ML17299A913
| ML17299A913 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/19/1985 |
| From: | Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17299A911 | List: |
| References | |
| 50-528-85-31, NUDOCS 8601080531 | |
| Download: ML17299A913 (8) | |
Text
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9 PDR APPENDIX B NOTICE OF DEVIATION Arizona Public Service Company P.
O.
Box 21666
- Phoenix, Arizona 85036 Docket No, 50-528 License No. NPF-41 As a result of the inspection conducted October 28 through November 8,
- 1985, a
deviation involving inadequate control of the design process was identified.
In accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C, 47 FR 9887 (March 9, 1982) the deviation is described below:
Section 1.8 of the Palo Verde Nuclear Generating Station FSAR endorses Regulatory Guide 1.64 (Revision 2) for operations phase activities with the following exception to position C.2 of the regulatory guide:
"Supervisory personnel may perform design verification under exceptional circumstances as documented and approved by the next level of supervision, if the justification...is individually documented and approved in advance."
Contrary to the above commitment, the Bechtel engineering organization has used their supervisors to perform design verification reviews without documented individual justification being approved in advance for each and every design change package since commencement of Vnit 1 operations activities (i.e., January 1985).
This is a deviation.
Please submit to this office within thirty days of the date of this notice a written statement or explanation regarding the above item, describing corrective steps
- taken, the results achieved (or corrective steps that are planned),
and the date when corrective actions will be completed.
OEG 19 1985 Dated To bert Young, Jr., Chief Engineering Sectio
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RESPONSE
TO NOTICE OF DEVIATION (50-528/85-31-04)
CORRECTIVE STEPS TAKEN FSAR Section 1.8 imposes the requirements of Regulatory Guide 1.64, Revision 2 after the issuance of an Operating LLcense.
It also allows (as discussed in the Notice of Deviation) the exception to position C.2 of the regulatory guide.
For activities to be performed prior to the issuance of an operating license, the Bechtel program complies with ANSI N45.2.11-1974, Section 6.1, which allows design verification to be performed by the originator's supervisor without prior documented approval.
Regulatory Guide 1.64, Revision 2,
effectively takes exception to ANSI N45.2.11, Section 6.1, by not allowing the originator's supervisor to perform design verification.
Since Bechtel Engineering was neither fully aware of the programatic impact of Regulatory Guide 1.64, Revision 2,
on operations phase activities nor that portion of the ANPP Operational QA Program which endorses Regulatory Guide 1.64, Revision 2
and complies with the
- FSAR, the requirement of ANSI N45.2.11-1974, Section 6.1, which had been used for construction phase activities continued to be used since commencement of Unit 1 operations activities.
'The regularly scheduled
- audit, by ANPP QA, of Bechtel's on site design activities in January, 1985 did not identify this inconsistency since Bechtel had not yet performed safety related design activities under the newly issued operating license for Unit 1.
The audit scoping matrix for ANPP requires that the Design Change Packages (DCPs) looked at during the on-site audit of Bechtel be used for the ANPP QA audit of Bechtel's design office (NORWALK).
Since no safety related DCPs had been generated, as stated
- above, this area was not examined during the design office audit, therefore, ANPP QA did not discover this inconsistency.
Because of this inconsistency between the design review requirements for operations phase activities and the design review requirements that were actually being performed, the following corrective steps were taken:
1.
CA85&252 on ll/12/85 that required Bechtel to address the issue of supervisors performing design verifications.
2.
A complete review of FSAR Section 1 has been completed by Bechtel Quality Assurance for other impacts to the ANPP Operational QA Program.
3.
Bechtel has completed a
review of all their project procedures which involve design verification in accordance with Regulatory Guide 1.64, Revision 2
and ANSI N45.2.11.
Only the following procedures were found to be in need of revision or clarification to demonstrate compliance with the Operational QA Program with respect to supervisors performing design verifications:
IP&.12, "Project Engineering Drawings and Drawing Change Notices";
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RESPONSE
TO NOTICE OF DEVIATION (50-528/85-31&4) Cont'd CORRECTIVE STEPS TAKEN (Cont'd)
IP<.14, "Specification Change Notice"; and IP-5.15, "Supplier Deviation Disposition Requests".
4.
Bechtel issued to responsible personnel an Inter-Office Memorandum, dated 12/9/85 which described interim changes to their Internal Procedures necessary to ensure documented independent design verification and to preclude the immediate supervisor from this activity.
II.
RESULTS ACHIEVED OR CORRECTIVE STEPS PLANNED Based on the corrective steps
- taken, the following results have been achieved:
1.
The review of FSAR Section 1.8 by Bechtel Quality Assurance concluded that no other conditions similar to the design verification problem were found to exist.
2.
Bechtel has initiated changes to procedures IP-4.12, IP&.14, and IP-5.15, as discussed in Item I.2,
- above, to provide independent design verification separate from the immediate supervisor to comply with Regulatory Guide 1.64, Revision 2, requirements.
3.
The interim changes described in Bechtel's InterWffice Memorandum, dated 12/9/85, brought the Internal Procedures into compliance with the ANPP Operational QA Program.
4.
ANPP QA/QC have reviewed and accepted Bechtel's response to CAR No.
CA85%252.
This response concluded that the deficiency was purely programatic, and had no impact on the design work performed by Bechtel since issuance of the Unit 1 Operating License.
ANPP is currently verifying the response.
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ANPP QA will perform a review of major design contractor programs and procedures to ensure applicable design control regulatory requirements are adequately addressed.
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RESPONSE
TO NOTICE OF DEVIATION (50-528/85-31&4) Cont'd III.
DATE WHEN CORRECTIVE ACTIONS WILL BE COMPLETED Corrective actions that remain to be completed are scheduled to be completed as follows:
1.
The changes to Bechtel Internal Procedures IP-4.12, IP<.14, and IP-5.15 were approved for use by Bechtel on January 8, 1986.
2.
The verification of the conclusion that there was no impact on the design work performed by Bechtel since the issuance of the Unit 1 Operating License is scheduled to be completed by the end of first quarter 1986.
3.
The review of major contractor design programs and procedures is scheduled to be completed by the end of second quarter 1986.
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