:
responsibility assignment
to assure calibration and control of
M&TE,
requirements for marking M&TE with calibration data,
due dates
and calibration status,
a system to assure
that
M&TE is recalled
and calibrated before
the calibration period has expired,
controls to preclude inadvertent
use of M&TE for which the
calibration period has expired,
out-of-calibration controls assuring evaluation of cause of
out-of-calibration status
and the acceptability of items
previously tested
or measured
using this equipment,
criteria and responsibility for assignment
of calibration
frequency,
and
requirements
that calibrations
be performed in accordance
with
procedures,
manufacturer's
specification or written
instructions.
The inspector
found that Procedure
No. 34AC-OZZ08, "Measuring and
Test Equipment
(M&TE) Work Control" was approved by the Plant Review
Board on July 9,
1984, then lost for about
a month.
The procedure
was being used during this period of time even though it had not yet
officially been approved by plant management.
The procedure
was
made effective August 28,'984.
This apparent
lapse in
administrative controls implementation
was found to be of minor
safety significance since only minor differences
between the old and
new work control procedure for M&TE were found to exist.
L ~
t
4
t
s'
A
10
The inspector
reviewed work order records for calibrations of M&TE
accomplished
from August
1 to August 28,
1984.
Of the 584
calibrations performed,
535
(92 percent)
were performed in
accordance
with approved station procedures,
28 (five percent)
were
performed using the manufacturers'pecification
or a vendor's
manual, eight (one percent)
were performed using other written
instructions,
and
13 (two percent)
were performed by an outside
source.
The inspector
choose at random
a work order in which the calibration
of a Hewlett Packard
Model 334A Distortion Analyzer (Equipment
No. SL2017)
was to have been performed in accordance
with
manufacturer specification,
Tech Manual No. EIM290.
Completed data
sheets
were reviewed against the requirements
in the Tech Manual.
Not all data specified in the manual had been taken.
The licensee
provided the inspector with technical justification for not
performing certain steps in the vendor manual.
The observation that
on the work order did not identify those specific steps in the
vendor's
manual which were to be performed,
or were exempted,
indicates
an apparent
weakness
in administrative control of
calibrations of MME performed in accordance
with a manufacturer's
specification or vendor's
manual.
The licensee
committed to
corrective action in this area.
(84-38-06)
The inspector's
review of 15 out of tolerance notices
(OTN's) issued
for MME resulted in the following findings.
OTN 84-460,
issued against
EM 1065,
was found to be
dispositioned
by verifying only the last use of the megger.
This instrument.
was used for preventive maintenance
on a number
of motor operated
valves in the safety injection and auxiliary
systems.
Procedure
No.
34AC OZZ03 "Control of
Nonconforming Measuring
and Test Equipment
(MME) and
Calibration Standards"
specifies that one method of determining
the acceptability of tests
when
a piece of MME used is found
out of tolerance,
is by verifying only the last test performed
with that instrument.
It is conceivable that
a satisfactory
verification of the last performed test
may not be sufficient
reason for acceptance
of other tests.
The licensee
stated their practice is to evaluate all tests to
determine
the necessity of additional verifications.
The
licensee
committed to revising the administrative controls to
bring these into line with actual practice.
Both OTN 84-675,
issued against pressure
gage, GU-0008,
and
OTN 84-692,
issued against micrometer
MM 1021, indicated that
these pieces of MME had not been used in the interval for
which the OTN's had been written.
Review of the usage
logs for
the micrometer
and pressure
gages
indicated the devices
had
been used.
Review of the work orders listing usage of these
two pieces of MME did, however, establish that the micrometer
S
"a
n
'tl
C
had not been used in making any critical measurements
and that
the pressure
gage
had been
used in a non-safety related
application.
In reviewing
OTN '84-690
and
OTN 84-691,
no usage
cards
were
found to exist for the pieces of MME affected,
crimp tool
EM 4170 and digital ammeter
EM 1313, respectively.
Although
usage
cards
were not created in these
two cases,
the licensee
stated it is their practice to create
a usage
card
when
a piece
of MME is received at its place of issuance.
Although none of the above findings represent violations of NRC
requirements,
the problems identified in the small sample of OTN's
reviewed indicate possible
weaknesses
in the evaluation of out of
tolerance notices.
The licensee
committed to perform additional
in-depth reviews in this area.
This area will be evaluated
during
a
subsequent
inspection
(84-38-06).
8.
Surveillance Testin
and Calibration Control
The inspector
examined the following procedures
to assure
that
a
program had been developed
to accomplish the surveillance testing,
calibrations
and inspections
required by the proposed
Palo Verde
Unit 1 Technical Specifications
and the
ASME BSPV Code Section XI
with regard to pump and valve testing:
(1)
Procedure
No.
73AC-OZZ10 Rev.
0,
"ASME Section XI Inservice
Inspection"
(2)
Procedure
No.
73AC-9ZZ04 Rev.0, "Surveillance Testing"
Based
upon the above review and discussions
with licensee personnel,
the inspector
concluded that the licensee had'established
or was in
the process
of establishing:
a comprehensive listing of required surveillances
including,
Tech Spec paragraph
surveillance
frequency,
and
modes in which
surveillance is required,
assignment
of responsibility for the accomplishment of each
surveillance
requirement to a particular licensee
organization,
procedures
for the performance of each surveillance test,
assignment
of responsibility for review of surveillance
data to
assure
Tech Spec compliance,
a system to ensure that each required surveillance is scheduled
and tracked,
and
a system to assure
compliance with the pump and valve section
(IWP and DN) of the
ASME BRPV Code Section XI.
12
The inspector determined that the licensee is tracking open items in
this area.
These
open items include: completion and incorporation
into the station manual of the cross-reference
relating technical
specification requirements
to surveillance procedures
or other
implementing instructions;
assignment
of responsibility for
performance of Tech Spec surveillance
requirement 4.3.3.9,
Table 4.3-8 Gaseous
Radwaste
System Explosive
Gas Monitoring System
channel
checks,
and Tech Spec surveillance
requirement 4.11.2.6,
quantification of radioactive material contained in Gaseous
Radwaste
System storage
tanks;
and completion of a comprehensive list of
hydraulic and mechanical
subject to surveillance
requirements
of Tech Spec 4.7.9.
The inspector also determined that the licensee
was planning to use
printouts from the non-safety related plant computer
system
as
a
means of accomplishing certain required safety-related
channel
checks in lieu of using qualified instrumentation.
The inspector
discussed
the philosophy and intent of a channel
check,
described in
section
1.5 of the Tech Specs (i.e.,
a channel
check is intended to
be
a qualitative assessment
of channel behavior during operation by
observation).
The licensee
committed to perform channel
checks
using the plant computer
system only when direct indication from
qualified safety-related
instrumentation is not otherwise available.
In addition,
the inspector discussed
with the licensee
the
requirement of Section 4.7.9i of the Tech Specs
regarding the need
to ensure that the service life of both hydraulic and mechanical
is not exceeded
between surveillance inspections.
The
inspector noted that no preventive maintenance
program for
mechanical
had been defined nor did the licensee provide
sufficient justification for the absence
of such
a program.
This
will be carried
as
an open item and examined during
a future
inspection
(Open Item 50-528/84-38-01).
Im lementation
The licensee
has identified 261 surveillance test implementing
procedures
to be required for performance of all surveillance
requirements.
The licensee indicated that
96 of these
were required
for entry into Mode 6.
Of the total required for all modes,
the
licensee
stated
that.
69 percent
were ready for use.
Of the
96
required for Mode 6,
81 percent
were said to be complete.
Implementing procedure
review will be the subject of future
inspection effort.
The inspector did discuss with the licensee
the need to perform
surveillances,
using the proposed
surveillance test implementing
procedures,
prior to their actually being required in order to
verify procedure
adequacy.
The licensee
indicated they were doing
this to some extent
and would consider increasing their efforts in
this area.
No violations or deviations
were identified.
h
h
13
9.
Haintenance
Performed
on the
AFWS
The inspector
examined selected preventative
and corrective maintenance
actions performed
on the
AFWS while the system is under control of the
Startup
Group.
The sample consisted of 22 completed
SWA/NCR packages,
23
work orders
and two Startup Turnback Work Orders.
The 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.
No violations of NRC requirements
were identified.
10.
Thermal Ex ansion Testin
of AFWS
The inspector
reviewed test procedure
(BOP Piping Thermal
Expansion Test)
and test guideline PETG-6-XX-1 (Piping Vibration, Thermal
Expansion,
and Dynamic Effect Verification) as they apply to thermal
expansion testing of the
AFWS.
The inspector discussed
the testing
program with licensee
representatives
and reviewed the test results
on
all pipe hangers
tested
on the
AFWS.
All hangers
were tested
successfully
and no discrepancies
were identified.
No violations of NRC requirements
were identified.
ll.
Desi n Chan
e and Hodifications durin
Plant 0 erations
The quality assurance
program for design control is described in
Section 17.2.3 of the
The requirements
for plant and
corporate safety committee (Plant Review Board) review of design
changes
and modifications are defined in Section 6.5 of the
Unit 1 draft Technical Specifications.
The inspector
reviewed the
following procedures
contained in the Station Hanual in order to
determine whether the licensee
has established
a design control
program consistent with his commitments
as described in these
documents.
(1)
Procedure
No.
73AC-OZZ12, "Plant Change Request
(PCR),"
Revision 2, of May 25,
1984.
This procedure
establishes
the
method for controlling and processing all design
change
requests,
including modifications, associated
with the
(2)
Procedure
No.
73AC-OZZ15, "Plant Change
Package
(PCP),"
Revision 1, of June
25,
1984.
This procedure provides the
method to develop,
review, implement and closeout plant change
packages
(PCPs).
The
PCP package
contains
the
PCR and the
Design
Change
Package
(DCP).
(3)
Procedure
No. 79AC-9ZZ07, "Nuclear Safety Review and
Evaluation," Revision 0, of February
14,
1984.
This procedure
describes
now safety evaluations
are performed to evaluate
J
't
'I II
1
proposed
design,
procedural
and operational
changes
according
to the criteria set forth in 10 CFR 50 '9.
(4)
Procedure
No.
73AC-OZZ17, "Detailed Design Development,"
Revision 0, of June
29,
1983.
This procedure
establishes
and
describes
the methods
used for the development of a detailed
design, in accordance
with ANSI N45.2.11, for plant
modification.
(5)
Procedure
"Change Control Process,"
Revision 0, of
July 5,
1984.
This procedure
establishes
administrative
controls for the request,
processing,
review and approval of
design
changes,
including closeout
and tracking of all plant
changes'6)
Procedure
No.
73AC-OZZ24, "Field Change Requests,"
Revision 0,
of April 5,
1984.
The purpose of this procedure is to control
the use of Field Change Requests.
(7)
Procedure
No.
73AC-OZZ26, "Impact Review and Transmittal of
Design Change
Documents (Prior to Acceptance),"
Revision 0, of
June
19,
1984.
This procedure
establishes
a method, including
documentation,
for review of design
changes for impact on
licensing, documents,
procedures,
programs
and activities.
B.
Procedure
Review
The above procedures
were reviewed to establish
whether the quality
program for design
and modification change
contained
the following
attributes:
procedures
establishing
controls for design
and modification
change
request,
including:
(a)
method for initiating a design or modification change.
(b)
design
change
request. control form, or equivalent, with
provisions for documenting
completion of required reviews,
evaluations,
and approvals prior to implementing the
change.
(c)
method for assuring that proposed
change
does not involve
an unreviewed safety question,
as described in
10 CFR 50.59, or a change in the technical specification.
l
(d)
method for assuring that applicable guidelines for fire
protection are included in design documents.
(2)
procedures
and responsibilities for design control have been
established
including:
(a)
identification of organizations
responsible for performing
design work'.
1
I 1
1'
15
(b)
responsibilities
and methods for conducting safety
evaluations.
(c)
procedures
and responsibilities for identifying,
reviewing,
and approving design input requirements.
(d)
methods,
procedures,
and responsibilities for performing
independent
design verifications.
(e)
responsibilities for final approval of design
documents.
(f)
procedures
and responsibilities .for assuring proper
inclusion of fire protection/prevention
requirements.
(3)
Administrative controls for design
document, control have been
established for the following:
(a)
controlling changes
to approved design
change
documents.
(b)
release
and distribution of approved design
change
documents.
(4)
administrative controls require that design documentation
and
records,
which provide evidence that the design
and review
process
was performed,
be collected
and transmitted to records
storage.
(5)
controls require that implementation of approved
design
changes
be in accordance
with approved procedures.
(6)
responsibility and method for reporting design changes/modifi-
cation to the
NRC in accordance
with 10 CFR 50.59.
(7)
program provided for periodic management
reviews
and audits of
the activities in this area in order to appraise
the
effectiveness
of the program.
C.
Audit Review
The procedures satisfactorily addressed all of these
program
controls.
In order to assess
the management
appraisal of the design
program,
the inspector
reviewed audits performed by the (}uality
Audits and Monitoring Group.
The following evaluations
and audits
were reviewed.
(1)
Evaluation of Operations
Readiness
(performed April 25 - May 6,
1983).
This activity was conducted to evaluate
the operations
readiness
of departments
within APS to support operation of
The design control portion of the evaluation
was to
assure
the overall effectiveness
and ability of APS to control
design
and design configuration. It should be noted that this
activity was performed in the early stages
of operations.
Therefore, draft procedures
were audited
and all findings were
then presented
to Corporate
gA as program recommendations.
The
16
audit report identified nine major .recommendations
which were
responded
to by APS management.
(2)
Operations
Readiness
Audit (performed February
14 - April 18,
1984) of Design Control.
No major problems identified.
(3)
Operations
Readiness
Audit (performed July 5-25,
1984).
Resolution of problems identified are in process.
This portion of the inspection
was intended to verify that the
licensee's
program for control of design
changes
and modifications
was adequately
implemented.
However, at this earlier stage of
operations,
no safety-related
design
change or modification record
packages
have been turned-over to the licensee.
Therefore,
inspection of program implementation will:be performed during a
future inspection.
No violations or deviations
were identified.
Startu
Work Control
To determine
the scope
and depth of work controls associated
with the
Startup
Program of Palo Verde for Un'it 1, the inspectors
examined
documentation
associated
with test'ctivity.
Included in this
examination were 304 Startup
Work Authorizations
(SWAs),
221 Startup
Field Reports
(SFRs),
and
71 Nonconformance
Reports
(NCRs) for the
testing
done under the portions of 91PE-1SI08
(Safety Injection System
Full Flow Verification Test) associated
with the low Pressure
Safety
Injection System.
For procedures
91PE-lAF01 (Auxiliary Feedwater
System)
and 91HF-lAFOl (Precore
Emergency
System Test)
the inspectors
examined
407 SFRs,
430
SWAs,
and
140 NCRs.
An area of concern regarding the depth of NCR resolution review during
examination of NCR's
SM-3567 (initiated January
17, 1984),
and
SM-4201
(initiated April 18, 1984).
NCR SM-3567 identified a rumbling sound
phenomena
in the suction piping associated
with l,ow Pressure
Safety
Injection Pump B.
The disposition of the
NCR was to keep the flow below
2200 gallons per minute,
as the phenomena
was observed in the range of
3000 gallons per minute.
The cause
was thought to be due to the system
lineup in use,
which was recirculation through the Refueling Water Tank
via a recirculation line rather than the normal injection path.
SM-4201 identified the
same
phenomena,
and
was initiated to facilitate an
investigation into the phenomena.
The startup organization
was fully
aware of, and had extensive
discussions
about, the situation following
the closure of NCR SM-3567.
This indicates that there
was considerable
concern about the potential effects of the phenomena.
Therefore,
the
closure disposition of NCR SM-3567 would appear to have been premature.
It also appears
that thoroughness
in the review of the
NCR was lacking in
that no consideration
was given to follow-up during later testing.
Other than the above item, the inspectors
found that startup work
controls were in place.
And were sufficient to assure
that no work
J
I
II
t
~h
17
activity would take place without sufficient managerial
review and
involvement.
SWAs and work orders, in general,
controlled work activity
sufficiently to a level that would prevent unauthorized
work being done.
No violations or deviations
were identified.
13.
Test Results
To examine the processes
that, Test Results
Reports
undergo during review
and approval the inspectors
reviewed the following procedures:
90AC-OZZ02, Startup Test Conduct
90AC-OZZ09, Startup Test Working Group
90AC-OZZ14, Startup Procedures
Preparation,
Review and Approval
90AC-OZZ18, Startup Test Results
Review
90AC-OZZ19, Startup Field Reports
The inspectors
then examined three Test Results Reports for the following
preoperational
tests:
91PE-1AFOl, Auxiliary Feedwater
System Test.
91HE-1AF01, Precore
Emergency
System Test
SI Full Flow Verification Test
The Test Results
Reports
were examined to determine
the depth
and
thoroughness
of the reviews
conducted
by the Test Working Group
(TWG).
The three reports
chosen
were in different phases
of the review cycle
and, therefore,
presented
a good overview of the processes
that reports
undergo during
a review by TWG.
Report 91PE-lAFOl had undergone
a full
review and had included all comments
by TWG that had concurrence
by the
Principal Startup Engineer
and the Group Supervisor.
All Test Exceptions
were concurred with and all SFRs resolved
as to final disposition.
Report 91HE-lAFOl had just undergone
TWG review and was in the
comment
review phase
where the
comments
made by TWG were in the process
of
concurrence prior to approval by the
TWG Chairman.
Again, except for TWG
comments
the Test Exceptions
and the
SFRs were resolved.
For 91PE-1SI08,
the Test Results Report was in the process
of being prepared.
The
inspector discussed
the process with the Principal Startup Engineer
a
Group Supervisor.
All test exceptions
were reviewed
and fully resolved
prior to submittal to TWG, as were outstanding
SFRs or NCRs that would
have
a bearing
on the acceptability of the Test Results Report.
In no
case
would TWG accept
a package without a fully successful test,
or a
satisfactory resolution of acceptance
criteria.
In the case of the testing conducted
under 91PE-1SI08 for the low
pressure
safety injection pumps,
two SFRs that were associated
with the
failure to achieve
a flow of 9600 gallons per minute in the combined
suction header
were prepared.
The flowrate was necessary
to measure
net positive suction head
when both
the containment
spray,and
low pressure
safety injection pumps are running
with a
common suction per
CESSAR 14.2.12.1.23-3.4,
The 9600 gallons per
minute is minimum projected flow for both pumps,
however, it could not be
achieved in the configuration used for testing,
which was through the,
k
H
iV
18
normal injection path for low pressure
safety injection.
The flow rates
that were achieved
were 8900 gallons per minute for LPSI "B" and
containment
spray "B" and
8600 gallons per minute for IPSI "A" and
containment
spray "A".
The higher head of the containment
spray pumps
held back the flow that could be achieved
from the LPSI pumps.
Therefore,
the desired point at which to measure
net positive suction
head could not be reached.
The resolution for the
SFRs
was to
extrapolate
to 9600 gallons per minute and calculate
the
NPSH at that
point.
The acceptance
criteria for NPSH at the suction of the LPSI pumps
is 22 feet.
The
NPSH at 8900 gallons per minute for LPSI "B" pump was
73.7 feet,
and for LPSI "A" pump at 8600 gallons per minute the
NPSH was
72.2 feet.
Calculations
by Combustion Engineering
showed that the head
would only be reduced
about
10 feet, in both cases,
when extrapolated
to
9600 gallons per minute.
Two items of interest occurred during testing of the Auxiliary Feedwater
System.
The first was
a problem the turbine driven pump experienced in
achieving multiple cold starts.
The resolution
was to change the
configuration of the steam supply to the turbine driver, which had
apparently affected the delivered pressure
to the driver.
The cold line
apparently prevented
the driver from achieving sufficient speed before
an
overspeed protection circuit tripped the turbine stop and throttle valve.
The second
problem had to do with excessive piping vibration on the
discharge line of the
same
pump.
The configuration of the valves in the
line led to a condition where the pump was pushing
on a column of water
in a fashion where the beat frequency of the pump and column were close.
To resolve the problem the flow through the recirculation line was
increased with a larger orifice.
Combustion Engineering
has
done an
analysis that
shows the reduced flow to the steam generators will be
sufficient to meet design requirements.
No violations or deviations
were identified.
Test Workin
Grou
The inspectors
held discussions
with four members of the Test Working
Group
(TWG), two who are permanent
members,
and two who are alternates.
The discussions
included Test Results
Reviews, test procedure
reviews,
disposition of TWG comments,
and conduct of TWG activities.
One of the
permanent
members
interviewed
was the
TWG Chairman.
At present
the process for review of test procedures
is such that the
proposed
procedure is routed to
a
sub-TWG review group.
Sub-TWG is a
group of level III startup
engineers
reporting to the
TWG Chairman (there
are
29 members in various discipl'ines).
The procedure is. review by this
group,
any comments
generated
are sent back for incorporation into the
body of the procedure.
After all comments
are resolved the procedure is
routed to the
TWG for review.
This provides
a two tier review, of
substantial
depth
and scope, for a test results report.
The results
are
summarized in a report attached
to the procedure
and data.
This receives
a review by each
member of TWG prior to the report being scheduled for a
meeting of the
TWG.
Each
member is responsible for assuring
the
discipline area
he represents
thoroughly reviews the report. It then
I
It
It
J"
~ ttI'f
19
I
goes to a meeting
and any comments
are. gathered,
a comment sheet is
filled out,
and the package
routed back to the Principal Startup
Engineer.
" After resolution of the
comments
the report can be approved.
This conforms to the procedures
governing the review process.
No violations or deviations'ere j.dentified.
15.
Records
and Document'Control durin
Plant
0 erations
A.
General
The licensee's
program for documents
and records control was
evaluated
against
commitments
contained in Sections
17.2.6
and 1.8
of the licensee's
Final Safety Analysis Report, Regulatory
Guide 1.88 (Collection, Storage,
and Maintenance of Nuclear Power
Plant (}uality Assurance
Records),
and licensee
implementing
procedures'nspection
emphasis
was directed to the licensee's
operational
phase
records
and document control programs.
B.
Document Control
(1)
Procedural
and Administrative Controls
The inspector
reviewed the following licensee
operational
phase
document control procedures.
78PR-OZZ01 Rev.
1,
PVNGS Document/Record
Control
78AC-OZZOl Rev.
1, Nuclear Operations
Document 6 Manual Control
78AC-OZZOl Rev.
1,
PVNGS Document/Record
Control
78AC-OZZ04 Rev.
1, Control and Issuance
of Design Document,
78AC-OZZ06 Rev.
1, Document/Record
Turnover Control
78AC-OZZ07 Rev.
1, Document/Record
78AC-.OZZ11 Rev. 0, Control and Issuance
of Field Change Request
78AC-OZZ12 Rev.
0, Control and Issuance
of Plant
Change
Package
78AC-OZZ13 Rev.
0, Control and Issuance
of As-built Drawings
and Drawing Amendments
Bechtel Internal Procedure
4.12, Drawing Change Notice
(a)
Administrative Controls
Review of these procedures
indicated that the licensee
had
established
administrative controls which:
assure As-built design
documents
are provided to the
plant in a timely manner,
(Bechtel IP 4.12,
provide for control of obsolete
drawings
(78AC-OZZ04).
establish
master indices of controlled documents,
including dates
and revision.
e
I
20
provide for issuance,
distribution and control of
Design Documents,
Technical Specifications,
and Final
Safety Analysis Report.
These include marking design
documents
as Controlled, Uncontrolled or Controlled
by User.
78AC OZZ07 )
78AC OZZ 1 1 ~
78AC OZZ1 2 ~
78AC OZZ 1 3 >
provide for receipt Controls by DDC-PV (78AC-OZZ06,
(b)
Procedural
Controls
The inspector verified compliance with selected
procedural
controls, including but not limited to:
(1)
Procedure
78AC-OZZ04, Control and Issuance
of Design
Documents
paragraphs
3.1.1.1 through 3.1.1.4
(Stamping of
drawings).
paragraph 5.2.1
(Use of drawing/transmittal
document)
paragraphs
5.2.2 and 5.2.3
(Use of Design
Document Distribution Matrix and System
38 to
track document transmittals
and status).
paragraphs
5.2.6
and 5.8 '
(Verification of
controlled document updates within 2 days)
paragraph 5.7.1
(Use of Controlled Drawing
Transmittal Acknowledgement Form and Tickler
File)
paragraph 5.8.1 (Stick files were identified by
a unique number to the Design Document
Distribution Matrix).
paragraph 5.8.2 (Stick files cover sheets
show
station
and drawings contained)
paragraph 5.8.6 (Physical removal of superseded
design
documents
by DDC-PV) (Refer to report
Section B,a,A for additional discussion).
(2)
Procedure
78AC-OZZ01, Nuclear Operations
Document
and
Manual Control
paragraph
3.1.5
(Use of "Information Only"
copies of procedures)
1
21
'
paragraphs
3.1.6
and 3.1.7
(Use of the
Procedure Distribution Matrix and Procedure
Index).
paragraph
3.1.7.1 (Distribution and use of Daily
Change List)
paragraph
3.1.8
(Use of Procedure
Change
Notices,
PCNs)
paragraph 5.1.3
(Use of DDC-PV Receipt Log)
(3) Procedure
PVNGS Document/Record
Control
paragraph 3.1.f.2
(Use of Field Revision Log)
paragraph 3.1.f.3
(Use of Daily Notification
Log)
paragraph 3.1.f.5
(Use of System
38 to reflect
as-built conditions at PVNGS)
The inspector
found that the definition of responsibilities for
distribution of controlled documents,
contained in procedure
78AC-OZZOl (Nuclear Operations
Document
and Manual Control),
needs revision to reflect the actual practice of As-built
Records
Management
Group performing the actual distribution and
update of procedures.
Discussions
with licensee
representatives
indicated that this change in responsibilities
had taken place
on August 13,
1984,
and that the licensee
was
already evaluating
how these procedures
should be revised.
No violations of NRC requirements
were identified.
(c)
Document Control Verification
The inspector verified that the licensee
had established
master
indices to control document distributions
and
an index to
reflect current revisions.
To evaluate
program effectiveness,
current revisions of procedures,
technical specifications
and
design drawings
were evaluated
at. multiple locations onsite.
Controls over the Final Safety Analysis Report were also
reviewed at several locations although this is presently
controlled by Bechtel from Norwalk, California.
(1)
Desi n Drawin Verification
Design drawings were evaluated at eight locations onsite
(NSSS-Trailer
10, Unit 1 Operators-Trailer
8, Unit 2
Startup Manager-Trailer 29, equality Control
Manager-Trailer 30, Unit 1 Technical Support-Trailer 2,
Unit 1 Control Room, Administrative Library, and the
Unit 2 Control Room).
At each location four
safety-related
Piping and Instrumentation
Diagrams
and
4
22
associated
Design Change Notices were evaluated
against
the current revision maintained by As-built Records
Management.
Drawings utilized to verify licensee
document
control effectiveness
included:
12-M-CHP-003 Rev. 9,
Chemical
and Volume Control System
PAID with 19 Design
Change Notices
(DCNs); 13-M-IAP-003 Rev. 6, Instrument
and
Service Air System
PAID with 18 DCNs;
13-M-SGP-001
Rev.
13, Main Steam
System
PAID with 6 DCNs;
and
13-M-SGP-002 Rev.
10, Main Steam
System
PAID with 4 DCNs.
Thus, total of 32 controlled drawings
and
376 DCNs were
inspected.
Based
on this review the following
observations
were noted:
Drawing 13-M-IAP-003 Rev.
6, Instrument
and Service
Air PAID, at the Quality Control Managers Trailer 30,
was missing
DCN No. 128.
Drawing 13-M-IAP-003 Rev. 6, Instrument
and Service
Air PAID, at the Administrative library, was missing
DCN No.
128.
Drawing 13-M-SGP-002 Rev.
10, Main Steam
System PAID,
at the Administrative Library was missing
DCN No. 51.
Thus,
two out of eight locations with controlled drawings
were found to not have
a fully up-to-date
DCN status.
Of
the 376 DCN's reviewed
as part of this inspection,
only
three problems
were observed.
This represents
a problem
rate of less
than one percent.
Drawing 13-M-SGP-001
Rev.
13, Main Steam
System
PAID,
at the Quality Control Manager, Trailer 30 location
still had superseded
DCNs Nos.
64, 65,
66>
67
68'9,
70,
71,
75 present in the Nuclear Projects
Records
Managements
(NPRM) DCN's folder.
The Unit 2
Control Room also had superseded
DCN No.
75 present
in the
NPRM DCN folder. It was, also,
noted that the
drawing revision which incorporated
these
DCNs
correctly reflected their incorporation.
Drawing 13-M-SGP-002 Rev.
10, Main Steam
System PAID,
at the Quality Control Manager Trailer-30 had
superseded
DCNs 41,
50 and 52 through 57 present in
the
DCN folder.
It,was, also,
noted that the drawing
revision which incorporated
these
DCNs correctly
reflected their incorporation.
Since
a revised drawing was present at these locations,
the presence
of the superseded
DCNs was not considered
to
be
a significant safety concern.
The licensee
corrected
this problem during the inspection.
The inspector identified discrepancies
in the
DCN status
of two "Controlled by User" drawings at the Unit 1
'I
a
4.
23
Technical Su'pport-Traile'r No.
2 location.
These included:
6 missing
DCNs to piping and instrumentation
drawing
13-M-SGP-,002
Rev.
9; and
2 missing
DCNs to piping and
instrumentation
drawing 13-M-IAP-003 Rev.
6.
Previous
licensee internal reviews ohe controlled drawings in
the Unit
1 Technical Support Trailer had identified
'imilar problems including 'missing DCN's and wrong
revisions of drawings.
Since the licensee
had already
identified simila'r, problems with the drawings at this
location, the need to provide improved controls over user
updated
drawings
was noted at the exit interview.
Two drawings
(13-M-CHP-003,
Rev. 9, Chemical
and Volume
Control System,
and 13-M-IAP-003, Rev.
6, Instrument
and
Service Air System)
were identified to have
19 and
18 DCNs
issued to these
drawings, respectively.
The lack of a
specific limit in Bechtel Internal Procedure
4.12 (Design
Change Notice) to control the number of DCNs outstanding
against
a drawing, prior to revision of the drawing,
during the construction/startup
phase
was discussed
with
licensee
representatives.
Licensee
representatives
stated
that controls
had been established
over the number of
outstanding
DCNs allowed during operations.
Based
on the above observations,
although isolated in
nature
and of minor safety significance,
the inspection
team leader
requested
that the licensee
commit to an audit
of their document control program to determine whether
additional controlled drawings
have not been maintained.
The licensee
agreed
to perform this audit at the exit
interview.
Pending evaluation of the licensee's
audit
findings, this is considered
to be an unresolved
item
(84-38-02).
(2)
Control of Station Procedures
Control over Station Manual procedures
was evaluated
by
comparing the latest revision of procedures,
identified by
DDC-PV from the Station Manual Procedure
Index and Daily
Change List (DCL), with the revision status four
procedures
at five locations.
No discrepancies
were
identified.
(3)
Controls over Technical
S ecifications
and the Final
Safet
Anal sis
Re ort
As an additional check on document controls,
the inspector
randomly selected
several locations where distribution of
Technical Specifications
was controlled by As-built
Records
Management.
All locations were found to have the
latest draft revision of June
21,
1984.
Although
distribution of the Final Safety Analysis Report is
presently controlled by Bechtel,
the inspector verified
that current copies
(Amendment
13) were present at four
J
I
24
locations.
No problems
were noted with the control of
either of these
documents.
No violations of NRC requirements
were identified.
C.
Records
Stora
e and Control
General
(2)
The licensee
was in the process
of transferring records
from
multiple onsite groups to Nuclear Projects
Records
Management
(NPRM).
Licensee
implementing procedure
78AC-OZZ07 Rev.
1,
(Document/Record Vault Storage
and Maintenance)
Section 5.1.1,
states
that "Records
generated prior to issuance
of an
operating license are to be turned over to Nuclear Projects
Records
Management
Drawing and Document Control, Palo Verde
location
(NPRM-DDC-PV) upon completion, within 24 months".
Review of licensee
Nuclear Projects
Records
Management monthly
status
report of document
and record turnover,
dated August 1,
1984, indicated the majority of licensee
records
are yet to be
transferred
to DDC-PV for archival storage.
Licensee
implementing procedure
78AC-OZZ06 Rev.
1 (Document/Record
Turnover Control) describes
the licensee's
program for
individual and bulk transfers of quality related records.
Inspection
emphasis
was directed
toward licensee procedural
controls which would be utilized during operations.
The scope
of records
maintained by Bechtel during construction
and by the
startup
group was not emphasized
during this inspection since
this had been evaluated
during previous inspections.
The
inspector 'reviewed the licensee's
DDC-PV vault design
documents
to verify that the permanent
records
storage facility was
designed
to meet the National Fire Protection Association
(NFPA) two hour rating.
Administrative and Procedural
Controls
The following licensee
procedures,
evaluated
by the inspector,
were the principle procedures utilized to evaluate
records
storage
and handling controls which would be in place during
operations:
78PR-OZZ01 Rev.
1,
PVNGS Document/Record
Control
78AC-OZZ06 Rev.
1, Document/Record
Turnover Control
78AC-OZZ07 Rev.
1, Document/Record
Vault Storage
and
Maintenance
Plant Policy 20
PVNGS Generated
Documents/Records
(a)
Administrative Controls
The inspector verified that administrative controls
had
been established
which:
II
25
define responsibilities for records
storage
and
transfer including designation of records
custodians
provide verification that records
received
are in
agreement
with transmittal
documents.
control access
to and distribution of records.
assure
that the records
storage facility/storage
conditions meet regulatory requirements.
(Plant
Policy 20,
controlled transfer of records to archival storage.
records retention provided in accordance
with
perscribe
actions necessary
when lost or damaged
or
illegible documents
are identified.
(b)
Procedural
Controls/Im lementation
The inspector also reviewed licensee
compliance with the
following procedural
requirements
and controls.
The licensee
was stamping
documents
as required by
Section 3.1.1.3
and 3.1.1.4 of 78AC-OZZ04 as
"CONTROLLED BY USER",
and
"CONTROLLED".
The licensee
was observed
to be stamping reproduced
documents
as
"Information Only", as required by Section 5.5 of
The inspector
randomly selected
several
documents
from the licensee's
Receipt
Log to evaluate
document
retrievability.
All documents
were provided in a
timely manner.
Procedure
78AC-OZZ07, Document/Record
Vault Storage
and Maintenance
paragraph 5.2.3
The licensee is maintaining
a
document receipt log as required
by procedure.
paragraph 5.3.1.1
Documents
were observed to be
kept in folders or envelopes
and
not stored loosely.
26
paragraph
5.4
Access lists were observed to be
posted at the DDC-PV vault, which
were signed by Nuclear Projects
Records
Manager.
paragraph 5.7.1
Temperature
and humidity controls
were observed to be monitored in
the
DDC-PV vault,
a maximum
humidity reading of 74'/, was
noted.
The licensee
has
initiated a plant change request,
dated August 22,
1984, to improve
humidity/temperature
controls in
the
DDC-PV vault.
Procedure
78AC-OZZ06, Document/Record
Turnover
Control Document.
Transfers of individual and groups
of records
are performed in accordance
with
78AC-OZZ06 and
The inspector
discussed
the requirements
contained in Sections
3.2 '
and
5.3(2) of ANSI N45.2.9 with licensee
representatives
during the inspection.
Licensee
representatives
agreed to review the clarity of how these
requirements
are proceduralized.
No violations of NRC requirements
were identified.
16.
Ins ection of Technical Activities Related to Startu
Field Re orts and
Nonconformance
Re orts
Unit 1
A.
O~b'eccive
The inspector
examined the site administrative programs
and
documentation
related to startup field reports
(SFRs), startup
nonconformance
reports
(SFR/NCRs)
and Arizona Public Service
Company
(APS) nonconformance
reports
(NCRs) issued against the auxiliary
system
(AFWS) installation in Unit 1, to assess
the
effectiveness
of the startup test group in maintaining the quality
of the
AFWS while under their control.
B.
Technical
A
roach to Ins ection
(1)
Review and obtain applicable
copies of SFR,
SFR/NCR and
administrative procedures
used onsite.
(2)
Review available
SFRs,
SFR/NCRs
and
NCRs issued against the
AFWS installation in Unit 1, to assess
such things
as technical
adequacy,
documentation
and disposition.
C,
Ins ection Activities and Findin s
t
(1)
The
AFWS was turned over to the startup
group approximately
March 9,
1983 and as of August 29,'984,
approximately
400
SFRs
I
I
1
27
had been issued against
the
AFWS by the startup test group,
along with various
NCRs, per the startup test group'ecords.
(2)
The inspector obtained
copies 'of the following site documents
listed below to identify 'the
SFRs,
SFR/NCRs
and
NCRs issued
against the
AFWS.
<<C
(a)
Report'umber:10;
Definition Number:01 Report title:
,Unit 1, all items for AF-S/S sort.
[from the master
tracking system
(MTS), as of August 31,
1984].
/
(b)
Report Number:05; Definition Number:NC, Report Title: All
open and closed
NCR No. Sort-Unit
1 [from the
MTS, as of August 30, 1984].
(c)
Report Number:04; Definition Number:CR, Report Title:,all
open and closed
BPC NCRs,
NCR Sort-Unit
1 [from MTS, as of
August 30, 1984].
(d)
Special
Run:
File: Activity tracking master, Unit 1 all NCRs for system
AF [from MTS, as of August 28, 1984].
(3)
Using the documents identified above
and available site
records,
the inspector
examined essentially all identified
SFRs,
SFR/NCRs
and
NCRs issued
and/or dispositioned
against
the
AFWS by the startup test group
as of August 30,
1984.
The
number of applicable
documents
examined
by the inspector are
listed below.
400
SFRs
102
SFR/NCRs
[SFRs assigned
NCR numbers]
46
12
(4)
Examination of SFRs,
SFR/NCRs
and
NCRs identified that
additional clarifications would have been desirable for some
documents in the initial write up of the reported condition,
information, deficient condition, etc., to aide
evaluation/disposition
of the applicable
documents in an
effective manner.
Also,
some dispositions of SFRs,
SFR/NCRs
and
NCRs could have
used additional information to
clarify/document the justification for the final disposition.
For example,
(issued April 4,
1983)
and
No. SJ-1842
(issued April 8,'983)
were dispositioned
and
stamped
'1NVALIDATE'nApril 13,
1983, without detailed clear
documentation of the justification for the final disposition.
The two NCRs noted in the example
above were identified
August 30,
1984, to the
APS group representative
assisting
the
inspector in his document examination.
The APS representative
notified the inspector
on August 31,
1984 that information
would be added to the above
two NCRs to provide additional
clarification of the final disposition.
This was typical of
the types of problems identified by APS during the
gA audit
k
V
h
l.
V
28
after the
CAT inspection in November 1983, which required
to stop all preoperational testing.
No documentation
problems
of this nature
were identified after testing
was resumed.
D.
Conclusions
(1)
The examination of available
SFRs,
SFR/NCRs
and
NCRs issued
and/or dispositioned
by the startup test group for the
AFWS
installation in Unit 1,
as of August 30,
1984, did not identify
any violation of NRC requirements.
However,
weakness in
initial documentation of descriptions of reportable
conditions
and dispositions
were noted.
(2)
Examination of the startup test group administrative
programs
for SFRs,
SFR/NCRs
and NCRs, did not identify any problems in
maintaining the quality of the
AFWS installation in Unit 1
while under the startup test group control,
as of August 30,
1984.
17.
QA/
C Administrative Controls
and Audits
The inspector
reviewed the following Operations
QA Criteria and Corporate
QA Department
Procedures
(QADP):
Operations
QA Criterion 2, "Quality Assurance
Program"
Operations
QA Criterion 6,
"Document Control"
,Operations
QA Criterion 18, "Audits"
QADP 1.0, "Organization and Responsibilities"
QADP 6.0, "Control of Corporate Quality Assurance
Department
Procedures"
QADP 6.1, "Control of Operations
QA Criteria Manual"
QADP 18.0, "Quality Auditing"
The reviews were conducted to evaluate
the licensee's
administrative
controls
and audit program in general,
and to:
(1) verify implementation
of FSAR and proposed Technical Specification
commitments for
administrative controls and'udits;
(2) verify that administrative
controls
and responsibilities exist for review of the effectiveness
of
the
QA program;
(3) verify that administrative controls exist to modify
the program
and its procedures
and that responsibilities exist for review
and approval of such modifications;
and (4) verify that the master audit
schedule
meets
the requirements
of Regulatory
Guide 1.33, "Quality
Assurance
Program Requirements,"
and associated
commitments.
The inspector
concluded that the administrative controls were in
accordance
with commitments
and the audit program was well established.
The inspector
reviewed
a sample of the audits
(scheduled
and unscheduled)
completed by the Quality Audits/Monitoring Section to verify
implementation of the audit program.
The inspector also reviewed the
training and qualification records of the auditors to verify their
qualifications to perform quality audits.
The licensee
appears
to be
correctly implementing the audit program with qualified personnel.
N
lg
r.
l0 "'
29
No violations or deviations
were identified.
18.
Review of Maintenance
Pro
ram
The inspector
reviewed numerous Station Manual Procedures
including the
following primary documents:
30AC-9ZZOl, Rev.
1,
"Work Control"
30AC-9ZZ02, Rev.
1, "Preventive Maintenance"
30PR
9ZZ01
p Rev.
1, "Maintenance
Program"
Procedure
reviews
and discussions
with maintenance
personnel
were
conducted to verify that
a maintenance
program had been developed in
conformance with proposed
Technical Specifications,
regulatory
requirements,
and commitments to industry standards.
The inspector
concluded that the maintenance
program was in accordance
with requirements
and documented appropriately.
Implementation of the maintenance
program
was not inspected
due to the
recent turnover of responsibilities for review of work packages.
This
will be examined during future inspections,
No violations or deviations
were identified.
19.
Maintenance Trainin
The inspector
reviewed the following Station Manual Procedures
to
evaluate
the maintenance
training and qualifications program in effect at
the site:
Rev. 3, "Training Program"
83TR-OZZ04, Rev.
0, "General Employee Training Pathway"
83TR-9ZZOl, Rev.
0, "Maintenance Specialty Training"
Based
upon discussions
with maintenance
superintendents
for the
mechanical, electrical,
and
ISC disciplines
and
a review of procedures,
the inspector noted that the process
to establish
the qualifications for
maintenance
personnel
was incorporated into written procedures.
Station
Manual Procedure
No. 83TR-9ZZOl, Rev.
0,
(Maintenance Specialty
Training), defines
the pathway for training of maintenance
personnel
and
their trainees.
However, the licensee is presently hiring only
journeyman level personnel
to perform maintenance
functions
and this
procedure is not being used.
The program for establishing
the
qualifications consists of numerous
telephone
and personal interviews,
a
written exam,
and
a "hands-on" practical test.
This program is not
included in procedures
and the test records
are not a part of the
individual training files.
In addition, the inspector
found that the
licensee
had not established criteria by which an individual maybe
deemed
fully qualified to perform his job function and duties.
The inspector
found the program currently in use for establishing
the
qualifications of maintenance
personnel
needs
to be revised to reflect
actual practice,
including definition of records
storage
requirements.
'VJ
0
, g'll
30
Upon notification of this finding at the exit meeting,
the licensee
committed to draft a procedure outlining the basis for the qualification
of maintenance
personnel.
Maintenance training remains
an open item to be followed up during a
future inspection.
(84-38-03)
20.
Trainin
Records for Resident
En ineers
A.
Bechtel
En ineers
The inspector
examined the training records for Bechtel project
engineers
assigned
to the Palo Verde site for conformance
to Bechtel
Engineering Department
Procedure
No. 5.34, "Engineering
Indoctrination and Training."
The inspector
found that contrary to
the procedure,
the records indicated that about
30 engineers
had not
received the required training.
Additionally, an Interoffice
Memorandum,
dated October
18,
1983, indicated that management
had
become
aware that many engineers
were not returning their training
sheets
and, therefore,
were not in compliance with the procedure
requirements.
Apparently, sufficiently high levels of licensee
and
Bechtel management
were not advised of the discrepancy with the
result that the identified discrepancy
was still not corrected
almost eleven months later.
The failure to comply with training requirements
as specified by
procedure is considered
an apparent
item of noncompliance.
(50-528/84-38/04)
B.
The inspector
examined the training records for APS resident
engineers
assigned
to the corporate office in Phoenix, Arizona, for
conformance
to APS Nuclear Projects
Procedure
No. NS-5,
"Indoctrination and Training."
The inspector
found that
APS Audit
No. S-84-002 had determined that
a considerable
disparity existed
among the training records of the three engineering discipline
groups.
As a corrective action,'
responsible
group was created to
establish
parameters
for consistency in procedures,
syllabi,
and
required training documents.
At present,
the licensee
has revised
their training procedure to comply with this commitment.
Nevertheless,
the inspector reviewed the training records of the
engineers
to assure
conformance to the previous revision of NS-5, to
establish that all engineers
received training in a timely manner
after being assigned
to the project and that all training
requirements
had been complied with as specified by the previous
revisions of the procedure.
The inspector
found that the records
examined
complied with the previous revision of the training
procedure.
No,violations or deviations
were identified.
I
r
~
21.
Audits
S-83-029
August 4,
1983
Design Control
Design Control
S-84-002
April 26,
1984
i
F1
The audits
were reviewed to assure'hat
the audits were comprehensive,
that items were closed out in a timely manner; that sufficient
documentation
was,reviewed
to. assure that an item had been properly
addressed
and resolved before closure, that items were followed up as
necessary,
and that audit checklists
were retained
as part of the
permanent
record.
I
The inspector
reviewed
two licensee audits of Bechtel design activities
conducted in 1983 and
1984.
The following two audits
were reviewed.
Audit No.
Audit Date
T~01 c
The audits
reviewed were found to be comprehensive
and of sufficient
depth to identify and correct problems
found in the area audited.
However,
one
NRC concern
was identified and this item is further
described in paragraph
22, below.
22.
Radwaste
S stem
During the review of APS Audit No. S-84-002,
dated April 26,
1984, the
inspector noted that
a Corrective Action Report
(CAR) No. CA-84-0138,
had
been written indicating that the Bechtel Design Criteria was out of date
relative to the requirements
The licensee
stated in Amendment No.
4 to the FSAR, dated
May 1981, that they complied
with Regulatory
Guide 1.143,
"Design Guidance for Radioactive
Waste
Management
Systems,
Structures,
and Components Installed in Light Water
Cooled Nuclear Power Plants," Revision 0, dated July 1978.
The
CAR is
still open and is currently being processed
by the licensee's
system for
resolving these
issues.
However,
due to the late stage of construction
and the proximity of the licensee's
targeted fuel load date,
the
NRC is
concerned
whether the Radwaste
and Steam Generator
Blowdown Systems
are
constructed
and designed in accordance
with the Regulatory Guide's
requirements,
including the equality Assurance
requirements
stated
therein.
Discussion with the licensee
indicated that the systems
are constructed
and designed in accordance
with the project's
Class
"R" requirements.
The licensee further states
that Class
R components
are under
a equality
Assurance
Program consistent with the requirements
of Regulatory
Guide 1.143.
This issue
was referred to NRR for evaluation
and resolution.
23.
Interview with Workers
In order to assess
the receptiveness
of supervision to worker's safety
concerns,
50 interviews of both APS and Bechtel craftsman
and first line
supervision
were conducted.
Additionally, 43 of those interviewed were
I
ha
4
,;4 <,~
5
i.i
"I
specifically asked if they felt intimidated or harassed.
The
interviewees indicated that they have not felt intimidated, harassed
or
restricted in the performance of their jobs.
Two individuals, however,
acknowledged that there
was
a high degree of schedular
pressure
and
mandatory overtime requirements. 'ven so,
these persons
could not point
out instances
where these pressures
had caused
improper quality
situations.
These issues
were already
known to the
NRC and will be
followed up during subsequent
inspection activities.
All but three
workers interviewed said they felt their supervision is receptive to
their work related
concerns.
An area of potential concern,
which was noted during the interviews
and
subsequently
discussed
with licensee
management,
involved a need for APS
to review and reassess
the use of required overtime and the impact of
scheduler
pressures
to assure
they do not impact on safety.
management
acknowledged
the
comment.
A second
area of potential concern
dealt with the thoroughness
of training (general administrative
and
maintenance
related).
This area will be evaluated
during
a subsequent
inspection
(84-38-05).
Workers Interviewed
D~isci line
No. Interviewed
Arizona Public Service
gA/QC Inspectors
and Engineers
ISC Technicians
Electricians
Mechanics
Resid'ent Design Engineers
11
6
4
4
7
Bechtel
QC Welding Inspectors
Electricians
Pipe Fitters/Welders
Resident Design Engineers
3
2
l5
8
24.
On August 31 and September
15,
1984,
an exit meeting
was conducted with
the licensee
representatives
identified in paragraph
1.
The inspectors
summarized
the scope of the inspection
and findings as described in this
report.
The licensee
acknowledged
the violation identified in the area
of project engineer training record completion.
Jeaay
f