ML20072K801
| ML20072K801 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/10/1983 |
| From: | Woods T ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20072K763 | List: |
| References | |
| ANPP-24039-JAR, NUDOCS 8307060426 | |
| Download: ML20072K801 (4) | |
Text
..
ENCLOSURE 4 i
Arizona Public Service Company to aox 21666 e PHOENIX, ARIZONA 85036 3
THOMAS G WOODS. JR June 10, 1983 am/5IfE'rIE'E*'[dEscr ANPP-24039 - JAR Mr. J. B. Martin Regional Administrator U. S. Nuclear Regulatory Commission g
Region V W
a Creekside Oaks Office Park Q*
T 1450 Maria Lane - Suite 210 S
Walnut Creek, California 94596-5368 E*
o h
r
Subject:
Arizona Public Service Company (APS) Comments to NRC Ia (Q
Systematic Assessment of Licensee's Performance File: 83-010-026
Dear Mr. Martin:
on Wednesday, May 25, 1983, Arizona Public Service Company (APS) met with NRC Region V to review the results of NRC Region V Systematic Assessment of Licensee's Performance (SALP) for the period July 1, 1981, through February 28, 1983. The following confirms the comments on the SALP Report that were provided orally at the meeting.
1.
Operation 0.1, Page 6, Second Paragraph
" Attention by the applicant will be required to ensure that necessary procedures and controls are implemented prior to fuel load."
i Response.
Arizona Public Service Company management will ensure that necessary procedures and controls are implemented prior to fuel load.
2.
Operations 0.2 Radiological Controls, Page 7, Second Paragraph f
" Inspection of certain radwaste system components identified apparent departures from the FSAR equipment descriptions. The Licensee stated that these matters would be examined and inconsistencies between the installed equipment and the FSAR description will be resolved shortly.- Additionally, certain gaseous effluent sampling systems do not appear to meet the required standards."
8307060426 830630 PDR ADOCK 05000528 O
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Mr. J. B. Martin 1
4 Regional Administrator Page 2
Response
a.
The radwaste installation has been reviewed by Operations Engineering and inspected by Operations QA/QC and the system is installed in accordance with the FSAR except minor nameplate data which will be corrected.
b.
With regard to the isokinetic sampling, we are reviewing the 90 sharp radius bends in the system to evaluate their acceptability.
3.
Operations 0.3, Maintenance, Page 7, Last ?aragraph "At present the applicant is in,the process of developing procedures necessary for the support of corrective or major maintenance activities.
4 The efforts of the Maintenance staff in the support of preoperational test activity is diluting the effort to develop these procedures."
i
Response
l Arizona Public Service Company will assure that Maintenance will have adequate procedures for the major maintenance and the support of corrective action activities.
4.
Construction C.3, Piping Systems and Supports, Page 9, First Paragraph
" Piping systems and supports were examined in portions of twenty inspections. Five items of noncompl'iance were identified in the 1
following areas:
failure to follow procedure for weld filler metal oven use; failure to meet requirements for capping pipe ends; failure to follow procedure for documenting an out-of-calibration condition of an automatic welding machine; performance of an unauthorized weld in a safety-related drain line; and an engineering failure to provide supports for a vertical piping segment connecting to a safety related drain line. None of these items were major or repetitive, however, the number of items indicates a possible programmatic weakness. The Licensee's corrective action was timely and appears effective."
i j
Response
Arizona Public Service Company has carefully reviewed these five items of noncompliance and does not believe that these noncompliances i
indicate a programmatic weakness.
Based on analysis and consideration of-the effects and contents of the noncompliances, we are convinced that these are isolated incidences.
Some examples of our analysis of these items include:
l
Mr. J.
B. Martin Regional Administrator Page 3 (1)
Failure to Follow Procedure for Weld Filler Metal Oven Use This noncompliance was the result of a weld rod control attendant improperly using a weld rod oven. This occurred twice, one discovered by an NRC inspection and the second incident discovered during an ASME audit.
Both times, the employees were dismissed.
There are 161 rod ovens in use at Palo Verde and much effort is expended to assure that all aspects of weld rod control are in conformance to specifications. We feel this is an act of deliberate violation of procedures and not a programmatic weakness.
(2)
Failure to Meet Requirements for Capping Pipe Ends There has been a continued effort to meet this requirement.
Our program has identified, on various occasions, that pipe spools have been left uncapped. However, in consideration that there are approximately 100,000 pipe spools on the site, we feel the program has limited this from occurring too often.
(3)
Failure to Follow Procedure for Documenting Out-of-Calibration Condition of an Automatic Welding Machine This noncompliance was the result of our mistake in including in the procedures adjustments that determine the efficiency of the operation of the automatic welding machine as a calibration activity. This should not have been included as a calibration activity because these adjustments do not have anything to do with the calibration of the welding machine.
(4)
Performance of an Unauthorized Weld in a Safety-Related Drain Line This, in fact, occurred when an individual deliberately violated all existing procedures and performed an undocumented weld.
This is not a programmatic weakness.
l (5)
An Engineering Failure to Provide a Support for a Vertical l
Piping Segment Connecting to a Safety-Related Drain Line I
This, in fact, occurred. The complexity of the imbedded piping I
drawings made it difficult to determine that this atmospheric drain is not imbedded for approximately five feet (5').
Consequently, a support was not considered to be necessary.
Mr. J.
B. Martin Regional Administrater Page 4 5.
Construction C.6, Electrical Power Supply and Distribution, Page 11, Last Paragraph "Although there is evidence of aggressive management involvement in correcting both Licensee and NRC identified problems in the electrical area, the NRC considers that continued emphasis by the Licensee's management and quality assurance organization is required to prevent the types of problems identified and correct those that 1
are identified."
Response
Arizona Public Service Company assures that we will continue to i
emphasize management and quality assurance activities and assure that the electrical and instrumentation meets our FSAR requirements.
We also assure you that the previous problems identified have been appropriately corrected and steps will be taken to prevent recurrence.
Arizona Public Service will continue our high level corporate management involvement in the activities at the Palo Verde Nuclear Generating Station to continue our assurance that safety and quality remains our highest priority.
1 Very truly yours, r
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TGWOODS:asd v
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s Mr. J. B. ~ Martin Regional Administrator Page 5 Distribution:
Richard DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission l
Washington, D.C.
20555 i
G. C. Andognini J. A. Roedel D. B. Fasnacht A. C. Rogers B. S. Kaplan W.
E.
Ide J. Vorees i
J. R.
Bynum D. Green /P. Klute A. C. Gehr W. J. Stubblefield (Bechtel-PVNGS)
W. G. Bingham. (Bechtel-PVNGS).
R. L. Patterson (Bechtel-Downey)
R. Welcher (Bechtel-Downey) g R. M. Grant (Bechtel-PVNGS)
D. R. Hawkinson (Bechtel-PVNGS)
L. E. Vorderbrueggen (NRC Site Inspector-Construction)
G. A. Fiorellf, (NRC Inspector-Operations)
Records Centtr - INPO K. L. Turley E. E. Van Brunt, Jr.
C. W. Lacey (Bechtel-Los Angeles)
.J.
E. Kirby B.
F. Godwin G. E. Pankonin C. N. Russo
~O.'M. De Michele I
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