ML17299A459
| ML17299A459 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/23/1985 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8507300350 | |
| Download: ML17299A459 (6) | |
Text
MEMORANDUM FOR:
J.
G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement FROM:
D. F. Kirsch, Acting Director Division of Reactor Safety and Projects Region V
SUBJECT:
REGION V RESPONSE TO ASSESSMENT OF PAKO VERDE UNIT 3 CONSTRUCTION INSPECTION PROGRAM Region V has completed a detailed review of the written assessment of the implementation of the Palo Verde Unit 3 construction inspection program.
The enclosure to this memorandum documents the corrective actions we have taken or planned to fully respond to each detail of this assessment.
Region V concurs with the assessment's conclusion that the MC 2512 construction program is being acceptably implemented, and that considerable effort remains~ to.complete, this program.
Region V has recently committed additional res'ources to this, program and will ensure that the program is completed.,
Your assessment has,'b'een
- valuable, and is app'reciated.
'rf)inat stoned by D., F. Kirsch I Il D. F. Kirsch, Acting Director Division of Reactor Safety and projects Region V
Enclosure:
Assessment
Response
cc w/enclosure:
J. Martin, RV A. Chaffee, RV L. Miller, RV bcc w/enclosure:
RSB/Document Control Desk (RIDS)
Resident Inspector RV/dot KIRS 7/gg /85 8507300350 850723 PDR ADQCK 05000530 8
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RESPONSE
TO ASSESSMENT FINDINGS 1.
766 Computer System Data was found to be incomplete As noted in the assessment, Region V recognized that the 766 Computer System Data was incomplete, but established a basis for program completion using other manual tracking documents.
The assessment questions whether, in several instances, certain modules should have been considered completed.
a
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(}uality Assurance Modules 35061 B, 35060 B and 35065 B
Region V agrees that, in light of changes in licensee gA management in 1984, it is appropriate to reperform Modules 35060 B and 35061 B.
Module 33065 B was last performed in 1984 (Report No. 50-530/84-09) as indicated by the 766 data, and will not be reperformed.
b.
equality Assurance Procedure Review Modules (45051 B, 47061 B, 48061 B, 53051 B, 55171 B, and 55181 B)
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Region V,'s position is that. these procedure review modules have been adequately inspected.
The rationale for this position is that the review of these modules for Unit 1, combined with the understanding that ea'ch of these procedures was necessarily reviewed by the inspector for'Unit 3 in order to complete of associated work observation modules. 'hanges to the controlling procedures would
,have been reviewed, at that time.
Rereview of these procedures solely to address the gA modules would not be a sound resource expenditure at this'; time.
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Welding Modules in 550XX and 551XX Series Region V agrees that'it was not readily apparent from the records reviewed that NDE,and records, review inspection requirements had been satisfied by p'erforming the 551XX series modules in lieu of the 550XX Series.
A review of these modules was conducted, subsequent to the assessment.
Region V concluded that the scope and intent of the NDE and records review requirements has been met.
gf Region V believes it has inspected the NDE area thoroughly.
Specifically, during the CAT inspection of September,
- 1983, numerous piping welds in Unit 1 were independently examined using the Region I NDE van, and structural welds in Units 1 and 3 were visually examined.
Additional areas where NDE was inspected were documented in the Palo Verde Construction Inspection History Study.
- However, to gain additional confidence that Unit 3 NDE, specifically, was
- adequate, additional NDE inspection will be performed prior to the completion of construction at Unit 3 using 550XX Series requirements.
With respect to records review requirements, Region V believes the quality records aspects of these modules are adequately addressed in
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modules
- 55154, 55155,
- 55156, and 55157, which have been scheduled for completion at Unit 3.
Additional reports which documented inspection in the area of (}uality Records are Reports 77-02, 77-04, 79-05, 79-10, 80-03, 80-05, 80-17, 81-01, 81-12, 82-02, and 83-34.
2.
The MC 2512 program will be completed for Unit. 3 prior to the initial licensing of Palo Verde Unit 3 (currently March, 1987).
This will be accomplished using two construction resident inspectors augmented by approximately twenty manweeks of onsite regional construction inspection.
As of June 22,
- 1985, 837 hours0.00969 days <br />0.233 hours <br />0.00138 weeks <br />3.184785e-4 months <br /> of direct inspection had been accomplished on Unit 3 in FY 84. It is anticipated that 1214 hours0.0141 days <br />0.337 hours <br />0.00201 weeks <br />4.61927e-4 months <br /> will have been expended by the end of PY 84, not including overtime.
3.
Region V agrees that the inspection report cover page should list the inspection procedures
- used, and has begun to do this.
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