ML17298B520
| ML17298B520 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/16/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| ANPP-31167-WFQ, NUDOCS 8411210277 | |
| Download: ML17298B520 (8) | |
Text
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Arizona Public Service Company ANPP-31167-WF(gTJBiO~
November 16, 1984 U.S. Nuclear Regulatory Commission Region V
1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 lE RgE goP~
Attention:
Subject:
Mr. D. F. Kirsch, Acting Director Division of Reactor Safety and Projects NRC IE Inspection Report 50-528/84-38 File:
84-019-026; D.4.33.2
Reference:
Letter from T.
W. Bishop to E. E.
Van Brunt, Jr.,
dated October 18, 1984
Dear Sir:
This letter refers to the special team inspection conducted by Region V on August 27 through September 15, 1984.
Attachment A provides our response to the Notice of Violation indentified in Appendix A of the referenced letter concerning Engineering Training.
Attachment B provides our response to the additional items of concern identified in the referenced letter.
Very truly
- ours, EEVB/TJB/mb Attachments FR.
E. E.
Van Brunt, Jr.
APS Vice President Nuclear Production ANPP Project Director cc:
R.
Zimmerman A. Gehr 8411210277 8411ib
(
ATTACHMENT A NOTICE OF VIOLATION Criterion V, to Appendix B of 10CFR50, states, in part, "Activities af-fecting quality shall be prescribed by documented Instructions, Procedures...
and shall be accomplished in accordance with the'se Instructions, Procedures, or Drawings."
Bechtel Engineering Department Procedure No. 5.34 states, in part, in paragraph 4.0, that "... Completion of training shall be within 60 days of the employee's date of assignment to the project/staff."
Contrary to the above, at the time of the inspection, it was found that about 30 out of 160 Bechtel project engineers did not have training records to substantiate compliance with the above requirements.
Additionally, it was found that management was aware of their staff's failure, to comply with the training requirements as evidenced by an Interoffice Memorandum dated October 18, 1983.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The training records were reviewed for compliance with Engineering Department Procedure EDP 5.34. It was found that Training Summary Sheets for 29 engineers at the jobsite were not completed.
No other noncompliances were found.
Each noncompliance was investigated and evaluated.
The evaluation showed that all but two individuals performing Tech-nical Engineering functions have previous experience on other Bechtel projects.
This experience establishes familiarity and understanding of Bechtel Engineering procedures.
Additionally, during their assignment at the Palo Verde site, all these engineers were involved in detailed day-to-day, on-the-job training in conjunction with their work.
Reading of procedures in conjunction with daily job activities was necessary.
Thus, the training was implemented but the required Training Summary Sheet was not completed as required by procedure.
Adequate training and understanding of site specific procedural requirements for the 29 engineers were verified by interviews con-ducted with each individual and documented by the subsequent com-pletion of the Training Summary Sheet.
Based on this information, no action is required to be taken in regard to any work completed by these individuals.
ATTACHMENT A NOTICE OF VIOLATION Page Two Engineering Management was aware of deficiencies in training records and did take initial corrective action.
The interoffice memorandum dated October 18, 1983 is evidence of this action and was written to correct conditions found prior to the memo date.
The conditions were corrected except for the training of one individual which has been evaluated as an isolated case.
Other actions which were taken as Engineering follow-up to the memo consisted of periodic reemphasis at Resident Engineering staff meetings, specific administrative follow-up, and personal contact.
Despite these actions, Engineering Management emphasis was inadequate to prevent recurrence.
CORRECTIVE STEPS TAKEN TO AVOID RECURRENCE:
As stated
- above, the root cause is attributed to a lack of specific procedural controls which would ensure required training records were completed within the specified time frame.
Reliance on Engi-neering Management attention alone has proved to be ineffective when balanced against total management purview.,
Revision 4 to the project Internal Procedure IP-2.10 is being pre-pared to clarify the specific administrative procedure to be followed for Bechtel Engineering personnel assigned to the jobsite.
This clarification will require that a training package be given to each newly assigned individual and specifically followed up by Engineering Management to assure compliance with EDP-5.34.'ny individual who has not completed the training requirement within 30 days will be specifically identified to Engineering Management.
An IOM signed by the Project Engineer or Resident Engineer will be issued to the responsible Group Supervisor, identifying individuals who are potentially in violation of the training requirement.
Additionally, to verify compliance with procedures, auditing of training records for Resident Engineers to EDP-5.34 will be included in the 1985 jobsite QA schedule.
Previous audits of training records did not identify this noncompliance because Resident Engineering was not specifically identified on either the design office or
, jobsite QA schedule.
Project QA shall review the design office QA audit schedule and applicable engineering procedures to determine if other areas exist where the design office audits of engineering do not include Resident Engineering activities. If other omissions are identified, they will be included in Project QA audit schedules for the first quarter of 1985.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance with EDP-5.34 was achieved on September 19, 1984.
Internal Procedure IP 2.10', Revision 4, will be issued by Decem-ber 21, 1984.
The review and preparation of project QA audit scheduled will be completed by December 28, 1984.
ATTACHMENT B NRC RE VEST FOR ADDITIONAL INFORMATION B.
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.
ANPP RESPONSE TO NRC CONCERN Just prior to this NRC inspection, an enhancement (integration) to the project control program for identifying, assigning, closing and maintaining the status of open items and commitments to the NRC (requiring resolution prior to the issuance of an operating license) was being made.
To support this enhancement, the following administrative control program and sub-tier implementing documents have been written:
Corporate Level:
5P406.00.00, "Action Tracking Policy".
5N406.01.00, "Action Tracking Procedure".
PVNGS Station Manual:
71AC-OZZ08, "Licensing Tracking System".
90GA-OZZ05, "Startup Master Tracking System".
Licensing Department Implementing Procedures:
5I406.01.01, "Licensing Commitment Tracking System".
5I406.01.02, "NRC Inspection and Enforcement Inspection Report Program".
5I406.01.03, "NRC Inspection and Enforcement Bulletins and Information Notice Program."
PTTACHMENT B Page 2
C.
Measurin and Test E ui ment Aspects of the quality assurance program for control of Measuring and Test Equipment (ATE) were reviewed.
Areas reviewed included work controls for performance of MRTE calibrations, control of MRTE in the field, method of recalling and controlling MRTE 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 MRTE 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.
ANPP RESPONSE TO NRC CONCERN ANPP equality Assurance has conducted an audit (84-026) relative to Measuring and Test Equipment, as well as evaluation of Out of Tolerance Notices.
The audit has revealed that the program is procedurally strong,
- however, weaknesses have been identified in some areas of implementation.
Final issuance of the audit report and assignment of recommended corrective actions is expected to be accomplished during the week of November 19, 1984.
The specific concern related to administrative controls has been addressed by revising the appropriate procedures 34AC-OZZ06, Revision 5 and 34AC-OZZ08, Revision 1 as committed to.
ATTACHMENT B Page 3
D.
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 surveillance; the system for scheduling and tracking surveillances; and the means of accomplishing surveillances and method of reviewing results of surveillances.
No violations of NRC rquirements 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 snubbers and (c) the.status of procedure verification of surveillance test implementing procedures.
These problems areas must be functional prior to plant operations.
Review of surveillance test implementing procedures is planned for future inspection activity.
ANPP RESPONSE TO NRC CONCERN a
The Director of Nuclear Operations has issued a directive to departments having Tech.
Spec. Surveillance Procedures indicating that the Plant Monitoring System is not to be used for recording Tech.
Spec.
Surveillance Requirements.
The exception to this is calculated points or instruments that do not have indicating devices such as readouts for the Fixed Incores.
ANPP RESPONSE TO NRC CONCERN b
The lack of specific Preventive Maintenance tasks for mechanical snubbers is specifically based upon the vendors tech manual.
As stated in the Pacific Scientific Technical Manual section on Maintenance, the snubbers are designed to be "practically maintenance free" and there are no maintenance inspections or services designated for specific time interval.
The normal Surveillance Test Inspection of visually looking at the snubbers at a prescribed interval and ensuring the snubbers are operable meets all of the Tech.
Spec.
requirements for the snubbers.
ANPP RESPONSE TO NRC CONCERN c
It has been ANPP's intent to validate (walkdown) Surveillance Test (ST)
Procedures.
Procedure validations will be documented and identified problems will be corrected within the procedures.
It is ANPP's position that the walkdown of procedures will enhance the initial test performances.
Additionally, actual "dry runs" for a selected portion of the ST procedures required will be completed prior to the Tech.
Spec.
required ST performance Where possible, ST's are already being performed in their associated periodicity.
ATTACHMENT B Page 4
I.
Document and Records Control durin Plant 0 erations Inspection in this area involved review of documents and records control procedures applicable to the operation 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 Quality 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.
ANPP RESPONSE TO NRC CONCERN ANPP Quality Assurance has conducted an audit (84-025) relative to the control of design drawings.
Based on the preliminary audit findings, as well as previously identified discrepancies, ANPP Nuclear Project Records Management is initiating a program whereby they will reduce the number of controlled drawing locations by approximately 65%
Additionally, they plan to reduce the number of controlled documents for which they will be required to control distribution.
This consolidation effort will provide the project with a precise, comprehensive document control program in line with Corporate and Regulatory objectives.
Final issuance of the audit report and assignment of any additional re-commended corrective actions is expected to be accomplished during the week of November 19, 1984.
ATTACHMENT B Page 5
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 adequate.
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 pract'ices 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 fo'r qualifications of maintenance personnel.
ANPP RESPONSE TO NRC CONCERN In response to the commitment made at the NRC exit, Maintenance Depart-ment Instruction 17, entitled "Maintenance Personnel Qualifications" is presently being generated to address the "basis" for qualification of Maintenance personnel.
This instruction will identify the program presently being used to select Maintenance personnel, the criteria by which an individual may be deemed to be fully qualified to perform his job function and duties, and the definition of the resulting records storage requirements.
This instruction is expected to be issued by December 6, 1984.