ML20054K799

Responds to NRC Re Violations Noted in IE Insp Rept 50-528/82-09.Corrective Actions:Administrative Steps to Identify Responsibilities for Cleanliness & Equipment Protection Completed on 820518

ML20054K799
Person / Time
Site:	Palo Verde
Issue date:	06/10/1982
From:	Andognini G ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20054K794	List: IR 05000528/1982009 ML20054K799
References
NOS-82-519, NUDOCS 8207060162
Download: ML20054K799 (4)

Text

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ELECTmeC OPinattONS June 10, 1982 Mr. Robert II. Engelken Office of Inspection and Enforcement Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek Plaza Walnut Creek, CA 94596

SUBJECT:

DOCKET 50-528 CPPR-141 PALO VERDE NUCLEAR GENERATING STATION IE INSPECTION REPORT 82-09 IE Inspection Report 50-528/82-09 dated May 12, 1982 identified two items of non-compliance. We have reviewed the subject inspection report and are providing the attached response for the two items.

Arizona Public Service is in full compliance with the items identified and plans to take no further action other than that specified in our attached responses.

Sincerely, a fu 4 GCA/SRF/j eh Attachment cc: Director, Office of Nuclear Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector--PVNGS NRC Project Manager-File: 82-055-026 8207060162 820625

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• ATTACHMENT ARIZONA PUBLIC SERVICE COMPANY

$ RESPONSE TO IE INSPECTION REPORT NO. 50-528/82-09' DOCKET NO. 50-528 CONSTRUCTION PERMIT NO. CPPR-141 ITEM 1 Criterion II of Appendix B to'10 CFR 50 states, in part, that, " Activities affecting quality shall be accomplished under suitable controlled conditions.

4 Controlled conditions include... suitable environmental conditions for accomplishing the activity, such as adequate cleanness . . . .'.'

Bechtel Procedure WP/P-QCI No. 13, " Housekeeping" states in Paragraph 6.4.4.1, "A Zone IV stea or item shall be swept clean of dirt and debris ...." and states in Juragraph 6.5.2.2 for a Zone V area, " Garbage, trash, scrap, litter, and other excess waste materials shall be collected and disposed.

of by burning, burying or removal from the jobsite. Such excess material shall not be allowed.to accumulate."

! Contrary to the above on April 15, 1982, the inspector observed the following:

a. Excessive debris, concrete dust and fire protective insulation fines were found accumulated on equipment and floors in the Zone IV Class IE' battery charger rooms. Several equipment protective coverings had been removed exposing opened electrical cabinets which were energized to the degraded environment.

b. Empty soft drink cans, insulation pads, hoses and other debris had been discarded in a Zone V confined area between the outside control

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i room shutdown cabinets. An accumulation of concrete and fire protec-

! tive insulation fines had also accumulated within the cabinets which were posted as energized.

This is a Level V Violation (Supplement II) i.

RESPONSE TO ITEM 1

1. Corrective Steps Which Have Been Taken and the Results Achieved i The battery charger rooms, remote shutdown cabinets and adjacent

areas have been cleaned by removing trash, dirt, and unnecessary

construction material. Also, Prerequisite Test Directors and l Startup' Engineers have been directed to conduct frequent inspec-

tions of areas containing energized electrical equipment noting

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cleanliness among other things, with particular emphasis on j

equipment important to nuclear safety.

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Page 2:

IEIR 82-09 PVNGS

2. Corrective Steps'Which Will Be Taken to , Avoid ~Further. Items of Noncompliance Letters on General Housekeeping Requirements and Housekeening/-

Protection of. Equipment have been issued to'all. personnel working at Palo Verde Nuclear Generating Station (PVNGS)! signed jointly by APS and.Bechtel persons responsible,for construction, startup and operation of PVNGS. These letters provided guidelines for maintaining general housekeeping conditions and made viola-tion of- housekeeping requirements grounds for. immediate termina-tion. They also assigned specific responsibilities for the' maintenance of cleanliness.and protection of plant equipment in various plant areas as-equipment and areas progress fromL Bechtel Construction to Bechtel or APS.Startup and, eventually,.

to APS Startup or Operations jurisdiction.-

3. Date When Full Compliance Will Be Achieved As of May 18, 1982, administrative steps to clearly identify responsibilities for cleanliness and equipment protection were completed. By May 20, 1982, applicable personnel had.been-briefed and procedures were implemented.

ITEM 2 Criterion V; of Appendix B to 10 CFR 50 states, in.part, that " Activities.

affecting quality shall be prescribed by documented instructions, procedures, or drawings, of'a type appropriate to the circumstances and shall be accomplished in accordance with these instruction procedures, or drawings. . .." .

The Becthel Administrative Control Procedure AD 115, " Temporary. Modification Controls", states in Paragraph 5.1.2, " Field identification of temporary modifications shall be accomplished by attaching the Temporary Modification Tag .. . . Tags shall be placed conspicuously and wherever- possible directly on the wire, cable, or component actually modified." ,

Contrary to the.above, on March 26 and 29,-1982, theinspectornotedthAt l pressure safety valves had been replaced with temporary' vents at the following l Unit 1 locations and the modified components were not tagged as required by

{ the procedure.

1,

a. Containment Sump Line - Line B

b. Safety Injection Tank 1B ac. Safety Injection Tank 2B

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This is a Severity Level V Violation (Supplement II). '

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Page 3 IElR 82-09 PVNGS RESPONSE TO ITEM 2

1. Corrective Steps Which Have Been Taken and the Results Achieved

a. An investigation showed that tags for the temporary modifications listed were issued as follows:

a) On Containment Sump Line - Line B (lPSIE-PSV140)

Issued - February 8,1982.

b) On Safety Injection Tank - 1B (1PSIB-PSV241)

Issued February 19, 1982.

c) On Safety Injection Tank - 2B (lPSIB-PSV221)

Issued February 19, 1982.

Apparently they had been inadvertently removed or destroyed sometime between their issuance and March 26 and 29. Duplicate tags were issued for the above temporary modifications and hung March 26 and March 29, 1982.

b. The above temporary modifications were removed and permanent plant equipment relief valves reinstalled on May 10, 1982, and applicable temporary modification tags were removed and cleared at that time.

2. Corrective Steps Which Will Be Taken to Avoid Further Items of Noncompliance I Prerequisite Test Directors and Startup Engineers have been directed to ,

periodically verify from tag logs that tags shown as outstanding and I l

installed are actually installed in the indicated locations. Duplicate tags will be-issued and placed if the original tag is found missing.

3. Date When Full Compliance Will Be Achieved Full compliance was achieved April 9, 1982.

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