ML20080B429
| ML20080B429 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/31/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8402070133 | |
| Download: ML20080B429 (160) | |
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a P. O. B O x 216 6 6 PHOE NI X, ARIZON A 85036 January 31, 1984 ANPP-28749-EEVB/WEI Director Office of Inspection and Enforcement U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Response to Enforcement Letter and Notice of Violations, dated December 12, 1983 File:
84-070-026
Dear Sir:
Arizona Public Service Company (APS), Project Manager and Operating Agent for the Palo Verde Nuclear Generating Station (PVNGS) and licensee under CPPR-141 issued in Docket No. 50-528, sdomits herewith its response to the enforcement letter, dated December 12, 1983, from the Regional Administrator, Region V, and to Sections I.A. and II of the Notice of Violations (Notice), dated December 12, 1983, transmitted with such letter.
The allegations made in Sections I.A.
and II of the Notice stem from the unannounced inspection of Palo Verde Unit ] in September, 1983, by the Region V Construction Assessment Team (CAT).
The response consists of five parts set forth in Attachments A through E to this letter:
Attachment A -
APS Management Actions Responsive to the Construction Assessment Team (CAT) Inspection and the Notice of Violation Attachment B APS Response to Certain Issues Common to Several of the Alleged Violations Attachment C APS Response to Section I.A. of the Notice of Violation for Which a Civil Penalty Is Proposed Attachment D APS Response to Section II of the Notice of Violation for Which No Civil Penalty Is Proposed 8402C70133 840131 PDR ADOCK 05000529 0
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Diractor, Offica of In:psction and Enforcement January 31, 1984 Page Two Attachment E APS Separate Answer, Filed Pursuant to 10 CFR 2.205, Protesting the Assessment of the Civil Penalty Proposed by Section I.A. of the Notice of Violation Attachment A explains in detail the comprehensive actions which APS management has taken in addressing the general observations made by the Regional Administrator for Region V in the enforco-ment letter.
The first step taken was the initiation of inten-sive internal and independent audits of the Palo Verde startup program.
The audits were comprehensive in scope covering all activities that take place during startup -- tests and inspec-tions, construction, maintenance and quality control.
The findings of such audits led to a series of follow-up actions:
The suspension of startup work and testing coordinated by the APS Startup organization.
The organization of a broadly based task force to evaluate and recommend measures which strengthen and improve management control of activities performed during startup.
Establishment of an improved work control program for work performed during startup.
Changes in organizational structure to improve controls of interfaces between the organizations involved in startup work.
Renewed efforts in the training and indoctrin-ation of all Palo Verde personnel to implement our goals of safety and quality.
Institution of a comprehensive reinspection program reaching beyond the limited scope of the CAT Inspection.
Attachments B, C and D address the specific alleged violations in Sections I.A.
and II of the Notice.
The violation alleged in Section I.A.,
for which a $40,000 civil penalty is proposed, is denied.
The grounds for the denials include:
Inaccuracies in the allegations.
Lack of safety significance.
Improper assignment of severity levels.
l Dircctor, Office of Inspection I
and Enforcam3nt January 31, 1984 Page Three l
Attachment D, which addresses Violations in Section II of the Notice for which no civil penalty is proposed, requests that the severity levels assigned to such violations be reduced.
These attachments also describe the steps taken and to be taken to correct the conditions found during the CAT Inspection and
-to preclude their recurrence.
Attachment E protests the civil penalty assessed in Section I.A.
and requests its complete remission.
In the alternative, the attachment requests mitigation of the penalty.
Apart from the alleged violations stemming from the CAT Inspec-tion (i.e., Sections I.A. and II), the Notice also includes in Section I.B.
an alleged violation resulting from an NRC investi-gation of allegations made in the Spring of 1982 by an individual who was then or had previ'ously been employed at the site.
The report of such investigation-has not been made public nor dis-closed to APS.
For that reason, APS requested an extension of time to respond to the alleged violation until all of the infor-mation on which it is based is made available.
This request has been granted, and APS will make a full and complete response to Section I.B. within the extended time.
At this time, however, we are submitting as Attachment F a partial response to Section I.B. of the Notice.
Attachment F addresses some of the technical aspects surrounding the alleged violation.
It does not address the elements of the alleged violation relating to the persons involved and their respec-tive responsibilities, because (i) information obtained by the NRC on such elements has not been made available to us; (ii) we have restricted our investigation of these elements on advice of counsel that such an investigation by APS could be
. construed as interfering with an ongoing federal investigation; and (iii) the matter has been referred to and is currently under review by the Department of Justice.
Since the partial, technical response to Section I.B. may have some relevancy to the matter of the intent of the individuals involved, we suggest that consideration be given to providing such response to the Department of Justice.
We have no objec-tion if you follow this course.
1 We previously sent you on January 11, 1984, a copy of our response to the Notice of Deviation which accompanied the Notice of Violation.
Dir3ctor, Office of Inspection
.and Enforcement January 31, 1984 Page Four If there are any questions concerning these matters, please do not hesitate to contact me.
Very truly yours,
{. rD.
Gl AA LA.A _
N E. E. Van Brunt, Jr.
Vice President, Nuclear EEVBJr:ACG: jaw Attachments cc:
J. Martin, Region V, NRC L. Vorderbrueggen,1.dC l
G. Fiorelli, NRC K. L.-Turley l
T. G. Woods, Jr.
W. E.
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STATE OF ARIZONA
)) ss.
COUNTY OF MARICOPA )
I, Edwin E. Van Brunt, Jr., represent that I am Vice President, Nuclear of Arizona Public Service Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its contents, and that to the best of my knowledge and belief, the statements made therein are true.
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Sworn to before me this 3/4 day of January,1984.
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ATTACHMENT A APS MANAGEMENT ACTIONS RESPONSIVE TO THE CONSTRUCTION ASSESSMENT TEAM (CAT)
INSPECTION AND THE NOTICE OF VIOLATION i
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ATTACHMENT A Page 1 APS MANAGEMENT ACTIONS RESPONSIVE TO THE CONSTRUCTION ASSESSMENT TEAM (CAT) INSPECTION AND THE NOTICE OF VIOLATION From the very inception of the Palo Verde project, the senior managementM of APS has actively participated in the management of the project, the quality assurance program established for the project, and the interfaces with the two major contractors engaged in the project, i.e.,
Bechtel and Combustion Engineering.
This intimate involvement of senior management is seen as a major contributing factor to the successes and record of achievements which Palo Verde has attained up to date.
Senior management is deeply committed to maintain this record of achievement throughout the startup and operation of Palo Verde.
While the CAT Inspection resulted in the finding "that basic construction appeared to be generally satisfac-tory,"E the number of deficiencies which were found (al-M
" Senior management" when used in this document refers to those officers of APS who are members of its Board of Directors, currently the Chairman of the Board of Directors and Chief Executive Officer, President and Chief Operating Officer, Executive Vice President, Arizona Nuclear Power Project, and Executive Vice President, Finance.
" Project management" when used in this document refers to the APS' Vice President, Nuclear Projects and Vice Presi-dent, Nuclear Operations and, unless the text indicates otherwise, Bechtel's Vice President and Manager of Domestic Operations, Project Manager, Construction Manager and Proj-ect Engineering Manager.
CAT Inspection Report, page 2.
ATTACFENT A Page 2 though acknowledged by the CAT Inspection team to be for the most part " minor in nature") and, particularly, the general observations reflecting upon the effectiveness of management control of the transition from construction to operation have served to intensify and deepen APS' senior management involvement and participation in the startup of Palo Verde.
There can be no question that the CAT Inspection has achieved the purposes of Appendix C to 10 CFR Part 2.
The CAT Inspection finding of an apparent " weak-ness in quality assurance and/or a lack of management con-trol by the APS Operations and Startup Groups"M was not a total surprise to APS management.
Because of concerns re-specting this area, APS project management (i.e., the Vice President, Nuclear Operations) had instituted preparation of a series of administrative controls in May, 1983.
These new controls and associated procedures were implemented on Sep-tember 27, 1983.
On August 30, 1983, separate reviews of 1
l prerequisite data in the electrical area and the mechanical, I
instrumental and control, and fire protection areas were i
instituted by the APS Vice President, Nuclear Operations.
l This action was followed.on September 9, 1983, with the designation of a Startup Data Review Task Force which was given the charter to:
(i)
Review the acceptance criteria used in the preceding data reviews; M
CAT Inspection Report, page 2.
A'"TACHMENT A Page 3 4
(ii)
Review the management systems used in startup; (iii)
Review the adequacy of the Disci-pline Test Schedule; (iv)
Review the reportability of infor-mation obtained under Section 50.55(e); and (v)
Develop appropriate corrective action recommendations.
Consequently, it is evident that, prior to the CAT Inspection, APS project management had detected the exis-tence of problems in the startup work and, prior to the CAT Exit Meeting, had instituted some corrective measures.
As a result of the discussions at the CAT Exit Meeting on September 30, 1983, APS project management, under the intensive direction and guidance of senior management, has undertaken a comprehensive series of additional actions, including (i) unifying the responsibility and authority for engineering, con-struction, startup, operation and maintenance of Palo Verde under one vice president; (ii) restructuring organizational groups to provide improved control of in-terfaces; (iii) establishing a defined control pro-gram for all work and testing per-formed subsequent to transfer of systems, subsystems and areas by Bechtel construction; (iv) retraining of personnel to the new work control program; (v) reinspecting or reviewing major portions of work and tests pre-viously performed; and
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ATTACHMENT A Page 4 (vi) improving the effectiveness of qua-lity control activities during con-struction and startup.
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Perhaps most importantly, APS management has re-newed its efforts to indoctrinate the personnel at Palo Verde with two concepts:
l
-(a) safety and quality continue to be the two primary goals in completing Palo Verde; and (b) meticulous. attention to detail in the performance of work and com-pleting requisite documentation is vital in achieving those primary goals.
The discussion that follows describes in greater depth the nature, scope and timing of the foregoing APS management actions.
The NRC Enforcement Lette'r dated December 12, 1983,
' pointed out two overall management control and quality as-surance program deficiencies observed during the CAT Inspec-l tion.
The management deficiencies perceived by the CAT are:
1.
Lack of effective management con-trols and weaknesses in quality pro p s implemented assurance during startup 2.
The Construction Quality Control inspection program allowed a number of minor deficiencies to go unde-tected.
l l
M "Startup" means all of the work and testing performed from the time a system is transferred from Bechtel construc-l.
tion to the APS Startup organization to the time that the system is accepted by PVNGS Nuclear Operations.
This in-cludes Prerequisite Testing and Phase I Preoperational Testing, as defined in the PVNGS FSAR, Section 14.2.1.
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ATTACHMENT A Page 5 These NRC concerns had also been expressed at the Exit Meeting held by the NRC with APS senior managementE/ after the completion of the CAT Inspection on September 30, 1983, and the Enforcement Conference held on November 23, 1983.
After the CAT Inspection began on September 6, 1983, APS project management initiated a number of positive actions, some of which were implemented before the Exit Meeting on September 30, 1983.
The actions taken encom-t passed a detailed investigation of the concerns expressed by the NRC.
The results of the investigation were reported to, and analyzed by, APS and Bechtel senior management.
Where problems were noted, management initiated action to evaluate possible solutions not only for the specific problem iden-tified, but als'o to determine and correct the root cause.
The proposed solutions were presented to management and action was taken to assure that overall management controls would ensure activities affecting quality were properly j
planned, controlled, carried out and documented.
The spe-(
cific actions taken are noted below for each of the NRC Concerns.
l 5/
Project management, other project personnel at the managerial level, and officers of each of the other utili-ties participating in Palo Verde also attended the Exit Meeting.
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I ATTACHMENT A Page 6 I.
Management _ Control and Quality Assurance During Startup Even before the end of the CAT Inpsection, it was i
clear that the NAC perceived a weakness in the management 1
controls and quality assurance program as implemented during the Prerequisite and Preoperational Testing phase of the plant.
This subject was discussed'briefly at the meeting between the CAT and members of project management on Septem-l ber 16, 1983, that was held to provide a status report on the CAT Inspection.
As previously noted, project management was already aware of some documentation, interface and control problems during this phase of the project.
The problems were thought to be partially a result of the several reor-ganizations and changes in the administrative program imple-mented during startup.
Also, as previously noted, a task force had been designated on September 9, 1983, to consider these matters and a new series of administrative controls and associated procedures, which had been in preparation during the preceding months, were implemented on Septem-
.ber 27, 1983.
Nonetheless, having heard the concerns expressed at the Exit Meeting by the CAT inspectors and members of NRC Region V management, the Vice President, Nuclear Operations requested immediately thereafter that APS Corporate Quality Assurance conduct a detailed audit of safety-related systems and all activities which occurred from the time of transfer t
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ATTACHMENT A Page 7 of a system from construction to startup until the accep-tance of the systen by PVNGS Nuclear Operations, including activities performed by Bechtel construction and APS Main-tenance.
This internal audit was conducted to give APS senior and project management an overall evaluation of the effectiveness of the programs and controls in use during the startup phase of the project.
The internal audit was con-ducted in two parts by separate groups.
The first was an audit of the activities performed by the APS Startup organ-ization and Bechtel.
This audit was conducted using fifteen auditors under the direction of the Startup QA/QC Manager from October 17 through November 6, 1983.
The second part of the audit, which ran concurrently, at$dited the activities of APS Maintenance.
The results of these audits indicated several weaknesses in program control, particularly at interfaces between organizations and in some cases the lack of proper implementation of the prescribed controls.
Additionally, APS senior management, shortly after the CAT Exit Meeting on September 30, 1983, commissioned an independent assessment to evaluate the construction, startup and operations programs with respect to regulatory compli-ance and readiness to receive an operating license.
The assessment was conducted by a team which was led by an experienced person from another utility.
Members of the assessment team included other personnel from the other utility, from Bechtel (but not associated with the project)
____m__
ATTACHMENT A Page 8 and from the Palo Verde project.
This independent assess-ment, with recommendations for ircprovements, was presented to APS senior management in late December, 1983.
In response to the deficiencies identified by the internal audit, the APS Vice President, Nuclear Operations-l formed the Project Management Interface Task Force on Novem-ber 22,
- 1983, to provide recommendati ons for project-integrated corrective action to resolve the program and control problems identified by the audits and CAT Inspec-tion.
Additionally, recognizing that the deficiencies identified by the audits could have an overall effect on the validity of testing and the acceptability of work performed, he ordered on November 23, 1983, all sEfety-related work ^and testing coordinated by the APS Startup organization be n
suspended until a unified project review and evaluation was conducted.
This suspension of work did not include repair -
work being performed by Combustion Engineering on nuclear supply system components because of the adequacN of l
steam l
the independent controls on this work provided by combustion
[
Engineering, Bechtel and APS.
i' The Project Management Interface Task Force was composed of senior project. personnel from the major organ-izations of APS and Bechtel involved in the project who were temporarily relieved of all other responsibilitiez. ^ The Task Force was chartered to develop and recommend a consis-tent, integrated program to respond to the problems per-1
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3-ATTACHMENT A Page 9 ceived, including consideration of various Corrective Action Requests then pending.
The Task Force was also directed to develop a recommended program which would be suitable to provide necessary and consistent management controls and te regain, through review, inspection or retest, any loss of-control that may have been present.
This action was desig-nated to assure that, in the final analysis, it could be
-da'monstrated that startup had been performed in a controlled s
manner and was supported by documented evidence.
The Task Force recommendations, developed after discussions with all levels of APS and Lechtel, were completed and presented to APS senior management'on January 17, 1984.
l To resolve the deficiencies discovered during the various evaluations 'and audits and to implement many of the l
management actions and controls recommended by the Task Force and the Assessment Team, APS management has taken, or T
has in process, a number of management actions including:
1.
Organization restructuring.
2.
Development and implementation of a program.for resumption of work and (s
testing under controlled condi-tions.
l 3.
Development and implementation of a program to assure that requirements for an operating license have been or will be satisfied.
These actions described more fully below, which have been, are being or will be implemented, will be incor-porated in project programs and procedures and will be
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Page 10 e
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1.
Organization Restructuring.
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4 On January 5, 1984, the management organization
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for Palo Vebde was significantly changed as shown ons Figure 1.
The key element nE this restruct'uring is that the APS managers of all project activities,
'i'.e.,
engineering, construction, startup, operation and main-
,V tenance, will now - report and be responsibile ' to a
-single point of control, i.e.,
the APS Vice President s
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Y Following this change, the Vice Dresident, Nuclear instituted the position of Transition Manager, Fig'tre 2.
This position provides a single. manager with the au-y thority and responsibility for all activities necessary s
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to accomplish and control the transition from the con-1 g
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struction phase to full power operation.
Figure 3 l
shows the Transition Manager's organization which pro-7 vided the resources to accomplish all necessary tasks.
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l The k'ey element of this step is that the Transition t
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,1 Manager provides a means for centralized management and coordination of the interfaces among the several organ-i.
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' Recommencement of Startup Work.
l.
A' program and schedule is being dev, loped to allow testing and work to resume in a planned, controlled i
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ATTACHMENT A Pcga 11 manner.
The plan consists of four basic actions de-fined below, a.
Determine the priority of work and testing required.
This step is taken so that work and testing c.n be resumed in a planned fashion, starting with the most critical activities.
It also allows resumption of work and testing sequentially in a controlled manner so that the effectiveness of the program can be evaluated, and any additional re-quired corrective action can be taken in a timely fashion.
b.
Ensure that subsystem configurations are known.
A series of walkdowns to specified criteria have been and are being conducted to assure that the configuration of each subsystem is known prior to the resumption of testing.
Since it is pos-sible that some undocumented changes were made in the configuration of systems, management has determined that prior to resumption of any pre-operational testing, the actual configuration of the component or system must be verified against design drawings.
Deviations are documented and evaluated by engineering and the deisgn is updated or configuration changed to conform with the design.
In this manner, when tests are psrformed O
4 ATTACEMENT A Paga 12 in the future, management will be assured of their validity because the system will have been in the proper design configuration.
Additionally, the information as to present configuration will allow the project to evaluate any effects this may have had on the validty of prevfous Preoperational Testing.
c.
Revision of Procedures.
The procedures necessary to perform a test or work activity on a component or system will be evaluated and revised as required prior to the resumption of testing to assure that activities will be performed in a controlled, documented manner.
This activity will assure that no work on that component or system will be performed unless authori:::ed and documented so that the configura-tion and status of a system is known.
Addition-ally, it will assure that testing is performed in accordance with, and controlled by, procedure, and results are properly documented.
d.
Training.
Prior to resuming testing, personnel involved will receive training into the need for meticulous attention to detail in their work activity and documentation and the need for complete accuracy.
Training will also be provided, as appropriate, in
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ATTACHMENT A Page 13 the procedures to control testing and work activi-ties, the equipment problem tagging system, and the procedure for monitoring proper housekeeping and protection of equipment.
Having planned what work and testing will be per-formed, knowing the configuration of the subsystem, having assured that the proper procedural controls are in place, and having trained personnel in the procedures and programs, work and testing will,be resumed gradually on a system or subsystem basis to assure proper control and to provide for the evaluation of these controls.
3.
. Program to Assure all Requirements Have Been Satisfied.
In addition to the action taken to resume testing, APS management recognizes the need to assure that, when a system is accepted by PVNGS Nuclear Operations, installa-tion, maintenance, and testing and retesting activites re-quired by design and licensing commitments have been per-formed and documented.
Any deficiencies in these areas must be identified and evaluated.
In order to gain this assur-ance, several actions and reviews have been initiated.
Some of the major activities initiated are listed below.
a.
Review of Work Authorization Documentation.
A review is being conducted of work authori-zation documents from the commencement of preoper-ational testing on a system to the present.
This will provide a basis for determining system status and the need for any system retesting.
e
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ATTACHMENT A Page 14 b.
Review of Discipline Test Schedule.
The Discipline Test Schedule is being review-ed to ensure that each safety-related component requiring testing was evaluated to ensure required testing is listed.
c.
Review of Preoperational Test Data.
The safety-related Preoperational test data is being reviewed to ensure that the test was completed and correctly documented or the test will be repeated to provide the necessary docu-mentation.
Prior to a system being accepted by PVNGS Nuclear Cperations, it will be verified that Preoperational Testing has been approved and satisfies design and licensing requirements.
Deviations from the above criteria will be noted and evaluated prior to system acceptance.
With this action, management will have assurance that all systems accepted by PVNGS Nuclear Operations have been properly tested.
In addition to these measures, APS project manage-l i
ment has taken or is considering additional steps in response to recommendations of the Project Management Inter-face Task Force to simplify and coordinate areas where I
interface problems have existed in the past.
Actions l
initiated in this area include:
l 1
i 1
ATTACHMENT A Page 15 1.
Increasing the Unit Shift Super-visor's level of involvement in activities by requiring his con-currence prior to the start, and his notification of completion of all testing and work activities.
2.
Responsibility for control of cleanliness and housekeeping has been promulgated and project per-sonnel have been trained accord-ingly.
3.
The control of material and com-ponents in the plant, especially when the components are disas-
- sembled, is being strengthened.
4.
The responsibility for configura-tion control within APS, and estab-lishing the interfaces for config-uration control. transfer from Bechtel to APS, has been assigned to one department, Nuclear Engi-neering.
A Configuration Control section within Nuclear Engineering, headed by a dedicated superviror, has been established.
5.
A more detailed integrated project schedule for activities within the transition period is being devel-oped to provide the ability to better plan and control activities.
6.
The nonconformance process to be used during the the transition period has been more clearly de-fined.
7.
Procedures utilized by one organi-zation that may affect the activ-ities of another organization are being evaluated to assure that they properly interface.
8.
The responsibility transfer, at time of system transfer and accep-tance, is being more clearly de-fined to ensure that the responsi-bility for' performance of such things as maintenance and house-keeping are unde'rstood.
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ATTACHMENT A Pcgn 16 d
9.
The flow path for quality-related records is being more clearly de-fined to ensure the location and responsibility for control of these records is clearly defined.
10.
The work control program utilized during the transition period is being revised to more clearly define and clarify who can perform work and the procedure utilized to
. perform the work and associated inspection.
In summation, APS management actions have resulted
-in in-depth examinations and evaluations of the management t
controls and the implementation ' of the quality assurance program during startup.
On the basis of such examinations
. and evaluations, action has been or is planned to be taken to strengthen such controls and improve such implementation.
In the view of APS management, such actions provide in-creased assurance that Palo Verde will be completed in a fashion that will meet all Regulatory Requirements.
To the extent experience indicates further improvements should be
' made, APS management commits to do so.
II.
Weakness in the Quality Assurance Program During Con-struction Which Allowed Deficiencies to Go Undetected.
A.
Correction of Deficiencies.
During and subsequent to the CAT Inspection deficiencies in the Project Quality Assurance /
Quality Control Program identified by the NRC and the Project were documented, evaluated, and cor-rective action was taken immediately where appro-i
ATTACHMENT A Pcgs 17 1
priate.
Shortly after the Exit Meeting on Septem-ber 30, 1983, a broad-based reinspection program was initiated in areas where the CAT Inspection had indicated an inspection problem.
These rein-spections were conducted to more clearly identify the extent of the problem and to assist in deter-mining the cause and extent of corrective action necessary.
Where appropriate, as indicated in Attach-ment D, 100% reinspection is being conducted.
Additionally, in other areas, such as raceway identification, a new inspection is being added later in the construction process to identify and correct deficiencies.
Where the reinspection effort revealed a number of deficiencies which, when evaluated, had no effect on the ability of the plant to operate, or the safety of the plant, an engineering anal-ysis was conducted to determine the " acceptance criteria" (as distinguished from " inspection cri-teria") necessary to assure the component or structure would meet its design function.
Where such acceptance criteria were determined to be significantly less stringent than the " inspection critaria" which had been utilized during inspec-tion and the reinspection results indicated that
ATTACHMENT A Paga 18 the deficiencies noted during reinspection did not violate the acceptance criteria, additional rein-spection was and will be deemed inappropriate.
In these cases, any deficiency found prev ously or in the future would have been or will be identified but dispositioned " accept-as-is."
With this approach, the conservatism in the inspection criteria in relation to the acceptance criteria provides assurance that, even with errors in inspection, adequate design margins are pre-served.
In each case where this approach was adopted, as indicated in Appendix D, the inspec-tion criteria was not changed.
Where this ap-proach is used in the future, the acceptance criteria used to evaluate any deficiencies found during inspection will be established by engineer-ing analysis or will the criteria established in Attachment D.
It should be noted that Palo Verde is li-censed to a seismic design loading of 0.2g, but has been designed to 0.25g, a fact which adds considerable margin in the design.
In performing the above-stated engineering analyses, no credit has been taken for added conservatism in the seis-mic design loading; all analyses have been per-formed at 0.25g.
ATTACHMENT A Paga 19 The details of corrective action taken can be found in the responses to the Notice of Violation in Attachments C and D.
B.
Management Meeting.
At the Enforcement Conference on November 23, 1983, the NRC Regional Administrator stressed the need for meticulous attention to detail and ac-curacy in completing documentation.
On the first work day following the Enforcement Meeting, a meeting was held by the then Vice President, Nuclear Projects, and the APS QA/QC Construction Manager with Bechtel Site and APS Site Construc-tion Management to review the discussions at the Enforcement Conference.
In this management meeting, the need for meticulous attention to r
detail and accuracy was stressed.
Following these meetings, the APS Construction QA/QC Manager met with Bechtel QC personnel to assure they under-l stood the requirement for meticulous attention to j
l detail and accuracy during inspection.
I On November 30, 1983, at the request of the APS Chairman of the Board and Chief Executive l
Officer, a meeting of APS and Bechtel senior management and other key project personnel was held to discuss the results of the CAT Inspection and the Enforcement Conference.
During the meeting
ATTACHMENT A Paga 20 it was concluded that a number of management steps were necessary to investigate the cause for the deficiencies noted and to determine appropriate corrective actions.
The steps agreed upon in-cluded:
(i) an investigation by Bechtel engi-neering management to determine if tolerances used at PVNGS were appropriate; (ii) a study by the Bechtel Manager of Quality Assurance of the Pro-ject Construction QA/QC Program and activities to determine what improvements could be made; and (iii) retraining of project personnel using a video tape made by the APS Chief Executive Of-ficer.
This retraining would stress that each individual was to perform his job with meticulous attention to detail and with complete accuracy in completing documentation.
These activities are discussed further below.
C.
Tolerances.
An independent review was concluded of the erection tolerances for pipe supports to identify if the lack of clearly stated and adequate but flexible tolerances was the cause of some of the lack of conformance of pipe supports with appli-cable drawings.
The review, conducted by the Bechtel Manager of Engineering, Los Angeles Power Division, indicated that the tolerances had been a
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ATTACHMENT A Paga 21 problem earlier in the project, but that current project procedures are realistic.
No further change in tolerances appears warranted or desir-able at this time.
D.
Bechtel Management Study of Construction Quality Program.
The Bechtel E.2ager of Quality Assurance con-ducted a quality program improvement study of con-struction activities and the control under the quality program and procedures.
The study was conducted in order to evaluate what improvements could be made to increase the effectiveness of the controls implemented during construction.
Spe-cifically, the review was to ensure that defi-ciencies in construction would be properly iden-
- tified, documented and evaluated.
The study results made several recommendations which are being reviewed and evaluated by project manage-ment.
In areas where the recommendations could have a significant impact on the overall effec-tiveness of the quality program, action will be initiated.
Specifically, one of the findings noted that in the past there was an attitude in QC which allowed engineering evaluation and disposition of
ATTACHMENT A Paga 22 a deficiency to become the standard by which inspections were conducted.
For an example, if minor deviations in weld size were identified by QC inspectors and these deviations were consis-tently accepted by engineering without rework, the QC inspectors concluded that these conditions were acceptable, that they would be dispositioned in the same manner if documented, and therefore there was not point in documenting the deviation.
In this respect, the QC inspector, in essence, was performing an engineering function rather than a strict inspection function.
In the meeting between the AFS Construction QA/QC Manager and Bechtel quality control person-nel, one of the items discussed was the function of QC to identify deviations and the function of engineering to evaluate the deviations.
It was stressed particularly that meticulous attention to detail means all deviations to drawing and spec-ification requirements should be identified and documented.
Also, the Bechtel Project Quality Control Enginear has held training sessions with the Quality Control leads and inspectors to emphasize the requirement to perform inspections to the drawing or specification requirements and to l
ATTACIf!ENT A Page 23 emphasize that " judgment calls" by QC inspectors are not permitted.
Another finding of the study was that sta-tistical analysis should be employed to aid in the understanding and evaluation of inspection results and in the planning for inspection verification.
The use of statistical methods and analysis is currently under review and evaluation for use in the planning and evaluation of Quality Assurance overview of the adequacy of QC inspection as ex-plained below.
E.
Indoctrination and Training.
To assure that project personnel, at PVNGS, in Phoenix and in California, understand that management expects and, in fact, demands, meticu-lous attention to detail and complete accuracy in their work and associated documentation, a video tape was prepared by the APS Chief Executive officer explaining these issues.
This tape is being presented, along with an explanation and training program, to project personnel.
Addition-ally, this tape is being incorporated into the indoctrination program for future Palo Verde per-sonnel, both on-site and offsite.
F.
Evaluation of Effectiveness of QC Inspection.
Two programs have been initiated to evaluate the effectiveness of QC inspection at Palo Verde.
ATTACHMENT A Paga 24 The Project Quality Control Engineer had initiated a program to evaluate the effectiveness of inspec-tions by each QC supervisor.
This program consists of the QC supervisor performing a reinspection of an installation inspection made by one of his in-spectors on a weekly or monthly basis.
Discrepan-cies noted will be identified and evaluated as nonconformances.
The QC supervisor will also present periodic training sessions on the errors noted, to all of his inspectors.
Additional corrective action will be taken if warranted.
This program is designed to increase the effec-tiveness of QC by providing training in areas where errors are made.
In addition, Bechtel Quality Assurance will perform sample reinspection of QC inspections in areas where problems have been noted.
Some of these areas, such as pipe defects, are highlighted in Attachment D.
A corrective action reverifica-tion plan has also been initiated by Bechtel QA to.
assure that significant corrective action taken by I
the Project in response to Deficiency Evaluation Reports and Corrective Action Reports have actually been successful in preventing recurrence.
Correc-tive action for deficiencies noted will be taken, as appropriate.
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ATTACHMENT A Pr.ga 25 The actions described above address the generic problems that may have led to the deficiencies in construc-tion quality control.
Corrective action is being taken to resolve these problems, and a system to monitor the effec-tiveness of these controls and to identify other problems has been established.
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I ATTACHMENT B APS RESPONSE TO CERTAIN ISSUES COMMON TO SEVERAL OF THE ALLEGED VIOLATIONS l
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ATTACHMENT B Page 1 APS RESPONSE TO CERTAIN ISSUES COMMON TO SEVERAL OF THE ALLEGED VIOLATIONS 1.
Definition of Construction-Startup Responsibilities 1.1 The CAT Inspection Report, the Enforcement Letter and Section I. A.
of the Notice of Violation are premised on a misinterpretation that construc-tion is verified to be complete when systems, sub-systems and components are transferred by Bechtel construction to the APS Startup organization.M This misconception was also apparent in the dis-cussione during the exit interview and the En-forcement Conference when members of the inspec-M See:
(1) CAT Inspection Report (a) a number of problems identified indi-cated that some of the deficiencies may have resulted from activities performed after the system or component had been turned.over to operations and startup."
(page 2)
(b)
"The inspections in this area [ electrical and instrumentation] revealed deficiencies in the thoroughness of the final inspections and/or in control of maintenance following testing."
(page 2)
(c)
"Again the inspections in this area (mechani-cal] revealed deficiences in the thoroughness of the final inspections and/or in maintenance following testing."
(page 2)
(d)
"Most deficiencies appear to result from inadequate inspections prior to or inadequate control of systems after turncver to operations and startup."
(page 3)
(footnote continued on following page)
__A
ATTACHMENT B Page 2 tion team stressed deficiencies in the " turnover" process and in the walkdown of systems at the time of turnover.
Most significantly, during the En-forcement Conference, it became apparent that at least same CAT inspectors were unaware that at Palo Verde Prerequisite Testing is conducted by and is the responsibility of APS Startup after transfer by Bechtel.
1.2 It must be recognized that the Startup Program put in place by APS for Palo Verde is unique.
Prere-quisite Testing, which is normally associated with completion of construction, has been the responsi-1/
(footnote continued from previous page)
(2)
Enforcement Letter (a) a number of problems identified indi-cate that deficiencies may have resulted from activities performed after the systems or components had been turned over to Operations and Startup."
(page 1)
(b) the number of such items reflects ad-versely on the quality of the final quality control inspec-tion effort of your quality assurance program at the time of system turnover to operations.
(page 2)
(3)
Section I.A. of the Notice of Violation
(
l (a)
"The items in Section II [ sic] below, al-though mostly minor in nature, reflect inadequate quality control inspection of a large number of deficiencies which should have been identified during final quality control inspections."
(page 1)
(b)
" Construction of the containment and pressure sensi,ng systems had been completed, turned over from the constructor to the licensee, and tested."
(page 2)
ATTACHMENT B Paga 3 bility of the Vice President, Nuclear Operations, and not the construction organization.
1.3.
Procedures in place recognize that the walkdown performed at transfer by ccnstruction are designed to determine the status of completion of construc-tion.
A method has been developed to track con-struction items not complete at time of transfer.
1.4 The unique Palo Verde Startup Test Program is ex-plained in the PVNGS FSAR, Section 14.2.1 - Summary of Test Program'and Objectives.
It is there ex-plicitly stated --
. The Startup Test Program consists of Prerequisite Testing plus the fol-lowing four phases:
Phase I Preoperational Testing Phase II Fuel Loading and Post Core Hot Functional Testing Phase III Initial Criticality and Low Power Physics Testing Phase IV Power Ascension Testing."
The FSAR goes on to define " Prerequisite Testing" as follows:
" Prerequisite Testing consists of tests and inspections required to assure construction is complete and that systems are ready for Preoperational Testing.
The completion of Prerequisite tests on each system results in system release to operations for the commencement of Preoperational (Phase I) Testing.
Prerequisite testing will verify that construction activities associated with the respective structures, components, and systems have been satisfactorily completed.
Prerequisite testing will consist of construction, and preliminary i
ATTACHMENT B Pags 4 tests and inspections which typically include, but are not limited to, initial instrument calibration flushing, clean-ing, circuit integrity and separation checks, hydrostatic pressure tests and functional tests of components."
[ Underscoring supplied for emphasis.]
1.5 Thus, under the Palo Verde scheme of things, it is clear that:
a.
Transfer of systems or subsystems by Bechtel to APS Startup is not intended to and does not signify completion of construction.
b.
Such transfer is made prior to Prerequisite Testing of components.
c.
Prerequisite Testing is the responsibility of the APS Startup organization.
d.
The walkdown of systems at the time of trans-fer of systems by Bechtel to APS Startup is not and was never intended to be a " final inspection" or a " final quality control in-spection effort."
e.
The cor.pletion of construction is signified by the acceptance of a system, subsystem or area by PVNGS Nuclear Operations, not the APS Startup organization.
Final inspection is completed at this time and is signified by such acceptance.
(See PVNGS Station Manual).
f.
System configuration is verified by PVNGS Nuclear Operations at the time of acceptance.
(See PVNGS Station Manual).
1.6 In light of the foregoing, it was and is incorrect to assume that the " turnover" of systems and com-ponents to the APS Startup organization marked the completion of construction or that final quality control inspections took place or were intended to take place on transfer from Bechtel to APS.
The
ATTACHMENT B Page 5 FSAR makes it clear that construction activities by Bechtel continue after transfer and the Pre-requisite Testing Program itself, conducted by the APS Startup organization, is an integral part of the completion of construction.
1.7 It is also inaccurate to infer or characterize the transfer of systems and components "from the con-structor to the licensee" as a " turnover to opera-tions".
It is clear from the FSAR that transfer to the PVNGS Startup organization does not con-stitute a acceptance to PVNGS Nuclear Operations.
1.8. Prior to a system being accepted by PNVGS Nuclear Operations, the configuration of the system will be verified for conformance to design drawings.
It will also be verified that all required testing has been performed and the results are. acceptable.
This process provides an acceptable means, after subsequent transfer to the APS Startup organiza-tion, of detection and resolution of a large number of the deficiencies noted during the CAT Inspection.
1.9 None of the safety-related systems or components inspected by the CAT inspector had been accepted by PVNGS Nuclear Operations.
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ATTACHMENT B Pago 6 2.
Evaluation of Issignment of Severity Level IV Violation 2.1 APS disagrees with the assignment of Severity Level III to the violation alleged in Section I.A.
of the Notice and with the assignment of Severity Level IV to the violations alleged in the follow-ing subsections of Section II of the Notice:
II.A.1. Cable Overfill; II.A.2. Separation; II.A.3. Raceway Identification; II.A.4. Raceway Identification; II.B.1. Structural Steel Bolting; II.B.2. Concrete Anchor Bolt Installation; II.B.4. Pipe Support Welding; II.B.S. Pipe Support Drawings; II.B.6. Pipe Pit; II.C.
Structural Steel Welding; II.D.
Valve Bolts; II.E.
Seal Material on Pipe Support.
2.2 In each case, as described in Attachments C and D, an evaluation has been conducted to determine whether the condition which had been found could have had a significant safety impact.
In each case, except II.B.3, it was concluded that the noted conditions were not safety significant.
These violations do not meet the requirements found in Appendix C to 10 CFR to have "more than minor safety or environmental significance" to be classified as Severity Level III or IV violations.
Steps were taken immediately (i) to correct the deficient condition that had been found, (ii) to investigate and evaluate the generic aspects of i
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ATTACHMENT B s
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's Paga 7 to d' velop and imple-each deficiency, and (iii) e ment. appropriate corrective action, where neces-sary.
In total, the response of APS has been
- prompt, coreprehensive and meaningful.
(See Appendix A).
s In light of the apparent discrepancy between the safety
-s significance of the alleged violations an'd the definition of Severity Level III and IV violations and theiimmediate cor-rective action taken, it is requested that, with the excep-tion of II.B.3, they besteclassified as' Severity Level V.
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I ATTACHMENT C l
i APS RESPON5Z TO SECTION I.A. OF THE NOTICE OP VIOLATION FOR WHICH A CIVIL PENALTY IS PROPOSED L
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ATTACHMENT C Pcgt 1 i
ADS RESPONSE To SECTION I.A i
OF THE NOTICE OF VIOLATION FOR WHICli A CIVIL PENALTY IS PROPOSEE 4
i PART I
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'l RESTATEMENT OF ALLEGED VIOLATION I.A.1 "I.
VIOLATIONS ASSESSED CIVIL PENALTIES "A.
Criterion II, as imple-mented by Chapter 17 of the licensee's PSAR and-FSAR, requires, in part, that:
'The quality as-
't;*].
surance program shall provide control over activ-ities affecting the quality of the identified i
structures, systems, and components,,to an extent consistent with their importance to safety.'
" contrary to the above requirements, the licensee's quality assurance program did not maintain adequate control over activities affecting quality, as evi-denced by the following examples:
i "1.
On September 10, 1983, it was determined that the containment pressure inetrumentation was J
ft incapable of performing its intended safety k
function in that caps had been installed on 7
I
, [,
the sensing lines.
Construction of the con-t
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ATTACHMENT C Pcga 2 tainment and pressure sensing systems had been completed, turned over from the con-structor to the licensee, and tested.
Sub-sequently, the quality assurance organization directed that the caps be installed without following established QA procedures for cor-recting potential deficiencies.
No adminis-trative requirement existed to assure that the caps would have been discovered until the next scheduled containment leak rate test, pursuant to the operating license require-ments.
This containment pressure instrumen-tation is required to automatically initiate the HPSI and other safety systems on high containment pressure.
"This is a Severity Level III Violation, (Supple-ment II).
(Civil Penalty-$40,000)"
APS RESPONSE TO ALLEGED VIOLATION I.A.1 1.
Admission or Denial of Violation 1.1 APS admits the following conditions and facts cited in paragraph I.A.1:
1.1.1 Such systems had been transferred by Bechtel construction to the APS Startup organization.
1.1.2 Certain Preoperativpc; Tests of such systems had been completed.
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ATTACHMENT C Pcg2 3 1.1.3 The APS quality assurance organization directed that caps be installed on the sensing lines.
1.1.4 Caps were installed on such lines pur-suant to the direction of the APS qua-lity assurance organization.
1.1.5 The installation of the caps on the sensing lines was not documented.
1.1.6 Containment pressure instrumentation is designed to automatically initiate the HPSI and other safety systems on high containment pressure.
1.2 APS denies the following facts alleged, explicitly or implicitly, in paragraph I.A.1:
1.2.1 Denies that the containment pressure sensing systems had been " turned over" to or accepted by PVNGS Nuclear Opera-tions.
1.2.2 Denies that the walkdown to assure sys-1 tem configuration which is associated with the acceptance by PVNGS Nuclear Operations had been conducted.
1.2.3 Denies that no administrative require-ment existed to assure that the caps would have been discovered until the next scheduled containment leak rate i
test.
1.3 In light of the foregoing admissions and denials and for the reasons hereinafter set forth, APS denies that the undocumented capping of the con-tainment pressure sensing lines prior to accept-ance by PVNGS Nuclear Operations, constitutes a violation of Regulatory Req'airements.M l
M The term " Regulatory Requirements" as used in this document has the same meaning given to such term in Footnote 2 to Appendix C of 10 CFR Part 2.
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ATTACHMENT C Pcg3 4 2.
Reasons Why No Violation Occurred 2.1 The capping of open lines to prevent the entry of dirt or materials into such lines prior to opera-tion is a proper and prudent action.
It is con-sistent with the require.nents of ANSI N45.2.3 for housekeeping during construction and the practices and procedures enforced at PVNGS from the com-mencement of construction.
2.2 At the time of the CAT Inspection in September,
.1983, there was no Regulatory Requirement that caps installed on open lines during construction or testing and prior to acceptance 'by PVNGS Nu-
- lear Operations be documented.
installed 'on the containment pressure 2.3 The caps sensing lines are testing caps provided per drawing 13-M-HCS-001 and are required for initial and subsequent testing.
The removal of the caps during operation is properly a matter to be gov-erned by operating procedures and not construction i
or startup procedures.
2.4 There was no Regulatory Requirement in existence at the time of the CAT Inspection in September, 1983, that an operating procedure be in place to inspect for the presence of and removal of the caps on the containment pressure sensing lines.
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ATTACHMENT C Pcgs 5 2.5 There was, in fact, an administrative requirement in existence at the time of the CAT Inspection which would have assured detection and removal of the test caps on the sensing line.
The closeout of I&E Information Notice 83-23, action on which had been initiated by APS prior to the CAT Inspec-tion, required action cnd verification of such action to assure the removal of testing caps on l
the containment pressure sensing lines prior to and during operation.
2.6 Under such circumstances, it is unreasonable and improper to assert that a violation of Regulatory i
Requirements had occurred in September, 1983, solely on an assumption that the presence of caps would remain undetected because cf a future vio-lation of a future Regulatory Requirement.
2.7 Acknowledging that it would have been prudent and I
good practice to have documented the placement of t
1 the caps on the sensing lines (as well as any other changes in the configuration of systems l
during startup), the lack of such documentation does not by itself demonstrate by example the lack of control of activities affecting quality where it cannot be demonstrated that other administra-tive requirements would not be effective to detect i
the presence of and provide for the removal of the sensing line caps.
ATTACHMENT C Pcga 6 3.
Corrective Steps Which Have Been Taken and The Results Achieved 3.1 The containment pressure sensing lines are capped, and this capping is controlled and documented through the use of the temporary modification system.
4.
Corrective Action Which Will Be Taken 4.1 To enhance the control of activities during the startup period, work will be performed under an approved work control program.
(See Attachment A, pages 10-16.). This action will provide assurance that changes to the configuration of a system are approved and documented.
4.2 Additionally, Bechtel Conctruction Work Plan Pro-cedures (WPP/QCI) are being revised to require that work performed on a system which has been jurisdictionally transferred to the APS Startup organization be authorized in writing by the APS Startup organization.
4.3 Station Manual Procedure 41ST-lZL13 will be re-vised to specifically address removal / verification of removal of containment pressure sensing line caps prior to entry into Mode 5.
4.4 Similarly, the Surveillance Procedure 36-ST-9SB03, which is done on a refueling outage frequency,
ATTACHMENT C Pcga 7 11 include a step that requires a blowdown and visual inspection of the lines.
5.
Dates When Full Compliance Will Be Achieved 5.1 Full compliance has been achieved with respect to specific conditions cited.
5.2 The revisions of Station Manual Procedure 41ST-12Z13 and Surveillance Procedure 36-ST-9SB03 are in the approval process which will be completed on March 23, 1984 and prior to fuel load, respec-tively.
5.3 All other action will be completed by February 29, 1984.
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ATTACHMENT C Pcga 8 PART II RESTATEMENT OF ALLEGED VIOLATION I.A.2 "I.
VIOLATIONS ASSESSED CIVIL PENALTIES "A.
10 CFR SC, Appendix B, criterion II, as implemented by Chapter 17 of the licensee's PSAR and FSAR, re-quires, in part, that:
'The quality assurance program shall provide control over activities af-fecting the quality of the identified structures, systems, and components, to an extent consistent with their importance to safety.'
" Contrary to the above requirements, the licensee's quality assurance program did not maintain adequate control over activities affecting quality as evi-denced by the following examples:
"2.
On September 7, 1983, the manual operator for valve SI V470 on the suction of the HPSI "A"
pump was disconnected and resting on the sprinkler system piping.
Construction of the subsystem had been completed, turned over to the licensee, and was undergoing preopera-tional testing.
There was no record of the defective and/or nonconforming condition I
ATTACHMENT C Paga 9 which included a missing stud nut and leaking flange.
"This is a Severity Level III Violation, (Supple-ment II).
(Civil Penalty-$40,000)"
APS RESPONSE TO ALLEGED VIOLATION I.A._2_
1.
Admission or Denial of Violation 1.1 APS admits the allegations in paragraph I.A.2 of the Notice that:
1.1.1 On September 7, 1983, the manual opera-tor for valve SI V470 on the suction of the HPSI "A" pump was disconnected and resting on the sprinkler system piping; and 1.1.2 There was no record of the defective and/or nonconforming condition which included a missing stud nut.
1.2 Further, in answer to the alleged violation, APS avers that, contrary to the allegations in para-graph I.A.2, the following conditions existed on September 7, 1983:
1.2.1 Preoperational testing of the subsystem was in progress.
1.2.2 The subsystem had not been presented for acceptance nor accepted by PVNGS Nuclear Operations.
1.2.3 Preoperational Testing required prior to acceptance of the subsystems of PVNGS Nuclear Operations would have resulted in the discovery and correction of the deficient condition.
ATTACHMENT C Pcga 10 1.2.4 The condition of the valve was in a near open position and this would have allowed the subsystem to operate in ac-cordance with the design intent.
1.2.5 The valve is used in the subsystem only to provide isolation during maintenance or repair of the HPSI "A" pump.
1.2.6 The condition of the valve in the sub-system, if left uncorrected, would have had no impact on the safe operation of the HPSI system, and, therefore, was not significant to safety.
1.3 In light of the foregoing admissions and averment of facts, APS denies that the undocumented status or condition of the subsystem on September 7, 1983, constituted a violation of any Regulatory Requirement for which the assignment of Severity Level III is permitted under Appendix C to 10 CFR Part 2.
In support thereof APS states:
1.3.1 Appendix C to 10 CFR Part 2 provides that Severity Level V is to be assigned to violations that have minor safety or environmental significance.
Severity Level IV is to be assigned were the vio-lation is "of more than minor concern, i.e.
if left uncorrected,
[it] could lead to a more serious concern."
(Em-phasis supplied.]
1.3.2 Since the nonconforming condition has been determined-to have no safety sig-nificance even if left uncorrected, it is not proper to assign Severity Level III to the violation.
1.3.3 The violation is distinguishable from the other examples cited in the Notice (see Attachment E, pages 3, 4,
9, 10),
and therefore the only basis on which the assignment of Severity Level III may be, i.e.,
" multiple examples," does not exist.
ATTACHMENT C Page 11 2.
Reasons for the Conditions Existing on September 7, 1983 2.1 Two problems existed which resulted in the condi-l tion found.
First, the bridle which was supplied by Roto Hammer was too short, thereby, allowing the rising stem to contact the top of the bridle before full valve opening was achieved.
- Second, with the adapter retaining nut missing, the rising stem pushed the bridle /adeptor assembly up and off the stem nut, disengaging the actuator from the valve.
2.2 I'.vestigation of these problems reveals that the remote actuator was installed by Bechtel in Janu-ary, 1983, after the system had been transferred to the APS Startup organization.
There is no pro-cedural requirement to inspect the length of the bridle to confirm the vendor chose and supplied the required size to accommodate valve stem travel.
2.3 After installation of the remote operator and stroking in January, 1983, and before the last known operation in August, 1983, the valve we.s disassembled and improperly reassembled.
This l
l resulted in the missing adaptor retaining nut, the missing bonnet stud nut, the loose bonnet bolts, and the leaking bonnet flange.
ATTACHMENT C Page 12 3.
Corrective Steps Which Have Been Taken and The Results Achieved 3.1 The noted deficiencies were corrected as docu-mented by SFR 1SI-292.
3.2 The condition has been evaluated for safety sig-l nificance.
The observed condition, if left uncor-rected, would have had no impact on the safe operation of the HPSI system.
The valve was in a near open position and this would have allowed the system to operate as per design intent.
The valve j
is used in the system on]y to provide isolation when servicing the HPSI "A"
pump.
The final report for DER 83-87 will document this evalua-tion.
3.3 Roto Hammer has been notified of this condition and is supplying the correct assemblies for Units 2 and 3.
3.4 Construction has revised the installation proce-dure (Special CIP 521.0) to require documented i
verification that the bridle being installed is the size specified for the particular valve for all future installations on the project.
4.
Corrective Steps Which Will Be Taken 4.1 The Construction Inspection Procedures will be i
revised to clarify the method of ensuring that the position indication is proper.
Addit
- nally, 1
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ATTACHMENT C Page 13 Bechtel Engineering is preparing a walkdown pack-age to reinspect all safety-related valves in Units 1 and 2 utilizing Roto Hammer remote oper-ators.
Any nonconforming conditions will be docu-mented and included in the final report to DER 83-87.
4.2 To assure that work performed during startup is properly controlled, work performed on any perma-nent plant equipment will be performed under an approved Work Control Program.
This will ensure that any changes to, or deviations from the plant design configuration, either temporary or perma-nent, are approved and documented prior to begin-ning the work activities.
Performance of work or test activities on any permanent equipment within APS' jurisdictional control will be required to be concurred with' by the Unit Shift Supervisor for the unit affected.
The above requirements will ensure that the plant design configuration and system status are maintained in a known, approved state.
(See Attachment A, pages 11, 15.)
4.3 APS will expand the Startup Work Authorization (SWA) procedure such that when a discrepancy is observed on equipment in the startup jurisdiction,,
a SWA or Startup Field Report (SFR) will be ini-tiated.
A copy of the SWA will be forwarded to
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ATTACHMENT C Pega 14 the Unit Shift Supervisor for his information and to determine if a tag should be hung to identify the problem locally.
All tags will be tracked and controlled by Operations personnel, with a copy of closed SWA's also forwarded to the Shift Super-visor to allow timely removal of tags.
4.4 The operations phase Work Control Procedure will be similarly expanded to assure prompt identifica-tion of discrepancies, local identification tag-ging of previously identified significant problems, and tracking of tags until resolution.
4.5 Before acceptance of a system or subsystem by PVNGS Nuclear Operations from the PVNGS Startup organi-zation, a PVNGS Nuclear Operations acceptance walkdown will be conducted on the system to con-firm that the system configuration is in accor-dance with design.
4.6 APS project management will issue a directive to all PVNGS Startup and Nuclear Operations personnel i
informing them of their responsibility to iden-I tify, pursue, and assure resolution of discre-pancies identified in an expeditious manner.
Per-sonnel will also be instructed not to perform work without the proper authorization and controls.
l 4.7 Locked open/ closed safety-related major flow path l
l valves (not including such valves es instrument i
,.. _. ~,.. _ _ - -. _, _,. -. _ -,,,,,..,,.. _,,...,,..,
ATTACHMENT C Paga 15 root, vent and drain valves) in Unit'l without remote position indication will be operated to verify operability and position indication, prior to fuel loading.
4.8 A generic surveillance test procedure will be developed to verify all major flow paths valves in Units 2 and 3 of PVNGS are fully operable and position indication is representative of valve position.
4.9 The appropriate operations phase generic valve repair procedures will include requirements to verify valve operability and position indication prior to return to service.
This will be com-pleted prior to fuel loading.
5.
Date When Full Compliance Will Be Achieved 5.1 The deficient condition of valve SI V470 has been corrected.
5.2 The corrective action specified in paragraphs 4.1, 4.2, 4.3 and 4.6 will be completed by February 15, 1984.
5.3 The corrective action specified in paragraphs 4.4, 4.5, 4.7, 4.8 and 4.9 will be completed prior to fuel loading.
5.4 The final report for DER 83-87 will be issued by April 15, 1984.
ATTACHMENT C Pega 16 PART III RESTATEMENT OF ALLEGED VIOLATION I.A.3.
"I.
VIOLATIONS ASSESSED CIVIL PENALTIES "A.
10 CFR 50, Appendix B, Criterion II, as iraple-mented by Chapter 17 of the licensee's PSAR and FSAR, requires, in part, that:
'The quality assurance program shall provide control over activities affecting the quality of the identified structures, systems, and components, to an extent consistent with their importance to safety.'
" Contrary to the above requirements, the licensee's quality assurance program did not maintain adequate control over activities affect-ing quality as evidenced by the following examples:
l "3.
On September 28, 1983, the position indicator for valve SI V402 on the suction of the HPSI l
i "B"
pump was positioned so that the valve could only be opened 30 to 35 percent of its i
full open position.
Construction of this subsystem had been completed, turned over to the licensee, and was undergoing preopera-
ATTACHMENT C I
Pega 17 tional testing.
There was no record of the defective and/or nonconforming condition.
"This is a Severity Level III violation, (Supple-ment II).
(Civil Penalty-$40,000)"
APS RESPONSE TO ALLEGED VIOLATION I.A.3 1.
Admission or Denial of Alleged Violation 1.1 APS admits the allegations in paragraph I. A.3 of the Notice that:
1.1.1 On September 28, 1983, the valve could only be opened 30 to 35 percent of its full open position.
1.1.2 There was no record of this condition.
1.1.3 The subsystem of which the valve is a component had been transferred by Bechtel construction to the APS Startup organization.
1.1.4 Preoperational Tes, ting of the subsystem was in progress in September, 1983.
1.2 In answer to the alleged violation, APS avers that the following conditions existed on September 28, 1983:
ATTACHMENT C Pcga 18 1.2.1 The subsystem had not been presented for acceptance nor accepted by PVNGS Nuclear operations.
1.2.2 Preoperational testing of the subsystem had not been completed.
1.2.3 No work on the valve had been performed which had not been properly controlled by work control procedures.
1.2.4 The condition of the valve was such that it could have been opened sufficiently to allow the subsystem to operate in ac-cordance with the design intent.
1.2.5 The condition of the valve, if left un-corrected, would have had no impact on the safe operation of the HPSI System, and, therefore, was not significant to j
safety.
1 1.3 In light of the foregoing admissions and averments of fact and the matters stated in Attachment B, pages 6-7, APS denies that the undocumented condi-tion of the subsystem existing on September 28, 1983, constituted a violation.
In support thereof APS states as follows:
1.3.1 The discrepant condition was not signi-ficant to safety and therefore did not constitute a Severity Level III viola-tion.
1.3.2 Appendix C to 10 CFR Part 2 provides that Severity Level V is to be assigned to violations that have minor safety or environmental significance.
Severity Level IV is to be assigned where the violation is "of more than minor con-
- cern, i.e.,
if left uncorrected,
[it]
could lead to a more serious condition."
(Emphasis supplied.]
ATTACHMENT C Ptga 19 1.3.3 Since the nonconforming condition has been determined to have no safety sig-nificance even if left uncorrected, it is not proper to assign severity Level III to the violation.
1.3.4 The violation is distinguishable from the other examples cited in the Notice (see Attachment E, pp. 3, 4, 9, 10), and therefore the only basis on which the assignment of Severity Level III may be
- made, i.e.,
" multiple examples," does not exist.
2.
Reasons for the Conditions Existing on September 28, 1983 2.1 During the installation of remote operators, Con-struction is not required to verify length of stroke.
The valve is stroked by an APS operator using the remote operator from stop to stop.
In this case, the travel was restricted by the valve stem position indicator nut not being properly set on the valve stem.
The indicator nut hit the top of the valve yoke and prematurely stopped valve travel in the open direction. Since the valve is stroked remotely, it would not be obvious that valve travel was being restricted.
Therefore, the APS operator and Construction Engineer assumed the valve was full open when, in fact, it was not.
2.2 The HPSI system was being tested at the time of the inspection.
Testing has not been completed.
3.
Corrective Steps Which Have Been Taken and the Results Achieved 3.1 The restriction on the operation of valve SI V402 to 30 to 35 percent of its full open position
ATTACHMENT C Page 20 caused by the position indicator has been eval-uated for safety significance.
The observed condition, if left uncorrected, would not preclude the operation of the HPSI system in accordance with design intent.
Bechtel Engineering has per-formed an evaluation which verifies that the system will perform to design intent with the valve open only 30 to 35 percent.
This evaluation has been confirmed with Borg Warner, the valve supplier, via telephone notes TN-E-3516.
The final report for DER 83-87, initiated to address flow restriction due to deficiencies in SI V470, will contain the evaluation which documents this analysis.
3.2 Construction has revised the installation proce-dure (Special CIP 521.0) to require verification that the stem is free to travel from full closed to full open without interference.
4.
Corrective Steps Which Will Be Taken 4.1 The deficiency noted on SI V402 will be addressed as part of the valve stroking required by Work l
Order 024447 and SWA 15578.
4.2 To ensure that no other similar deficiencies exist and that none will occur in the future, the Con-struction In.spection Procedures will be revised to clarify the method to ensure that the position indication is proper.
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ATTACHMENT C Pagt 21 4.3 Locked open/ closed safety-related major flow path valves (not including instrument root, vent and drain valves) in Unit 1 without remote position indication will be operated to verify operability and position indication, prior to fuel loading.
4.4 A generic test procedure will be developed to verify all major flow path valves in Units 2 and 3 of PVNGS are fully operable and position indica-tion is representative of valve position.
t 4.5 The appropriate operations phase generic valve repair procedures will include requirements to verify valve operability and position indication prior to return to service.
This will be com-pleted prior to fuel loading.
l l
5.
Date When Full Compliance Will Be Achieved 5.1 The deficient condition of valve SI V402 will be corrected prior to acceptance of this subsystem by PVNGS Nuclear Operations.
5.2 The corrective action specified in paragraph 4.2 l
will be completed by February 15, 1984.
5.3 The corrective action specified in paragraphs 4.3, 4.4 and 4.5 will be completed prior to fuel loading.
5.4 The final report for DER 83-87 will be issued by March 15, 1984.
l l
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- ATTACHMENT C Pcg3 22 PART IV RESTATEMENT OF ALLEGED VIOLATION I.A.4.
"I.
VIOLATIONS ASSESSED CIVIL PENALTIES "A.
10 CFR 50, Appendix B, Criterion II, as implemented by Chapter 17 of the licensee's PSAR and FSAR, re-quires, in part, that:
'The quality assurance program shall provide control over activities affecting the quality of the identified struc-tures, systems, and components, to an extent consistent with their importance to safety.'
" Contrary to the above requirements, the licensee's quality assurance program did not maintain adequate control over activities affecting quality as evi-denced by the following examples:
"4.
On September 14, 1983, 87 3/8-inch bolts were missing from the base frames for six motor control centers (MCC's) of the vital AC onsite power dis-tribution system.
These bolts are necessary to ensure the structural integrity of the MCC's.
"This is
- a. Severity Level III Violation, (Supplement II).
(Civil Penalty-$40,000)"
ATTACHMENT C Paga 23 APS RESPONSE TO ALLEGED VIOLATION I.A.4 1.
Admission or Denial of Violation 1.1 APS denies that on September 14, 1983, 87 3/8-inch bolts were missing from the base frames for six motor control centers (MCC) of the vital onsite power distribution system.
1.2 APS denies that any bolts which are necessary to ensure the structural integrity of the MCC's are missing.
1.3 Accordingly, APS denies the alleged violation.
1.4 In support of such denial, APS submits that it is apparent from the CAT Inspection Report, dated November 11, 1983, and the Notice that no specifi-cation or other requirement has been ' cited to establish the number or sizes of bolts required for mounting McC's to maintain their structural integrity.
It appears that (i) the allegation that 87 bolts are missing resulted from counting unused holes in the base frames for six MCC's and (ii) the allegation that all or some of the
" missing" bolts are necessary to ensure structural integrity is based on an unsupported assumption.
2.
Reason for the Conditions Observed 2.1 The NEMA III nonwalk-in cabinets which house the motor control centers (MCC's). tag nos. 1-E-PHA-M33, 35, 37 and 1-E-PHB-M34, 36 and 38, were con-
ATTACHMENT C Page 24 structed and mounted per General Electric instal-lation drawings.
2.2 See Figures 1 and 2 for the connec'; ion details and the location of the bolts on the front and back side of the cabinets, respectively.
The lifting lugs as shown on the vendor drawings were used to handle the NEMA III cabinets during shipping from Mebane, North Carolina, to the Palo Verde jobsite, and during their installation.
After completing the installation, the lifting lugs were removed as they created a safety hazard by protruding into aisle space.
The installation drawings did not indicate that the lifting lugs must remain in place, and since the lugs posed a safety hazard by projecting into the walkways, it was deemed appro-priate that they be removed.
2.3 On the front side of the cabinets (See Figure 1),
the four 3/8-inch diameter bolts (Item 1) that the lifting lug fits over were either removed when the lifting lugs were removed, or were never installed by General Electric (GE) prior to shipment.
For the front side, the 3/8-inch diameter bolts serve as part of the connection between the front base channel (C6) and a parallel channel (C4) which, in turn, is connected to a transverse channel (C4).
On the back side of the cabinets (see Figure 2),
j
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- a..,
the two 5/8-inch diameter bolts (Item 6) which connect the lifting lug to the base channel (C6) were not reinstalled after the lifting lugs were removed.
It was not apparent from the vendor drawings that these bolts also serve as part of the connection between the back base channel (C6) and a parallel channel (C4) which, in turn, is connected to a transverse channel (C4).
2.4 The front and back connections of the cabinet at each lifting lug location have other bolts which were in place after removal of the lifting lugs.
2.5 Since the drawing did not adequately specify the bolting arrangement with the lifting lug removed, the subject bolts were overlooked during a subse-quent Bechtel Engineering audit of safety-related equipment installations attached to structures.
The audit was concerned with as installed attach-ment of the equipment to the structure (i.e., slab and wall) compared to the installation drawings and the qualification report and did not review the assembly of the cabinets.
It should also be noted that the audit team found that the installa-tion of the MCC's and the NEMA III cabinets was incomplete, that the MCC's mounted in the NEMA III cabinets were not consistent with the qualifica-tion of the MCC's, and that an engineering evalua-
ATTACHMENT C Page 26 tion was required.
As a result of the engineering evaluation, DCP 1SE-PH-035 was issued to have the installation modified.
- However, the original issue of the DCP did not address the subject bolts.
2.6 As a final point, it may be stated that the in-stallation of these MCC's is unique, because these MCC's are the only type mounted inside NEMA III cabinets which are designed to protect the elec-trical equipment from the effects of the Auxiliary Building sprinkler system.
No other safety-
~ ' ated equipment is installed in this manner.
3.
Corrective Steps Which Have Been Taken and the Results Achieved 3.1 Bechtel Engineering investigated the alleged vio-lation concerning missing bolts from the base frames as shown in Figures 1 and 2 for the six motor control centers (MCC's).
The results of the investigation as documented in calculation 13-CC-ZQ-E01, Revision 2, indicated that the seismic qualification of the MCC's would not be invali-dated under the as-installed condition, nor would the condition affect the structural integrity of the system under any design loading.
General Electric has reviewed the results of the Bechtel analysis and concurs with the conclusions.
(TN-
m 4
l ATTACHMENT C Pege 27
~
E-3503, datud 12/27/83, and B/ANPP-E-110302, dated
,1
.s 12/29/83).
Therefore, the missing 3/8-inch dia-i meter bolts from the base frames for six motor control centers ofithe vital AC onsite power dis-tribution system,Ere not necessary to ensure the V,
structural integrity of the MCC 's.
The final
+,,
for DER 83g04 will document this evalua-i report 1
s
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tion.
-i J
4.
Corrective Steps Which Will Be Taken 4.1 Although the miss~ing four 3/8-inch diameter @olts on the front side and the two 5/8-inch diameter x_
s,
bolts on the back side,'of each lifting lug loca-'
~
tion are not considered safety significant and are s
s notr(ipiired,theywillbeinstalledinUnit1per s
l revised and clarified GE drawings and as docu-N l
mented by DCP 1SE-PH-035, Modification 1.
4.2 Instal ation work, using updated and clarified drawings in Utlits 2 and 3, is currently ongoing '
and inst'adlations will be' completed in accordance with these documents.
i u
4.3 Bechtel Construction, Work Plan Procedure (WPP/QCI) 3 258.0 is~ being revised to require Engineet.ng ap-l l
proval prior'to the remov l\\of any temporary at-s e
tachment from installed eqilipment.
4.4 Bechtel has initiated a review of the documents of safety-related equipment installations in Unit 1, l
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- \\ t ATTACHMENT C Pega 28 2 and 3 attached to structures to permit a selec-tive verification such installations as appro-priate.
The review and verification will deter-mine if the safety-related equipment was installed per vendor drawings and instructions.
The results will be documented by DER 83-84.
5.
Date When Full Compliance Will Be Achieved 5.1 A PCN to WPP/QCI 258.0 will be issued by Janu-ary 31, 1984.
5.2 Design Change Packages 1SE/2SE/3CE-PH-035 will be completed prior to fuel load in each unit.
5.3 The final report. for DER 83-84 will be issued by May 15, 1984.
', 5.s ' Ths four 3/8-inen diameter bolts and two 5/8-inch di'ameter bolts for Unit 1 McC's will be installed s
prior to fuel load.
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ATTACHMENT C Page 29 i
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FIGURE 1 - FRONT LIFTING LUC ASSEMBLY (Two per cabinet) j L/f7hGL(JG f
-/NCHCHANNEL 4
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Item 1 - Holes for 3/8 inch dianter mounting bolts which attach the C4 support girt to the C6 base. These bolts are required after lifting lug removal.
Item 2 - Mounting holee for the lifting lugs attachment bolts. No bolts are required after lifting,1ug removal.
l Item 3 - Holes for 5/8-inch dinneter bolts used to attach the i
lifting lug. These bolts are not required after lifting lug removal.
l Note A - Af ter lif ting lug removal 2-5/8-inch diameter bolts (Item 3) may be installed as a substitute for the 4-3/8-inch diameter bolts (Item 1).
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ATTACFEENT C Page 30 FIGURE 2 - BACK LIFTING LUG LOCATION (Two per cabinet)
NO BOL TS LIFT /NG LUG MOUNT /NG l
BRACKE7ill/FT/NG LUG
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& /NCH CHANNEL.
Item 4 - Holes for 3/8-inch diameter mounting bolts which attach the C4 support girt to tite C6 base (See Note 3).
Item 5 - Mounting holes for the lifting lug attachment bolts. No bolts are required after lifting lug removal.
Item 6 - Holes for 5/8-inch diameter bolts used to attach the lif ting lug. These bolts are required to be reinstalled af ter lif ting lug removal.
Note B - The C6 lif ting lug mounting bracket, which is welded in place, covers the four middle 3/8-inch diameter bolt locations. This makes installation of the middle 3/8-inch diameter bolts impossible.
The two 5/8-inch diameter bolts shall be reinstalled as a substitute after lifting lug removal.
s.
3 ATTACHMENT D 4
APS RESPONSE TO SECTION II, OF THE NOTICE OF VIOLATION FOR WICH NO CIVIL PENALTY IS PROPOSED
^l J
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o ATTACHMENT D 0
Page 1 APS RESPONSE TO SECTION II OF THE NOTICE OF VIOLATION FOR WHICH NO CIVIL PENALTY IS PROPOSED
)
PART I NOTICE OF VIOLATION II.A.
" Appendix B of 10 CFR 50, Criterion V, as implemented by Chapter 17 of the licensee's PSAR and FSAR requires, in part, that:
' Activities affecting quality shall be pre-scribed by documented instructions, procedures, or drawinge, of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions, pro-cedures, or drawings.'"
VIOLATION II.A.1 "1.
The separation and identification criteria as identi-fied in FSAR Section 8.3.1 are described, in part, by the following Bechtel documents:
(a) " Cable and Raceway Physical Separation Guide,"
Drawing 13-E-ZAC-077, Revision 2, and (b) " Installation Spe-
- j. -
cification for Cable Splicing, Termination and Sup-ports," Specification No. 13-EM-306, and " Installation Specification for Electric Cables and Cable Trays,"
Specification No. 13-EM-300.
s l
ATTACHMENT D e
o Page 2
" Tray fill requirements in the above specifications re-quires that cabling in random filled cable trays shall not extend above the side rails of the tray.
" contrary to the above requirement, in random filled tray lEZJ4AATSCE, cables were projecting above the level of the tray side rails."
"This is a Severity Level IV Violation (Suppl.ement II)."
RESPONSE TO VIOLATION II.A.1 (1). Admission or Denial of the alleged Violation:
The violation is admitted but the severity level assigned is incppropriate for the reasons stated herein and in Attachment B, pages 6-7.
(2). Reasons for the Violation:
This specific condition concerns a case which oc -
curred due to the close proximity of an HVAC duct to the tray in a congested area.
(3). Corrective Action Steps Which Have Been Taken and Results Achieved:
1 The noted deficiency has been docmnented on NCR EJ-3403 and dispositioned " rework".
The correc-l tive action for this case requires the control i
cables in the tray to be reorganized to provide l
clearance with an HVAC duct.
Overfilled trays are not a repetitive problem, because tray fill is monitored by the EE580 circuit and Raceway Program.
When 30 percent fill l
l
ATTACHMENT D g
Paga 3 is reached (e.g.,
this is the ratio of cross-sec-tional area of tray to cross-sectional area of the cable) the computer program refuses to accept any more cable in that tray section.
At that time, the designer has the option of overriding the computer restriction and including additional cables, provided that an evaluation is performed to establish that heat load criteria are not ex-ceeded and that cable tray is not filled beyond a reasoncble capacity to contain the cable.
Based on positive results from the evaluation of each such case, the 30 percent computer fill may be exceeded.
Thirty percent computer fill in general corresponds to 100 percent tray fill since the cables become interwoven during the pulling pro-cess.
Where there is no safety impact, tray fill is allowed to go above the side rai'Is.
Specifi-cation 13-EM-300 has been revised by FOR 72.521-E to permit cables to extend above the tray rails where there is no tray cover, provided that proper separation has been maintained.
Transfer Pro-cedure (WPP/QCI)31.0 has been revised to provide that no cable is in contact with other equipment.
Bechtel supervision in Unit 1 conducted a training session with eight electricians on the revised specification requirements.
The electricians con-t b
1 ATTACHMENT D Page 4 ducted a 100 percent review of all Unit 1 uncovered cable trays.
Conditions found which deviate from the revised specification requirements / allowances are being corrected.
Bechtel Construction has reviewed this same in-stallation in Units 2 and 3 and has taken steps to overcome the congestion caused by the HVAC duct.
(4). Corrective Steps Which Will Be Taken To Avoid Further Violations:
To preclude recurrence of nonconforming tray fill in Units 2 and 3, a PCN to Bechtel Construction Work Plan Procedure (WPP/QCI) 31.0 is being pre-pared to require an inspection for tray fill to the requirements of Specification 13-EM-300 as described above at the time of the area release walkdown prior to acceptance by Nuclear Opera-tions.
Field Engineering and QC will perform a 100 per-cent reinspection of all safety-related uncovered cable trays in Unit 1.
Unit 2 will reinspect any safety-related cable tray that has been released to PVNCS Nuclear Operations.
All deviations found will be corrected.
(5). Date When Full Compliance Wi31 Be Achieved:
The mmpleted reinspection of Unit 1 will be com-pleted by March 1, 1984.
ATTACHMENT D Page 5 Inspections of Unit 2 and 3 will be completed prior to fuel load of each unit.
Project Quality Program Manual, Procedure 18.6 - Project Quality Assurance Surveillances will be revised to specifically establish a monthly program for an overview of previously accepted installation by QC by February 28, 1984 VIOLATION II.A.2 "2.
The separation requirement, as described in the above specifications, identifies the minimum separation dis-tance between safety-related open-top trays and non-safety-related totally enclosed trays or raceways (con-
.duit) as one inch.
" Contrary to the above requirements:
"a.
Non-safety-related conduit lEZADCNRQ506 for thermostat lEQFNT1243C in HPSI A pump room was separated from safety-related group 1 junction box 1EZACCAKKJ03 by less than one inch.
"b.
At diesel generator E-PEA-G01, non-safety-related flexible conduit lEZGlANRX11 at junc-tion box 4 was in contact with safety-related flexible conduit lEZGlAARR20 at junction box 6.
"c.
In 4160-volt switchgear cubicle E-PBA-S03L
[ sic], non-safety-related flexible conduit I
.J
l I
ATTACHMENT D Paga 6 lEZJ1ANRR52 was separated from safety-related wiring by less than one inch (required sepa-ration is one inch).
"d.
In 4160-volt switchgear cubicle E-PBA-503K
[ sic), non-safety-related flexible conduit lEZJ1ANRR51 was separated from safety-related wiring by less than one inch (required sepa-ration is one inch).
"This is a Severity Level IV Violation (supplement II)."
RESPONSE TO VIOLATION II.A.2 (1). Adraission or Denial of the Alleged Violation:
The conditions described do exist, but item., "a" and "b" are not violations because the PVNGS FSAR or quality program addresses them.
Item "a" is not a violation of separation criteria requirements be-cause conduit lEZADCNRQ506 is for a telephone circuit.
Low-voltage circuits for telephone and/or computer systems have been analyzed and found as having no adverse effect on adjacent Class IE cables; therefore, they are considered exempt from the separation criteria requirement.
A change to the FSAR, SARCNil14, was initiated prior to the inspection (8/25/83) to clarify that Regulatory Guide 1.75 is not applicable to low energy circuits.
l
l ATTACHMENT D l',
Paga 7 Item "b"
is not a violation, since the noted de-ficiency is in an area which has not received the final inspection and acceptance per Bechtel Con-struction Work Plan Procedure (WPP/QCI) 251.1.
It is planned that these kinds of conditions will be identified and corrected as required by Regulatory Guide 1.75 during completion of walkdown, which is specifically designed to focus on all tray, con-duit, and wiring separation requirements.
The walkdowns per WPP/QCI 251.1 have not been com-pleted in many areas of Unit 1 because the imple-mentation of late design changes in many cases would have impacted compliance with the separation requirements.
The violation described in Items "c" and "d"
is admitted but the severity level assigned is in-appropriate for the reasons stated herein and in Attachment B, pages 6 and 7.
(2). Reasons for the Violation:
The root cause of the violation described in Items "c" and "d" can not be pcsitively identified.
The Class 1E vendor installed wiring within the cabinet may have been moved or disturbed during work or testing to come within one inch of the non-class 1E flexible conduit.
Alternately, the flexible con-duit may have been installed incorrectly.
l i
ATTACHMENT D e * '
Page 8 (3). Corrective Actions Taken to Date and Results Xchieved:
The specific conditions found were documented on Startup NCR's SE-2916 and SE-3293 or corrected on the spot.
' To broaden the data base for evaluation of the conditions originally found, Bechtel Construction conducted a similar review on the Containment Spray Pump "A-Train" and the Charging Pump "A-Train".
One other separation problem was identified during this review and was documented en NCR EJ-3646.
The conditions of noncompliance with separation criteria applicable to conduit installations as documented by the referenced NCR's have been re-viewed for safety significance.
The review indi-cates that the conditions, which are all consid-ered ninor, if.left uncorrected would have no impact on the ability to operate the plant and/or achieve a safe shutdown.
The final Construction QC walkdown inspections for conduit-to-conduit and conduit-to-tray have not been completed by Con-struction and Quality Control.
The list of re-leased areas not inspected per WPP/QCI 251.1 has been submitted for inclusion into the Master Tracking System (MTS) to assure completion prior to fuel load.
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ATTACHMENT D Page 9 (4). Corrective Steps Which Will be Taken to Avoid Further Violations:
To assure compliance with these requirements Con-struction will conduct retraining sessions with Field Engineers and QC Engineers to re-emphasize the importance of separation inspections.
Inspection for separation is currently covered in the installation precedures and documented on raceway installation and termination cards.
The separation inspection required by WPP/QCI 251.1 may or may not be completed as part of the area release walkdown required by WPP/QCI 31.0.
A PCN to WPP/QCI 31.0 is being prepared to require a note on the area release document noting that the 251.1 walkdown-has not been completed as part of (or before) the area release walkdown.
This will provide that the open item will be tracked on MTS.
The Field QA Surveillance Program will be upgraded to include a selective sampling of QC accepted installations on a monthly basis to continually assess effectiveness of the inspection program in vital areas of tray and conduit.
t l
SAR Change Notice 1142 has been initiated to clarify that Regulatory Guide 1.75 is not applic-able to low energy circuits such as telephone and paging circuits.
This SAR Change Notice provides-I s
I 1
l
l ATTACHMENT D Page 10 additional clarification to that already provided concerning low energy circuits such as fire detec-tion, previously provided in SAR Change Notice 1114.
(5). Date When Full Compliance Will be Achieved:
o Completion of all Unit 1, 2,
and 3 walkdown inspections will be completed prior to fuel load for each unit.
o The revision to WPF/QCI 31.0 and the acao-ciated retraining session will be completed By February 15, 1984.
o SAR Change Notices 1142 and 1114 will be in-corporated into a future amendment of the FSAR.
o Project Quality Program Manual, Procedure 18.6 - Project Quality Assurance Surveillance -
will be revised to specifically establish a monthly program for an overview of previously accepted installations by QC by February 28, 1984.
VIOLATION II.A.3 "3.
The separation requirement as described in the above specifications requires that each circuit and raceway be given a unique permanent alphanumeric identification and colored dots (round emblems) along their lengths at intervals not greater than 15 feet.
~
ATTACHMENT D Paga 11
" Contrary to the above requirements:
"a.
A separation group.1 cable tray located in HPSI pump room A was not marked with red colog identification (round emblems) between points 1EZACEATCBA and llEZACCARC03.
"b.
Round blue identification emblems were missing from channel D conduit (PT-351) for a distance of approximately 40/50 feet at the 120 feet elevation.
"c.
Temporary alphanumeric identification on cable tray lEZAIDBTXCF had not been replaced with permanent identification.
"This is a Severity Level IV Violation (Supplement II)."
RESPONSE TO VIOLATION II.A.3 (1). Admission or Denial of Alledged Violation:
The violation is admitted but the severity level assigned is inappropriate for the reasons stated herein and in Attachment B, pages 6 and 7.
(2). Reasons for the Violation:
For items "a" and "b",
the project has experienced problems with retaining these markings in place.
These markings were disturbed and fell off.
For item "c",
the work had not been completed due to an oversight.
ATTACHMENT D Pcgn 12 (3). Corrective Steps Which Have Been Taken and Results Achieved:
The specific problems identified were corrected as follows:
a.
Red dot missing in HPSI "A" room corrected on the spot.
b.
Blue emblems missing for 40 to 50 feet at 126 elevation corrected on the spot.
c.
Temporary I.D. was replaced by permanent I.D.
as documented on NCR EA-3332.
To broaden the data base for evaluation, Con-struction conducted a review of raceways as-sociated with Charging Pump "A-Train" and Contain-ment Spray Pump "A"-Train" for similar raceway identification problems.
Of 220 raceways reviewed, 13 were found to have some deficiency.
These are documented on NCR's EJ-3645 and EJ-3647.
As a result of this evaluation, a 100 percent reinspec-tion program for safety-related raceway will be implemented in Unit 1 to assure compliance with this requirement.
The condition of missing raceway / conduit alpha-numeric identifications and color codings as identified by the NRC violation have been evalu-ated for safety significance.
The evaluation indicates that the noted conditions, if'left un-O
ATTACHMENT D Paga 13 corrected, would have no impact on the ability to operate the plant and/or achieve a safe shutdown,
since the cables are also color coded.
The con-dition does net constitute a significant construc-tion deficiency requiring extensive repair or re-design to establish conformity with design re-quirements.
(4). Corrective Steps Which Will be Taken to Avoid Further violations:
To preclude recurrence in Units 2 and 3, PCN 57 has been issued to WPP/QCI 31.0 requiring raceway identification verification at the time of area f
l release walkdown.
I Field Engineering and QC Engineering personnel will be trained regarding the additional in-spection element added as a result of the pro-cedural revision.
The Field QA Surveillance Program will be upgraded to include a selective sampling of QC accepted l
l installations on a monthly basis to continually i
assess effectiveness of the inspection program in vital areas of raceway identification.
(5). Date When Full Compliance Will be Achieved:
1 Retraining of responsible personnel, and comple-tion of the 100 percent reinspection program for Unit 1 will be completed by March 15, 1984.
ATTACHMENT D Page 14 o
Project Quality Program Manual. Procedure 18.6 - Project Quality Assurance Surveillance -
will be revised to specifically establish a monthly program for an overview of previously accepted installations by QC.
This revision will be issued by February 28, 1984.
VIOLATION II.A.4 "4.
IEEE Standard 384-1974, ' Criteria for Separation of Class IE Equipment and Circuit Breakers,' endorsed by the Licensee in Section 8.3.1 of the FSAR in Section 5.1.2, states, in part, ' Exposed Class IE Raceways shall be marked in a permanent manner at points of Entry and Exit from an Enclosed Area.'
" Contrary to the above requirements, at the time of the inspection, the following separation group I conduits were not identified by alphanumeric markings:
"a.
Conduits lEZJ1AARCl2, 14, and 16 on both sides of the wall between group I,
4.16 KV switchgear area and channel A remote shutdown panel area at the 100-feet elevation.
"b.
Conduit sleeves lEZJ1BARCl3, 14, and 15 en control building wall in channel B remote shutdown area at the 100-foot elevation.
"Thi.s is a Severity Level IV Violation (Supplement II)."
ATTACHMENT D Pnge 15 R.ESPONSE TO VIOLATION II.A.4 (1). Admission or Denial of the Alleged Violations:
The violation is admitted but the Severity Level assigned is inappropriate for the reasons stated herein and in Attachment B, pages 6 and 7.
(2). Reasons for the Violation:
The first condition is attributed to an oversight by the Field Engineer.
The omission is attributed to oversights by area release walkdown personnel; this requirement was not included as a specific inspection element in the Construction walkdown procedure.
(3). Corrective Steps Which Have Been Taken and Results Achieved:
The specific problems id:.ified were corrected on the spot.
To broaden the data base for evaluation, Construc-tion conducted a review of raceways associated 1
with Charging Pump "A-Train" and Containment Spray l
Pump "A-Train" for similar raceway identification l
problems.
Of 220 raceways reviewed, 13 were found l
to have some deficiency.
These are documented on NCR's EJ-3645 and EJ-3647.
1 As a result of this evaluation, a 100 percent l
l reinspection program for safety-related raceway will be implemented in Unit 1 to assure compliance.
1 with this requirement.
l l
l 1
ATTACHMENT D Page 16 The conditions of missing raceway /conduiti alpha-numeric identifications and color codings as iden-tified by the NRC violation have been evaluated v
for safety significance.
The evaluation indicates that the noted conditions, if left uncorrected, would have no impact on the ability to operate the plant and/or achieve a safe shutdown.
The condi-tion does not constitute a significant construc-tion deficiency requiring extensive repair or redesign to establish conformity with design re-quirements.
(4). Corrective Steps Which Will be Taken to Avoid Further Violations:
To preclude recurrence in Units 2 and 3, PCN 57 has been issued to WPP/QCI 31.0 requiring raceway identification verification at the time of area release walkdown.
Field Engineering and QC Engineering personnel will be trained regarding the additional in-spection element added as a result of the pro-cedural revision.
The Field QA Surveillance Program will be upgraded to include a selective sampling of QC accepted in-stallations on a monthly basis to continually assess effectiveness of the inspection program in vital areas of raceway identification.
A ATTACHMENT D Page 17 (5). Date When Full Compliance Will Be Achieved:
Retraining of responsible personnel, and completion of the 100 percent reinspection program in Unit 1 will be completed by March 15, 1984.
Project Quality Program Manual will be revised to specifically establish a monthly program for an over-view of previously accepted installations by QC by February 28, 1984.
il l
1
(
l l
1 I
l t
ATTACHMENT D Page 18 PART II NOTICE OF VIOLATION.II.B.
" Appendix - B of 10 CFR 50, Criterion V, as implemented by Chapter 17 of the Licensee's PSAR and FSAR requires, in part, that:
' Activities affecting quality shall be pre-scribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions, pro-cedures, or drawings.'
" contrary to the above requirement and the specifications listed below, the following conditions existed at the time of the inspection."
VIOLATION II.B.1.
"1.
Section 11.0 of Bechtel Specification 13-CM-320,
' Erection of Structural and Miscellaneous Steel,'
states, in part:
' Installation shall be in accordance with AISC ' Specification for Structural Joints using ASTM A325 or A490 bolts.'
Paragraph 5(a) of the AISC specification requires that A325 bolts, 7/8-inch diameter be tightened to at least a minimum tension of 39 Kips.
An acceptable method of obtaining this ten-sion is described in paragraph 5(c),
' Turn-of-Nut Tightening,' which requires that bolts be brought to a
' snug tight' condition plus an additional 1/3 to 2/3 turn, depending on the bolt length.
e
ATTACHMENT D Page 19
" Contrary to these requirements, on September 5 and 13, 1983, four A325 bolts were finger loose.
Using a calibrated torque wrench, two A325 bolts showed a tightness of less than 39 Kips.
These bolts were located in the structural steel beams as itemized in NRC Inspection Report No. 50-528/83-34, pagec VII-3&4.
"This is Severity Level IV Violation (Supplement II)."
RESPONSE TO VIOLATION II.B.1 (1)
Admission or Denial of the Alleged Violation:
The violation is admitted but the severity level assigned is inappropriate for the reasons stated herein and in Attachment B, pages 6 and 7.
(2)
Reasons for the Violation:
(a)
Loose Bolts:
The NRC performed visual inspection of 368 bolted connections of platform and structural steel in the Auxiliary and Containment buildings.
Four bolts were found in one con-nection of an Auxiliary Building personnel access platform which were " finger loose."
During a review after the NRC identified the loose bolts, Bechtel QC identified two addi-tional bolts in another connection of the same platform which were also " finger loose."
Bechtel Quality Assurance performed a similar visual surveillance of 43 connections and l
ATTACHMENT D Page 20 found no loose bolts; however, one bolt did not meet the specified thread engagement.
(Reference NCR CC-4333).
Subsequent to this, Bechtel Engineering performed a visual review of structural steel connections in the Auxi-liary and Containment Buildings of Units 1, 2 and 3.
A total of 361 connections containing 2,192 bolts were reviewed.
One connection containing four " finger loose" bolts, one connection with one loose bolt, and one ccn-nection with one bolt having insufficient thread engagement were identified.
These connections were in the Unit 1 Containment Building at elevation 120'-0".
In the cases found by these inspections, the loose bolts tend to be located in clusters, not randomly located within connections and have been painted in the loosened condition indicating that proper installation was never completed.
This indicates that the reason for the violation is oversight by both craft and QC inspection.
The two connections which had four loose bolts are standard AISC, bearing type, clip-angle connections consisting of six bolts in each co'nnection.
The remaining two bolts in
- _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ ___ _ _ _ a_
l ATTACHMENT D Pago 21 each of these connections were found to be tight.
Per general drawing 13-C-00A-001, all structural steel bolted connections are bearing type with the maximum number of rows of bolts permittable unless noted otherwise on the design drawing.
Providing this type of connection is conservative in tuo re-spects:
(1)
Conservative loads are used to design the members and the connec-tions typically are adequate with fewer than the maximum number of bolt rows.
(2)
By the nature of AISC specified design allowables, design of con-nections is more conservative by a substantial margin than that of the connected member.
Also, bearing type connections do not rely on tension in the bolt to transfer load and, in fact, as long as the bolts remain in the con-nection adequate load transfer will occur.
The nut in this case is purely a retaining device and theoretically could be replaced by anything which would ensure that the bolt
ATTACHMENT D Page 22 did not fall out of the connection (i.e.,
This concept is reinforced in the commentary on the AISC Specification for Structural Joints (8/14/80), Section C6, page 22, where it is stated in part:
. The performance of the bolt in bearing is not dependent upon high tension.
Visual evidence of wrench im-pacting is adequate indication that the nut
~
has been tightened sufficiently to prevent it from loosening or falling off accidentally."
Combining the above facts with the results of all the inspections, which indicate 99.5% of the connections do not have loose bolts, Bechtel Engineering has evaluated that the loose bolts in bearing type connections is not prevalent and is not safety significant.
No further inspection of bearing type joints is warranted.
The connection which Bechtel QC identified as having two loose bolts is a beam to wall con-nection consisting of three bolts total.
The remaining bolt in this connection was found to be tight.
This connection is typical of structural steel connections at concrete interfaces and in skewed connections in that
~
ATTACHMENT D i
Pcga 23 the holes are slotted in the horizontal di-rection to allow for irregularities in the cast in place concrete walls and for fabrica-tion tolerances, respectively.
If lateral loads are present that must be transmitted through these connect' ions, then the bolts would be required to be friction-type.
Al-though this particular joint is slotted in the horizontal direction, no horizontal loads are required to be transmitted by this con-nection and the vertical loads may be trans-ferred as in a bearing type connection.
The same conservatisms which were mentioned earlier also apply here.
A further discus-sion of friction type connections is pre-sented in Part II.B.1.b.
(b). Undertorqued Bolts:
The NRC also performed calibrated torque wrench testing on 62 high strength bolts which were not visually loose.
Two bolts were determined by the NRC to show a torque or tensi,n less than the minimum required by AISC.
Bechtel Construction conducted an identical inspection of 115 other randomly selected high strength bolts and found four bolts, of the 115 bolts inspected, that were
,y
\\
ATTACHMENT D Pago 24 p..
tight but did not meet torque requirements.
s A further investigatioa was made by Bechtel s
x Engineering by performing a calibrated torque wrench test on 180 additional bolts in the
. y
' ~ A' Unit 1,2, and 3 Auxiliary and Containment Buildings.
This investigation indicated that
'OS%'of the bolts checked in the Containment y_
Buildings were torqued correctly.
Of the remaining 5%, only a slight rotation (1/12 to 3,
,\\,
9
~
1/16 turn) was required to bring the bolts up i
to the required torque.
s 2 'before, 'li't, is pointed out that for the most pa\\.rt4 the structural steel joints in the ys containment and Auxiliary Buildings are
'Yi,.
bearing typs and do not depend upon tension for load transfer.
AISC uses the same in-stallation procedure for bearing or friction type connections to minimize the changes of craft error in installing the bolts as bear-
\\
ing type when they should be friction type.
1 b,
)
Y..
It also ensures against accidental loosening of the nut and possible loss of the bolt from the connection.
For those joints in Containment which require s
(friction type bolts, design margins are such 1
~
'that at least one bolt in any connection may k
h 7
s s,
s
ATTACHMENT D Paga 25 be undertorqued or even loose without af-fecting the load carrying capacity of the s
joint.
The 5% of the bolts which are indi-
~"'
cated to be undertorqued are acceptable based i
on this fact and the aforementioned design conservatisms.
Bechtel Engineering will, however, perform a further investigation of Accessible, critical, friction type connec-tions inside the Containment to assure con-nection adequacy.
In the Auxiliary Building, a higher percent-age of bolts than that in containment was shown to be undertorqued.
This is of little
,s significance primarily for the following rea-
l Sons:
The majority of the main structural steel in N
the Auxiliary Building is used for supporting the wet weight of the concrete slabs during construction.
It has already served its primary function.
The remaining main struc-tural steel, which supports grating, does not have slotted holes and all connections are bearing type.
The platforms inside the Aux-iliary Building are for personnel access only.
The steel is lightly loaded and the connections are bearing type.
Secondary
t
.I ATTACHMENT D Pcg2 26 steel which spans between main beams and supports HVAC ducts or cable trays in all buildings do have slotted holes in the hori-zontal direction.
These beams are, however, lightly loaded and tension (even if it were f
less than the AISC minimum) in any one of the four connection bolts would provide 1.oad n
-i transfer.
In the highly unlikely event that j
all four bolts, ' two on each end, were loose, g,-
structural integrity would still be main-tained and fai10re of the beam or the systen it supports woul,d tht occur.
Subsequent re-
~
J view of the Design. drawings for Category. I 5
/
_j Buildings other than the Containment show~
t
/
' hat the connections, described for the Aux-
~ ' '
t
~
- r
..G
^'
iliary Building are pypical.
It is therefore
+:.
. concluded the.t no criticdl friction-type con-t nections are present in these buildings _and no further investigation is warranted outside of Containment.
5 As a further point of informah.icn concerning this subject, the newest AISC Specification for Structural Steel Joints (8/14/80 ) ' no longer recognizes the calibrated torque wrench methodology because of "the large variability of torque-to-tension relation-
ATTACHMENT D Psga 27 ships for seemingly similar bolts and con-ditions."
(3). Corrective Steps which Have Been Taken and Results Achieved:
(a)
Loose Bolts:
(i)
The loose bolts in the two structural joints of platferm A-C-6 at elevation 51'-6" in the Auxiliary Building which 4
were identified by the NRC and Bechtel QC have been replaced and torqued to AISC requirements in accordance with NCR CA-4308.
(ii)
The loose bolts identified by the En-gineering walkdown will be corrected as documented by NCR CC-4496.
(b)
Undertorqued Bolts _:
(i)
An inspection was made by Bechtel En-gineering using a calibrated torque wrench.
?.lthough a number of bolts were found to be undertorqued, the condition is not safety significant.
1:o further investigation is warranted in Category I buildings other than the containment.
(4). Corrective Steps Which Will be Taken to Avoid Further Violations:
(a)
Loose Bolts:
(i)
No further steps will be taken.
~.
ATTACHMENT D Page 28 (b)
Undertorqued Bolts:
(i)
Since this data indicates that approxi-mately 5% of the structural steel bolts installed may be undertorqued, Bechtel Engineering will prepare and implement a walkdown program which will provide for reinspection of the accessible critical structural steel connections in all Con-tainment Buildings in Units 1, 2, and 3.
These connections by their location and design will be determined as essential for the structures to function under design basis conditions.
The connec-tions inspected will be those which require a friction type bolt in order to transfer lateral loads.
Based on the results of this reinspection program, decisions can be made on what further actions must be implemented.
The Field QA Surveillance Program will be upgraded to include a QA overview of structural steel bolt /
welded connections accepted by QC on a monthly random sample.
This activity is alco included in the approved Field QA Audit Schedule.
(5). Date hten Full Compliance Will be Achieved:
o The reinspection progra.n of the accessible
~
critical connections in Units 1,
2, and 3
ATTACHMENT D Page 29 Containment Buildings will be completed by April 20, 1984.
o Revision to Project Quality Program Manual, Procedure 18.6,
" Project Quality Assurance Surveillance," will be issued by February 28, 1984.
VIOLATION II.B.2 "2.
Bechtel Specification 13-CM-307, ' Design, Installation, and Testing of Concrete Anchors,' establi-shed require-ments for bolt embedment depth, spacing, torquing, and case-by-case Licensee approval for use.
" Contrary to these requirements, concrete expansion anchors were deficient in that 15 bolts were under-torqued, washers were missing under two nuts, three bolts were insufficiently spaced.from other bolts or unused holes, three unused holes were ungrouted, and two cases existed where prior Licensee approval was required and not obtained.
These anchors were located in various safety-related raceway supports, and are itemized in NRC Inspection Report No. 50-528/83-84, pages VII-8&9.
"This is a Severity Level IV Violation (Supplement II)."
RESPONSE TO VIOLATION II.B.2 (1). Admission or Denial of Alleged Violation,:
The violation is admitted but the severity level assigned is inappropriate for the reasons stated herein and in Attachment B, pages 6 and 7.
ATTACHMENT D Page 30 (2)
Reasons for the Violation:
Expansion anchors of various types are used on this Project only when all other viable alterna-tives are exhausted.
Expansion anchors are cate-gorized by Specification 13-CM-307 into four
- groups, "A"
through "D",
depending on their ap-plication and safety significance.
Group "A "ex-pansion anchors are used for safety-related pipe supports and hanger connections.
Only Rock Bolt Expansion Anchors are used in Group "A".
Group "B"
includes all electrical cable tray supports and Cut.egory I HVAC duct supports.
Approved Hilti, Ramset, or Drillco expansion anchors may be used for Group "B".
Group "C" includes pipe sup-ports and hanger connections.for the fire-pro-tection piping and for all other project clas-sifications not included in Group A, B,
or D.
Approved Hilti, Ramset or Drillco expansion anchors are used for Group "C".
Case-by-case approval by APS is required for expansion anchors used in Groups A, B,
and C.
Group "D"
includes electrical raceway (except cable tray), aluminum sheathed cable, non-class IE systems, instrument tubing, sensing lines, local panels, communication systems, non-category I HVAC supports, and mis-cellaneous platferm and stair systems where load O
y e-
--_-,.m
,.m
c.
,,-s
.r..
ATTACHMENT D Page 31 is transferred in shear only.
Hilti, Ramset or Drillco expansion anchors may be used for Group "D".
No case-by-case approval, testing or docu-mentation is required since the criteria for the use of these anchors were pre-established.
The expansion anchors for all groups are designed conservatively using large factors of scfety and in accordanca with I&E Bulletin 79-02.
Furthe.r factors of safety are applied when vibratory or impact loadings may be present.
With respect to the 15 Hilti KWIK-bolt expansion anchors which were found by the NRC t'o be under-torqued, test data has shown that Hilti KWIK-bolt expansion anchors lose a significant amount of their initial torque, up to 30 percent in some cases.
It was also shown that this loss does not significantly affect the anchor's load carrying capacity.
The high factor of safety utilized in design ensures the proper functioning of the anchor.
Subsequent to the NRC inspection, Bechtel QC teinspected, at random, an additional 226 con-crete expansion. anchors in various areas of the Auxiliary, Control and Containment Buildings.
Of those, one bolt was found to be slightly under-torqued, but not loose, and one was stripped (turned in hole but would not pull out) such that ii
ATTACHMENT D Page 32 it could not be torqued.
None of the other type of
.01ations identified by the NRC were found during the reinspection effort.
Prior to, and continuing after the NRC inspection, a systematic walkdown of electrical raceway supports has been in progress.
The purpose of this walkdown is to ensure compliance with the design drawings and specifications.
It encompasses Units 1, 2, and 3 and supplies as-built information for Bechtel Engineering review and disposition.
Deficiencies such as those found by the NRC CAT inspection are routinely identified, documented and dispositioned by Bechtel Engineering.
Most of these discrep-ancies are found to be acceptable and are dis-positioned Use-As-Is and are documented on FCR's or as-built drawings.
These which are deemed unacceptable are corrected and documented by NCR's.
The deficiencias found by the NRC which are rela-tive to concrete expansion anchors have been eval-uated by Bechtel Engineering and it has been de-termined that none of the conditions would have adversely affected the safety of plant operations.
Left undetected, none of the deficiencies would have caused failure of the systems they support.
This is due, in part, to the high amount of re-I
)
ATTACHMENT D Page 33 dundancy designed into each system.
Based upon these considerations, none of the conditions identified are safety significant.
Based on the fact that the HPSI "A"
room has undergone a significant amount of modification which is not typical of most of the plant, Bechtel Engineering feels that the number of deficiencios found is not representative of the overall quality of installation.
To provide additional data con-cerning these installations, a reinspection in Units 1,
2, and 3 of expansion anchors will be performed and the results evaluated.
Torque will be checked to 70 percent of the installttion torque value.
This inspection torque, based on the previously mentioned test results, is the torque which the in-situ anchors are expected to exhibit.
Failure to obtain APS' approval prior to in-stallation of concrete anchors is attributed to oversight.
All the responsible individuals in-volved in approving concrete anchor installations have reviewed this violation and applicable spec-ifications.
(3). Corrective Steps which Have Been Taken and Results Achieved:
The problems identified by the NRC concerning con-(
crete anchors were either corrected on the spot,
ATTACHMENT D Page 34 as documented on NCR's WA-3396, EA-3400, and EA-3405 or were covered by FCR 62,238-C.
These violations were all found in the HPSI "A" Room and in the Auxiliary Building wraparound section at Elevation 100'-0".
(4). Corrective Steps Wnich Will be Taken to Avoid Further Violation:
A procedural change to require 100 percent QC in-spection for all accessible safety-related con-crete expansion anchor installations is being pro-cessed.
The original inspection sampling require-ment was 10 percent; however, the implemented practice of inspection as verified by the rein-spection program, has been approximately 90 percent.
Bechtel Engineering has revised Specification 13-CM-307 by issuing SCN 3570.
This change im-proves the administrative process by which APS approval is obtained before concrete expansion anchors can be used.
An additional SCN to Spec-ification 13-CM-307 will be issued to reflect the QC procedural change mentioned above.
In accordence with the revised specification, En-gineering must include a reference to the APS au-thorizing correspondence on any design document issued to Constructioh showing expansion anchors.
4
l l
ATTAChTENT D Page 35 As part of the transfer process, as established by WPP/QCI 31.0 a punchlist is assembled of all work remaining in the area that must be completed prior to the area release.
Grouting of unused holes is included on that punchlist.
The Field QA Surveillance Program will be upgraded to include a selective sampling of QC accepted in-stallations on a monthly basis to continually assess effectiveness of the inspection program in vital areas of concrete expansion anchors, (5). Date When Full Compliance Will be Achieved.
o The revisions to Specification 13-CM-307 and Construction procedure WPP/QCI 24.1 will be issued by February 28, 1984.
o The expanded evaluation of the installed con-crete anchors will be completed and docu-mented by April 1, 1984.
o Project Quality Program Manual will be re-vised to specifically establish a monthly program for an overview of previously ac-cepted installations by QC by February 28, 1984.
s VIOLATIONS II.B.3 and II.B.4 "3.
Procedure WPP/QCI 201.1, Revision 18, dated May 25, 1983, ' Nuclear Pipe Hangers and Supports Installation,'
Appendix I,
requires the QC Engineer to verify each completed task on the 'CIP for Nuclear Pipe Supports.'
J
ATTACHMENT D Page 36 "The inspection requirement on the CIP for ' Task l' is to verify that the support assembly is correct per ap-proved engineering drawings and specifications.
" Contrary to the above, in September, 1983. Unit 1 pipe supports were found to be incorrectly installed per ap-proved drawings and specifications but had been ver-ified correct by the Piping QC Engineer.
Specifically, supports SI-106-H003, H005, and H036; SI-101-H00A; and SI-106-H001 were found with items which did not meet drawing requirements as described in Inspection Report 50-528/83-84, pages V-3, 4,
and 5.
The supports had been ' accepted by Piping QC Engineers during the period between November 28, 1979, and November 20, 1981.
"This is a Severity Level IV Violation (Supplement II)."
"4.
Procedure WPP/QCI 201.1, Revision 18, dated May 25, 1983, ' Nuclear Pipe Hangers and Supports Installation',
Appendix I,
requires the QC Engineer to verify each completed task on the 'CIP for Nuclear Pipe Supports'.
The
'CIP' inspection requirements for Task 8 require l
the Welding QC Engineer to verify that field welding is complete.
For Task 9, he is to check the vendor welding for size and length.
Additional instructions to the i
Welding QC Engineer in Appendix I instruct him to verify welding acceptability.
l
" Contrary to the above, in Septe.
r 1983, Unit 1 pipe supports were found with unacceptable weld conditions i
ATTACHMENT D Page 37 which had been reported as acceptable by the Welding QC Engineers.
Specifically, pipe supports SI-100-H005, H015, and H034; SI-102-H00B, SI-106-H0ll and SI-176-H001 and H003 were found with unacceptable weld condi-tions.
The supports had been verified acceptable during the period July 14, 1980 to September 15, 1982.
The welds and deficiencies are described in NRC In-spection Report No. 50-528/83-84, pages V-5, 6, and 7.
"This is a Severity Level IV Violation (Supplement II)."
RESPONSE TO VIOLATIONS II.B.3 and II.B.4 (1). Admission or Denial of Alleged Violation:
The violations are admitted but the severity level assigned to Item II.B.4 is inappropriate for the reasons stated herein, and in Attachment B, pages 4
6 and 7.
(2). Reasons for the Violations:
During the NRC inspection of the Safety Injection System, 12 pipe supports were found which did not meet the criteria of the design drawing and ap-plicable tolerances allowed by Procedure WPP/QCI 201.1.
The basic concern seems to involve the size and quality of welds which were performed by the craft and accepted by Quality control.In re-viewing the violations, many of the problems are a result of unclear procedures for inspecting welds.
Along circumferential areas of piping, problems
ATTACHMENT D Pega 38 arise when a pipe stanchion or a pipe lug is pre-pared to fit up to a pipe (see Figure 1).
GAP r
1
,y,,,,
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"J w ississssisi n SECTION A-A PLAN FIGURE I_
As shown in Section A-A of Figure 1, the normal fit-up of pipe spools and support stanchions leaves a gap between the inside and outside dia-meters of the stanchions.
Although the design drawing specified the pipe spool to support stanchion attachment weld to be an all-around
ATTACHMENT D Page 39 fillet weld, this attachment weld was in many cases made by filling in the gap between the spool and the stanchion.
This method of welding is structurally equivalent to the fillet weld spec-ified on the design drawing.
Another common problem detected on welded piping attachments such as support stanchions, was the omission of the fillet weld cap on a full penetra-tion weld required by the design drawing.
Fillet weld caps are normally specified on all support stanchions with full penetration attachment welds to provide a smooth stress path transition between the pipe spool and the stanchion.
Due to the size ratio between the pipe and the support stanchions used on this project, however, the majority of all stanchions do not actually require the fillet weld cap required by the design drawings to ensure the structural adequacy of the support.
Even though these cases do not cover all discrep-encies found, they are an example of the types of occurrences observed.
When designing miscella-neous steel structures certain criteria are used by Engineering which tend to establish a large factor of safety in the structure.
To meet stiff-ness requirements, deflection allowables are estab-lished.
By designing the structure to meet these l
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ATTACHMENT D Page 40 allowables, stresses in the members of the struc-ture are kept significantly below the allowables established by code.
For small bore piping, actual stresses tend to be not more than 20% of allowables while for large bore piping stresses are generally never more than 60% of allowables.
In addition, weld sizes are usually governed by code ininimums and not strength requirements.
(3). Corrective Steps Which Have Been Taken and Results Achieved:_
Specific pipe support items identified by these
' violations have been corrected by the following NCR's.
Violation II.B.3:
PA-7141, PA-7149, PA-7151, and PA-7154 Violation II.B.4:
PA-7154, PA-7155, PA-7170, PA-7171, PA-7229, PA-7230, and PC-7238 Since a number of supports on safety-related sys-tems were found to be " substandard" with regards to design requirements, the project elected to implement a major and comprehensive reinspection program.
The following types and categories of supports and racks were included in this reinspec-tion program:
ATTACHMENT D Pcga 41 a.
All ASME Nuclear Class 1 pipe supports.
b.
All ASME Nuclear Class 2 and 3 pipe supports included in the condensate Transfer and Storage System, the Essential Chilled Water System, the Essential Cooling Water System, the HVAC -Containment Building, and the Con-tainment Hydrogen Control System.
c.
All pipe supports in the In-Service Inspec-tion Program which includes the Auxiliary Feedwater System, the Chemical and Vc,lume Control System, the Reactor Coolant System, the Main Steam System, and the Safety Injec-tion and Shutdown Cooling System.
d.
All other safety-related pipe supports in-spected and accepted by Construction QC prior to June, 1980.
The reinspection program included 2199 pipe sup-ports and pipe racks.
All inspections of the program were completed on December 16, 1983.
A total of 2,047 pipe supports and 104 pipe racks were reinspected.
A total of 48 pipe supports were not accessible for reinspection.
All non-conforming conditions noted during the rein-spection program were documented on NCR's PX-7370 and PX-7313.
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ATTACHMENT D Page 42 These NCR's identify a total of 1,269 nonconform-ing conditions on 807 different pipe supports or pipe rack assemblies.
The majority of nonconforming conditions were con-cerning welds.
A total of 925 (72.9%) of all con-ditions reported addressed weld quality, weld size and weld length / location deficiencies.
Weld qual-ity includes the general quality of weld (example, weld splatter) and accounts for 93 (7.4%) of all deficiencies.
Weld size is the evaluation of all welds either undersize, oversize or cases where the size of weld is unclear on the applicable design docurunts.
This case accounts for 565 (44.5%) of all deficienceis.
Weld length / location accounts for all incomplete welds, short welds, intermittent spacing incorrect, missing welds and incorrect locations of welds and accounts for 267 (21%) of all deficiencies.
All weld deficiencies were evaluated as not having an aaverse affect for the respective systems with the following justifi-cations:
(1) All linear indications which re-sulted in code violations were removed.
(2) As stated previously, Bechtel Engineering has in-cluded enough conservatism to account for con-struction practices; and (3) of all the undersize welds which violated the AISC, AWS or ASME Code e
l ATTACHMENT D Page 43 requirements, 87% were 1/16" undersize, 11% were 1/8" undersize, and the remaining 2% were noted as being 3/16" undersize.
The welds which were 3/16" undersized were on obtuse angles where accurate measurements could not be mede, or in low stress areas where the minimum AISC weld size was not required for strength.
The design of the subject pipe support welds have been qualified as de-scribed in Bechtel's M&QS Report GRS-020-02, which is included with DER 80-3, The "as-built" cal-culations indicate that the designs are sufficient to carry the project design loads.
Therefore, the installed and as-designed pipe supports are ac-ceptable without repair.
This condition is viewed as not reportable under the requirements and re-portability criteria of 10 CFR 50.55(e), because if the condition had not been detected, it would not have constituted a significant safety hazard.
While the majority of the problems involved weld deficiencies, the most severe problems involved deficiencies in pipe support configurations and in pipe support components.
Pipe support configur-ation deficiences include fabrication problems, such as existing members larger or smaller than specified on the design drawing, and pipe support damage, such as members distorted or missing or i
ATTACHMENT D Page 44 unauthorized disassembly of bolted connections.
A total of 165 (13%) of all reported deficiences involved pipe support configuration problems.
Pipe support component deficiencies include those aspects of component installation, such as true-ness and correct installation per manufacturer's recommendation.
A total of 135 (10.6%) of all reported deficiencies involved pipe support com-ponent problems.
The most severe deficiencies identified by the reinspection program include five supports which have undocumented disassembly after final Con-struction QC acceptance.
These include hangers 1EC013H00E, 1EC014H00M and lECO61H00J which were found with the high strength bolts removed; hanger lEC015H00E had a member com-pletely removed; and hanger 1SI220H007 which had one of two snubbers disconnected at one end.
These conditions represent an overall failure rate of 0.2 percent and are evaluated as safety signifi-cant.
The evaluation of the reported hanger configura-tion and component deficiencies also indicates that the adequacy of 41 pipe supports with prob-lems in their categories have been rendered inde-terminate.
The various problems include:
(1)
ATTACHMENT D Paga 45 components skewed beyond manufacturers tolerance, (2) component pipe clamp bolt loose, (3) strut lock nut loose, (4) strut retainer ring missing, (5) cotter pins missing and (6) various jam nuts missing.
In each of the above cases, the locking device used to keep the component from vibrating loose is missing.
A missing locking device will not cause a failure of the support but could lead to component failure.
In connection with this reinspection program, Quality Assurance conducted an overview of the QC reinspection program on a random sample of 99 pipe supports to assess inspection effectiveness.
This resulted in rejection of 7 pipe supports accepted by QC during this reinspection program for a 7 percent error rate.
CAR S-83-56 was issued to QC to establish cause and obtain the necessary cor-rective measures to avoid recurrence.
All defi-ciencies found as a result of this overview pro-gram were dispositioned as "Use-As-Is".
In summary, the reinspection program can basically be separated into one group of weld problems and another group of support configuration problems.
Weld problems definitely encompass a larger number of supports.
However, the problemt, are all ac-ceptable as far as strength is concerned and did
ATTACHMENT D Page 46 not render the support incapable of its required function.
Even though strict inspection criteria was not followed in accepting these welds, all supports have been accepted and are fully func-tional for the design conditions.
Support con-figuration problems are not as numerous, but they do have a much greater severity level.
Almost all configuration deficiencies show evidence of cor-rect installation at one time, even though their present condition 'of disassembly was not docu-mented.
(4)
. Corrective Steps Which Will be Taken to Avoid Further Violation:
The scope of the reinspection program was adequate to determine the types, severity, and frequency of deficiencies which can be expected throughout each of the units.
This information indicates, that the remainder of Unit 1 safety-related pipe supports require reinspection to address the safety sig-nificant problems found during the reinspection program.
No additional reinspection for weld size, length or quality is required based upon the evaluated acceptance rate in the reinspection program.
The revised procedure for control of work per-formed during startup coupled with the use of
ATTACHMENT D Pcga 47 Bechtel Construction procedures to cover disas-sembly and reassembly of supports during startup will preclude recurrence.
F The following training sessions including special-i::ed training by Bechtel's Material and Quality Services (M&QS) on inspection techniques have been conducted with QC and Field Engineering personnel:
o October 20, 1983 - Instruction of Pipe Support and Welding QCE's by Bechtel M&QS on proper use of fillet weld gauges and on visual weld inspection criteria.
Instruction of Pipe o
October 27, 1983 Support and Welding QCE's and Welding FE's by Bechtel M&QS on proper use of M&QS weld gage for skewed fillet welds.
o December 7, 1983 - Reinstruction of Pipe Support and Welding QCE's by PFQCE on weld reinspection acceptance criteria.
Reinstruction of o
December 14, 1983 Pipe Support and Welding QCE's by Lead Welding QCE on pipe support accept /
reject criteria.
To improve and direct the Quality Assurance ac-tivity relative to the installation and QC accep-tance of pipe supports and other key construction activities, the following Quality Assurance pro-gram improvements are being implemented:
ATTACHMENT D Page 48 a.
A corrective Action Reverification Program is being established by Bechtel Jobsite QA.
The purpose of this program is to reverify the effectiveness of previous corrective actions taken for selected quality problems which:
o t'ere serious enough to have been reported to the NRC (DER's) o Have a history of recurrence (trends / audits / surveillance CAR's) o Ma.y be generic (Bechtel Power Divi-sions CIDS computer program).
Procedural guidelines are in the process of formulation to establish the selec-tive methodology, establish frequency of reverification,'and document results on appropriate forms.
b.
The Field QA Surveillance Program will be up-graded to include a selective sampling of QC accepted installations on a monthly basis to continually assess effectiveness of the in-spection. program in vital areas of pipe sup-ports.
(5)
Date When Full Compliance Will be Achieved:
o The physical work to resolve all nonconfor-mances requiring rework was completed January 20, 1984.
9 e.-
ATTACHMENT D Page 49 o
The revised final report for DER 83-74 will be issued by February 28, 1984.
o QA verification of corrective action taken by QC for Bechtel CAR S-83-56 will be completed by February 15, 1984.
o Project Quality Program Manual, Procedure 16.0 - Corrective Action - will be revised to include the corrective action reverification program and issued by February 28, 1984.
o Project Quality Program Manual, Procedure Project Quality Assurance Surveil-18.6 lance - will be revised to specifically es-tablish a monthly program for an overview of previously accepted installation; by QC.
This revision will be issued by February 28, 1984.
VIOLATION II.B.5 "5.
Specification 13-PM-204, Revision 12, dated April 17, 1983, paragraph 12.1.2, states the design and location of all pipe supports shall be the responsibility of project engineering.
Paragraph 12.1.4 states pipe sup-ports designed by engineering will be shown on drawings and all design details will be shown including miscel-laneous steel.
" Contrary to the above, in September, 1983, Unit I pipe support SI-100-H012 contained a miscellaneous steel l
1 ATTACHMENT D Page 50 member.
The member was not shown on the pipe support drawing, 13-SI-100-H012, Revision I, and was used to provide support to an instrument air line.
"This is a Severity Level IV Violation (Supplement II)."
RESPONSE TO VIOLATION II.B.5 (1)
Admission or Denial of the Alleged Violatiosu The violation is admitted, but the severity level assigned is inappropriate for the reasons stated herein and in Attachment B, pages 6 and 7.
(2)
Reason for Violation:
This condition is attributed to oversite by Bechtel Engineering.
(3)
Corrective Steps Which Have Been Taken and Results Achieved:
The noted procedural deficiency is documented on APS Corrective Action Request C83-142N.
The iden-tified pipe support drawing has subsequently been revised.
l Bechtel Engineering will review all Unit 1, 2 and i
j 3 pipe support drawings for the existence of any non-documented attached supports.
Normal design practice is to assare that multiple supports are clearly cross-referenced on the drawings.
The attaching support and the support being attached to are shown in phantom with support numbers on their respective counterpart drawings.
Similarly,
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ATTACHMENT D Page 51 the design calculations of each support include the load effects from all supported piping.
Loads from attaching supports are identified in the cal-culation with the support numbers indicated.
A review of this condition has determined that it is not safety significant.
(4)
Corrective Steps Which Will be Taken to Avoid Further Violations:
Revised calculations, hanger drawings, design change package, and DER's which apply to Units 1, 2 and 3 will be prepared if necessary as a result of the investigation.
Bechtel Engineering has notified all responsible design personnel of the design document require-ment.
(5)
Date when Full Compliance will be Achieved:
The investigation by Bechtel Engineering will be completed by March 1, 1984.
VIOLATION II.B.6 "6.
Procedure WPP/QCI No. 204.0, Revision 3,
' Piping Sys-tems Release for Insulation', Appendix I requires that piping systems be checked for unacceptable surface dam-age prior to insulation of the piping.
" Contrary to the above, pipe spool 15I-009 S002 was cer-tified acceptable for insulation on November 14, 1982, with the unacceptable pit in the pipe which violated minimum wall requirements.
is i
' s ATTACHMENT D Page 52 c
"This is a Severity Level IV Violation (Supplement II)."
RESPONSE TO VIOLATION II.B.6 (1). Admission or Denial of the Alleged Violation:
4 The violation is admitted but the severity level assigned is inappropriate for the reasons stated herein and in Attachment B, pages 6 and 7.
-(2). Reasons for the Violation:
s This violation was caused by an oversight by the QC Inspector.
An unclear procedure contributed to the oversight.
(3). Corrective Steps Which Have Been Taken and Results Achived:
The identified condition and another condition identified by the NRC CAT Team were documented on NCR's SM-2976 and PA-7138.
Both conditions were evaluated by Engineering as not violating minimum required wall requirements and were dispositioned
.q.
"Use-As-Is".
The depth of the indication did exceed the manufacturer's tolerane.e for minimum wall (12.5% of nominal).
However, in the investi-gation of this condition, Engineering determined
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that the minimum wall thickness required by design (calculation ZZ-584) had not been violated.
- This, therefore, does not represent a safety significant condition.
s 1
The WPP/QCI 204.0 for surface inspection of piping prior to release for insulation was revised and h
ATTACHMENT D s
Page 53 expanded for clarification.
Specifica1tly, the procedure was changed from a simple "acceptr buy-off to separate buy-offs for surface damage, arc strikes, and cleanliness.
The reference to ED-1 for visual acceptar.ce criteria was deleted and the specific evaluation rcquirements were put into the procedure.
When the visual criteria is indeter-minate, a minimum wall evaluation is described that must be documented on the Construction In-spection Plan (CIP).
If, after that evaluation, the surface indication is not acceptable, the pro-cedure now requires that an NCR be prepared.
In order to determine the likelihood that some unacceptable surface indications could exist on piping insulated prior to the procedure changes, a review of approximately 550 "Q"
class spools was made in Unit 1.
This sample included spaols that had been previously insulated but were currently "uninsulated" for some reason, and spools that had yet to be insulated.
Although many spools were reported with minor blemishes, abrasions, or indications, all but five were acceptable to the visual criteria.
The five indications were eval-uated and found to be acceptable to the current criteria.
No nonconforming indications were found.
ATTACHMENT D Page 54 The sample size approximately 550 represents 22 percent of the 2,532 "Q"
spools requiring insu-lation.
It has been concluded, therefore, that no detrimental surface irregularities exist on "Q"
piping insulated prior to the procedure change.
(4). Corrective Steps Which Will be Taken to Avoid Further Violations:
To maintain high inspection standards for the work being performed in Units 2 and 3, formal training for piping field engineers, QC engineers, and sub-contract engineers was conducted after the pro-cedure was changed.
Three PCN's have subsequently been issued against WPP/QCI 204.0.
The Field QA Surveillance Program will be upgraded to include a QA (
trview of piping systems re-leased for insula Aon per WPP/QCI 204.0 on a con-tinuous monthly basis, to assure correct disposi-tion / resolution of surface damage and maintenance of cleanness, prior to application of insulation.
WPP/QCI 204.0 is included in the approved Field QA Audit Schedule.
This activitiy will specifically cover Unit 2 and 3 systems released for insula-tion.
(5). Date When Full Compliance Will be Achieved:
WPP/QCI 204.0 revisions and retraining of respon-sible personnel have been completed.
Revision to
ATTACHMENT D o -
Page 55 Project Quality Program Manual, Procedure 18.6 Project Quality Assurance Surveillance - will be issued by February 28, 1984.
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ATTACHMENT D Page 56 PART III NOTICE OF VIOLATION II.C
" Appendix B of 10 CFR 50, Criterion IX, as implemented by Chapter 17 of the licensee's PSAR and FSAR, re-quires, in part, that:
' measures be established to assure that special processes including welding are controlled and accomplished in accordance with appli-cable codes, standards, specifications, criteria, and other special requirements.'
"FSAR Section 3.8.1.66 states:
' Welding is done in ac-cordance with AWS Dl.1-72, Revision 1, 1973, Structural Welding Code. ' Bechtel Drawing 13-S-ZAS-536, Revision 3,
requires a 5/16-inch fillet weld when attaching structural steel vertical members to horizontal mem-bers.
Drawing 13-C-ZAS-570, Revision 8, requires a 5/16-inch fillet weld when attaching structural steel to embedded plates.
Additionally AWS Dl.1, Paragraph 10.17, states that undercut shall be no more than 0.01-inch deep when its direction is transverse to primary tensile stress in the part that is undercut, and not more than 1/32-inch deep for all other situa-tions.
" Contrary to the above requirements, at the time of the inspection, the size of structural steel fillet welds was less than required by the drawings and undercut in welds exceeded the requirements of AWS Dl.l.
These l
l ATTACHMENT D Page 57 welds were located in various safety-related structural steel and are itemzed in NRC Inspection Report No. 50-5283-84, pages VII-4, 5, and 6.
"This is a Severity Level IV Violation (Supplement II)."
RESPONSE TO VIOLATION II.C.
(1)
Admission or Denial of the Violation:
The violation is admitted but the severity level assigned is inappropriate for the reasons stated herein and in Attachment B, pages 6 and 7.
(2)
Reasons for the Violation:
The engineering deviations to AWS Dl.1-72, as in-cluded in the construction procedures and con-struction specification, had not yet been included in the applicable sections of the FSAR.
Field Engineering and Quality Control Inspection personnel did not identify or document minor deviations from weld specification requirements which had previously been accepted by project engineering on a nonconformance report without rework.
(3)
Corrective Steps which Have Been Taken and Results Achieved:
The noted violations concerning miscellaneous steel welding were documented on NCR CA-4320 for resolution.
The findings from Bechtel's re-inspection program are documented on NCR's CA-4366 and CA-4415.
NCR CA-4366 prompted the generation a
ATTACHMENT D Page 58 of DER 83-72 to provide an evaluation for safety significance under the requirements of 10 CFR I
50.55(e).
The structural and miscellaneous steel welding requirements as contained in Specification 13-CM-320 were revised for clarification and ease of interpretation by Field Change Requests (FCR) 72,146-C and 71,023-C, and Specification Change i
Notice (SCN) 3568.
Areas specifically addressed were weld undersize, oversize, and undercut.
The changes covered both welding requirements and inspection accept / reject criteria.
An additional review was performed by Bechtel Engineers to assure that all deviations to AWS Dl.1 meet the l
project design requirements.
Responsible Field Welding Engineering and Welding QC personnel were trained not only on the specification changes but also retrained on weld inspection techniques and the use of weld inspection tools and implements.
(a)
A training session on the use of skewed fillet weld gauges was conducted on Octo-ber 27, 1983, with all Welding QC Inspectors and all Welding Field Engineers.
f (b)
Training sessions were conducted with Welding QC Inspectors on October 20, 1983, and Decem-ber 7, 1983, to provide instruction on the
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ATTACHMENT D Page 59 clarified criteria and to reinforce existing inspection criteria.
Reinspection of 348 additional structural welds was completed on November 7, 1983 and the evalu-N ation of observed conditions is as follows:
Out of the 348 welds inspected, a total of twenty or approximately six percent were found to be undersized; eighteen welds were between 1/32" and 1/16" undersized while two were 1/8" undersized.
This condition is not safety significant.
Oversize welds are of concern when they could result in lamellar tearing of the base metal.
Particular concern is given to lamellar tear-ing when base materials greater than one inch
' in tnickness are overwelded.
The major pur-pose of limiting oversized welds on material less than one inch thick comes from econom-ical and distortion considerations.
The oversized welds identified here have been visually examined for excessive distortion and any indication of lamellar tearing.
No cracking or unusual distortion was observed.
The design margin used for this type of con-nection is generally about 30 percent.
Only a few connections were designed up to the allowable loads.
ATTACHMENT D Pagm 60 All design loads for the reinspected weld conditions were approximately 80 percent of the allowable loads.
As is expected for the majority of the cases, where design loads approximate allowable loads, margin still exists (e.g.,
approximately 15 percent which can be demonstrated by testing or dynamic analysis).
A review of the undersize structural steel welds identified by NCR's CA-4320, 4366, and 4415, comprising all the undersize welds identified by the NRC inspection plus those found by the Bechtel reinspection program, have been evaluated for safety significance.
The review by Bechtel Engineering found that all identified weld sizing defects could be dispositioned "Use-As-Is" since, if left un-corrected, none of the defects would repre-sent a safety significant condition.
Combining the very conservative design load-ing requirements, the conservative AISC minimum weld requirements, and results of the reinspection which resulted in all weld /
defects being dispositioned "Use-As-Is",
Bechtel Engineering concludes that the struc-tural and miscellaneous steel welding already
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ATTACIf""NT D Pagn 6.
completed in Units 1, 2,
and 3 is adequate, and is not safety significant.
Based on this evaluation, no additional reinspection of structural steel welds in Units 1, 2 and 3 is warranted.
(4)
Corrective Steps Which Will be Taken to Avoid Further Violations:
The FSAR will be revised by SAR Change Notice 1123, which will incorporate the specific welding requirements currently contained in Specification 13-CM-320.
The exceptions taken to AWS Dl.1-72, Revision 1, 1973, and the justification for the exceptions will be incorporated into the FSAR.
This change clarifies the licensing document to incorporate the flexibility permitted by the Code.
The change +1so provides consistency between the implemented practice reflected in the construction specification, as allowed by the Code, and the licensing document.
A re-review by Bechtel Engineering to provide ad-ditional assurance of consistency between the li-censing documents and the other currently imple-mented construction specifications is currently being completed and will be documented by the final report issued for Deficiency Evaluation Report 83-72.
2 ATTACHMENT D Page 62 The Field QA Surveillance Program will be upgraded to include a QA overview of structural steel welded connections accepted by QC.
This selective sampling on a monthly basis will assure that on-going activities are in compliance with specifica-tions and AWS Dl.1 requirements.
The WPP/QCI governing this activity will also be included in the approval Field QA Audit Schedule.
(5)
Date When Full Compliance Will be Achieved:
o A draft revision to FSAR Section 3.8.1.6.6 and 3A.10 will be submitted for NRC review by March 31, 1984, and incorporated into Amendment 13 to the FSAR.
o Additional training of Welding QC and Field Engineering to reinforce inspection criteria will be conducted by January 31, 1984.
o The final report for DER 83-72 will be issued by March 15, 1984.
o Revision to Project Quality Program Manual, Project Quality Assurance Procedure 18.6 Surveillance - will be issued by February 28, 1984.
ATTACHMENT D Page 63 PART IV NOTICE OF VIOLATION II.D "10 CFR 50 Appendix B, Criterlon XVI, states in part, that:
' Measures shall be established to assure that conditions adverse - to quality such as failures deficiencies defective material and equipment, and nonconformances are promptly identified and cor-t rected.'
Borg Warner valve assembly drawing number 77770-1 requires that the stud nuts connecting the bonnet to the valve body be torqued to a value of 160-200 foot pounds.
" Contrary to the above, on September 15, 1983, the in-spector observed torque verification performed on valve number V-470 which resulted in the identification of loose stud nuts connecting the bonnet to the valve body.
"This it a Severity Level IV Violation (Supplement II)."
RESPONSE TO VIOLATION II.D 1.
Admission or Denial of the Alleged Violation:
The violation is admitted but the severity level assigned is inappropriate for the reasons stated herein and in Attachment B, pages 6 and 7.
Reason for the Violation As noted in the response to the violation noted in section I.A.2, SI-470 was incorrectly assembled because of incorrect supplied parts from a sup-
Y Al"I'ACEMENT D pea 2 64 plier, although the asse
'ontrolled and documented.
However, sul the instal-lation, the valve was part.
assembled and improperly assembled.
2.
Corre:tive Steps Which Have Been Taken and the Results Achieved:
Valve SI V470 has been repaired as documented by SFR 1SI-292.
3.
Corrective Steps which Will be Taken to Avoid Further Violations:
To preclude recurrence on Units 2 and 3 and to provide a documented inspection on futare valve installations, Construction will revise WPP/QCI 202.0 to require verification that all vendor bolts, studs, and nuts are intact at the time the installation CIP is completed.
The responsible personnel will be trained regarding the additional procedure requirement.
To assure work performed under the jurisdiction of APS is properly controlled, work performed on any permanent plant equipment will be performed under an approved Work Control program.
This ensures that any changes to, or deviations from the plant design configuration, either temporary or perman-ent, are approved and documented prior to begin-ning the work activities.
Performance of work or test activities on any permanent equipment within r--r-.-
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ATTACHMENT D Page 65 APS' jurisdictional control must be concurred with by the Operations Shift Supervisor.
The operations phase Work Control Procedure will be similarly expanded to assure prompt identification of discrepancies, local identification tagging or previous identified significant problems, and tracking of tags until resolution.
The above re-quirements will ensure that the plant design con-j figuration and system status are maintained in a known, approved state.
APS will expand the Startup Work Authorization (SWA) procedure s.ch that when a discrepancy is f
observed on equipment in the startup jurisdiction, a SWA or SFR will be initiated.
A copy of the SWA will be forwarded to the Shift Supervisor for his information and to determine if a tag should be hung to identify the problem locally.
All tags will be tracked and controlled by Operations per-sonnel, with a copy of closed SWA's also forwarded to the Shift Supervisor to allow timely removal of tags.
Before acceptance of a system or subsystem by PVNGS Nuclear Operations, a PVNGS Nuclear Opera-tions Acceptance Walkdown will be conducted on the system to confirm that the system configuration is in accordance with design.
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ATTACHMENT D Paga 66 issue a directive to all AJS Startup and Opera-tions personnel informing them of their respon-sibility to identify, pursue and assure resolution of all discrepancies identified.
Personnel will also be instructed not to perform work without the proper authorization and controls.
4.
The Date When Full Compliance Will Be Achieved:
4.1 Construction procedures will be revised and personnel trained by February 28, 1984.
4.2 Startup procedures will be revised and per-sonnel trained by March 1, 1984.
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ATTACHMENT D Page 67 PART V NOTICE OF VIOLATION II.E
" Appendix B, of 10 CFR 50, Criterion II, as implemented by Chapter 17 of the licensee's PSAR and FSAR, re-quires, in part, that:
'The quality assurance program shall provide control over activities affecting the quality of the identified structures, systems, and com-ponents, to an extent consistent with their importance to safety '
" Contrary to the above requirement, pipe support SI H008 was found during the September, 1983, inspection with rubber seal material in between the Flourogold slide plates, Item 54 and 55 on the drafing.
The ap-plicable support drawing does not permit the use of rubber material.
The rubber material may impair the sliding function.
The support had been accepted by QC on November 29, 1979.
(
"This is a Severity Level IV Violation (Supplement II)."
l l
RESPONSE TO VIOLATION II.E l
1.
Admission or Denial of Violation:
The violation is admitted but the severity level l
t assigned is inappropriate for the reasons stated below and in Attachment B, pages 6 and 7.
2.
Reasons for the Violation:
The investigation of this violation revealed that the sealant subcontractor had spilled sealant ma-
4 ATTACHMENT D Pcga 68 terial some time earlier in the area.
The cleanup effort did not include an inspection for possible effect on equipment in the immediate area, and some material remained between the sliding plates until found by the NRC.
3.
Corrective Steps which Have Been Taken and the Results Achieved:
During reinspection of approximately 2,100 safety-related pipe supports, detailed in the response to Violations II.B.3 and II.B.4, all observed defi-ciencies were documented, including sealant ma-terial on or in the supports.
As a result, two additional supports were found with sealant ma-terial between the pipe and the restraint.
The conditions found by the NRC and during Con-struction's reinspection effort are documented on NCR -PA-7169 and NCR PX-7370, Items 300 and 364, and dispositioned " rework."
This condition has been evaluated for safety sig-nificance.
It was determined by Bechtel Engine-ering that the presence of the sealant material would not have impaired the function of the sup-port.
The sample size representing approximate 19 percent of all " safety-related" supports, the relatively few incidents found, and the evaluation that there is no safety-related problem, indicate
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1.
ATTACIDIENT D Pagn 69 that no additional reinspections are warranted for sealant material on supports.
4.
Corrective Steps That Have Been Taken to Avoid Further Noncompliance:
To preclude rectrrence on all Units, Subcontract Notices have been sent to both penetration sealing subcontractors directing them to notify the Bechtel Subcontract Coordinator of any spillage.
Upon such notification, the immediate area of the spillage will be inspected by Bechtel to assure proper cleanup has been achieved Both sealing Subcontractors have acknowledged the SCN's in writing, stating that their personnel had been trained in the new requirement that spills be reported to the Bechtel Subcontract Coordinator in the future.
5.
Date When Full Comoliance Will Be Achieved:
Full compliance has been achieved.
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3 ATTACHMENT E APS SEPARATE ANSWER, FILED PURSUANT TO 10 CFR 2.205, PROTESTING THE ASSESSMENT OF T'iE CIVIL PENALTY PROPOSED BY SECTION 1.A. OF THE VIOLATION.
.m_____._._____
ATTACHMENT E Page 1 SEPARATE ANSWER OF APS FILED PURSUANT TO 10 CFR 2.205 TO SECTION I.A. OF THE NOTICE OF VIOLATION 1.
Pursuant to 10 CFR 2.205 and the Notice of Violation, APS denies the violation alleged in Section I.A. of the Notice and protests the imposition of a civil penalty therefor.
As grounds for such denial and protest, APS states as follows:
1.1 The allegation in Section I.A. of the Notice that APS violated Criterion II of Appendix B, 10 CFR Part 58 is based solely upon the four " examples" cited in such section, to-wit:
1.1.1 The installation of caps on the contain-ment pressure sensing lines without the documentation required by established QA procedures and in the absence of any administrative requirement which would assure removal of the caps prior to operations.
1.1.2 The absence of any documentation re-cording the disassembled, nonconforming condition of the nanual operator of valve SI V470 on HPSI "A" pump.
1.1.3 The absence of any documentation re-cording the nonconforming condition of the position indicator for valve SI V402 on HPSI "B" pump.
1.1.4 The absence of bolts from the base frames of such MCC's necessary to ensure the structural integrity of six motor control centers (MCC's).
1.2 Two of the four examples cited did not constitute
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a violation of Criterion Il of Appendix B to 10
ATTACHMENT E Page 2 CFR Part 50 or any other Regulatory RequirementsM as demonstrated by Attachment C.W 1.2.1 The installation of caps on the contain-ment pressure sensing lines (the first example) was not a violation for the reasons stated in Sections 1 and 2 of Part I of Attachment C, pages 2-5.
1.2.2 No bolts necessary to ensure the struc-tural integrity of six MCC's (the fourth example) were missing as demonstrated by Sections 1-3 of Part IV of Attachment C, pages 23-27.
1.3 With respect to the second and third examples cited in Section I.A.,
APS denies that the un-documented, nonconforming condition constituted a Severity Level III violation, because the exis-tence of the condition, if left uncorrected, would not have prevented the HPSI system from operating in accordance with its design intent and, there-fore, was not significant to safety, s
It is questionable in 'the absence of safety significance whether the discrepant condition meets the test of a Severity Level V violation, i.e.
" minor safety concern."
It clearly does not meet the test of a Severity Level IV violation, M
The term " Regulatory Requirements" as used in this document has the same meaning as that given to the term by footnote 2 in Appendix C to 10 CFR Part 2.
M References in this document to Attachments A, B and C mean those attachments to the letter, dated January 30, 1983, from APS to the Director, Office of Inspection and Enforcement, submitted in answer to the Notice of Violation.
i 1
ATTACHMENT E Paga 3 since it is explicit in Appendix C of 10 CFR Part 20 that Severity Level IV applies only to a condi-tion "of more than minor concern; i.e.,
if left uncorrected, they could lead to a more serious concern."
(10 CFR 2, App. C,Section III).
Severity Level III applies only to "signifi-cant violations involving a deficiency in a li-censee quality assurance program for construction related to a single work activity (e.g.,
struc-tural, piping, electrical or foundations) and normally involves multiple examples (10 CFR 2, App.
C.,
Supp. II, para. C.l.).
(Em-phasis supplied).
Section I.A. of the Notice does cite four ex-amples, but it is clear that the second example is a work activity that is not any way related to example no. 1 (instrumentation) or example no. 4 (electrical).
It is also distinguishable from example no. 3 (which APS denies is a violation),
because example no. 3 did not involve a failure to follow work procedures during preoperational testing.
1.4 For foregoing reasons, APS denies that Section I.A.
alleges a Severity Level III violation and protests the assessment of the civi1 penalty as proposed.
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ATTACHMENT E Paga 4 2.
In the alternative, if the foregoing protest of the im-position of a civil penalty for the violation alleged in Section I.A.
of the Notice is disallowed, in whole or in part, APS requests the remission or mitigation of the civil penalty proposed by the Notice.
In support of such request and addressing the five factors dis-cussed in Section IV.B. of Appendix C to 10 CFR Part 2, APS submits the following:
2.1 APS acknowledges that (i) the discrepant condi-tions identified in the four examples cited in Section I.A.
did exist in September, 1983, (ii) there was no documentation or record of such dis-crepant conditions, and (iii) such conditions were identified by the CAT.
Nonetheless, consideration of these acknowledged facts must-be tempered by the following considerations:
2.1.1 The subsystems and equipment referred to in first, second and third examples had not been accepted by PVNGS Nuclear Operations. (See Section 1 of Parts I,
II and III of Attachment C, pp.
3, 9,
and 17, respectively.)
2.1.2 The transfer of such subsystems and equipment by Bechtel construction to the APS Startup organization did not mark the completion of construction under the PVNGS startup program. (See PVNGS FSAR, Section 14.2.1, pp. 14.2-1 and 14.2.2 and Attachment B, pp. 1-5.)
2.1.3 The subsystems and equipment referred to in the first, second and third examples were undergoing Preoperational Testing in September, 1983.
(See Section 1 of
ATTACHMENT E Pega S Parts I, II and III of Attachment C, pp.
2, 9, and 17, respectively.)
2.1.4 The existence of conditions which do not conform to conditions required for oper-ation is inherent in any incompleted construction.
2.1.5 Under the foregoing circumstances, the imposition of a civil penalty for a lack of documentation or a failure of APS to detect the discrepant condition can be based only upon an assumption that docu-mentation and correction would not have resulted from the completion of Preop-erational Testing then in progress or from inspections preceding acceptance by PVNGS Nuclear Operations of the discre-pant conditions.
2.1.6 It is unfair and unreasonable to impose a civil penalty upon an assumption that a violation of a Regulatory Requirement will occur in the future.
2.1.7 Each of the discrepant conditions cited in the second, third and fourth examples has been analyzed to be not significant to safety.
The significance to safety of the first example rests solely on an unreasonable assumption of a future failure to meet Regulatory Requirements.
Consequently, the conditions cited in the examples do not meet the criteria established by Appendix C to 2 CFR fart 2 for assignment of Severity Level III.
2.1.8 The assignment of Severity Level III to violations cited in the four examples is not warranted under the circumstances where (i)
None of the examples are signifi-cant to safety; (ii)
There are no multiple examples re-lated to a single activity (see section 2.6 hereof at page 10); and (iii)
The deficiency is a lack of docu-mentation of the status or condi-
ATTACHMENT E Page 6 tion of subsystems or equipment still in Preoperation Testing.
2.1.9 The severity level assigned to the lack of documentation respecting the status of subsystems and equipment still under-going Preoperational Testing should not exceed Severity Level V, or Severity Level IV at the most, if such deficiency is considered " symptomatic of program deficiencies, rather than isolated con-cerns."
Section IV, B).
2.2 Prior to the CAT Inspection, APS had (i) identi-fied the concerns identified in the Enforcement Letter and expressed by the CAT inspectors and the Regional Administrator during the Exit Meeting and the Enforcement Conference, (ii) had initiated corrective action, and (iii) had initiated steps to determine reportability under 10 CFR $50.55(e).
(See Attachment A.)
2.3 On its own initiative, APS has promptly taken com-prehensive measures (i) to improve the PVNGS Startup program, (ii) to assure proper implementa-tion of its quality assurance progrei, including, among other things, proper documentation, and (iii) to assure that work, inspections and tests previously performed during the Startup program were accomplished satisfactorily.
(See Attachment 2-3) 2.3.1 With respect to the timeliness and scope of the measures taken by APS to address the concerns raised by the CAT Inspec-D
ATTACHMENT E Pega 7
- tion, Attachment A addressed such matters more fully and is incorporated herein by reference.
In summary, how-
- ever, the record shows corrective measures were initiated by APS prior to the completion of the CAT Inspection.
The scope and intensity of such measures was subsequently increased with the senior management.gnd guidance of APS direct involvement Thus, in addition to the internal audit initiated by the Vice President, Nuclear Operations, immediately following the Exit Meeting on September 30, 1983 (see Attachment A, pp. 6-7), APS senior man-agement commissioned an independent as-sessment conducted by a team consisting for the most part of members with no direct responsibility for PVNGS and headed by a qualified individual from another utility.
This independent as-sessment was instituted promptly after the CAT Exit Meeting and before the CAT Inspection Report was issued.
(See At-tachment A, pp. 7-8).
On November 23, 1983, after completion and review of the internal audit, start-up work was suspended, on the sole initiative of APS, until a satisfactory work control program could be developed and implemented.
(See Attachment A,
- p. 8).
On January 5, 1984, shortly after com-pletion and review of the independent audit, the management structure for Palo Verde was reorganized.
(See Attach-ment A, p.10).
M "APS senior management" means thosa: officers of APS who are also members of its Board of Directors, currently the Chairman of the Board of Direct. ors and Chief Executive Of-ficer, the President and Chief Operating Officer, the Execu-tive Vice President, Arizona Nuclear Power Project, and the Executive Vice President, Finance.
4 ATTACHMENT E Page 8 All of these actions, as well as others cited in Attachment A, demonstrate not only timeliness, but of equal importance, the dedication of APS management to com-plete Palo Verde in a manner which will prevent recurrence of the problems which have been identified.
2.3.2 With respect to improvements in the Startup program, APS has instituted a structural reorganization which (i) unifies under -one officer the responsi-bility and authority for engineering, construction,
- startup, operation and maintenance of PVNGS, (ii) establishes improved means for controlling the in-terfaces between separate organizations within APS.and between such organizations and outside organizations such as Bechtel and Combustion Engineering, and (iii) clearly defines and limits the role and responsibility of the PVNGS Startup or-ganization to Prerequisite and Phase I Preoperational Testing and relieves it of responsibility for functions for which it has neither authority nor re-sources (e.g.,
engineering, construc-tion, procurement, maintenance).
(See Attachment A, p. 10).
2.3.3 Both APS and Bechtel have instituted reviews and reinspection programs which reach far beyond the limited scope of the subsystems and areas inspected by the CAT.
(See Attachment A, pp. 6-8, 13-14, 17-25).
2.3.4 Renewed efforts have been instituted for training and indoctrination of project personnel to the high standards of safety and quality established for PVNGS with meticulous attention to detail.
(See Attachment A,
pp. 4, 12, 19-20, 23).
2.4 The enforcement history at PVNGS is demonstrably excellent.
There has been no failure to implement previous corrective action committed to because of prior similar problems.
ATTACHMENT E Pegn 9 2.5 There is no evidence that APS management had prior notice of the specific non-conforming conditions cited as examples in Section I,A. of the Notice as a result of a licensee audit or a specific NRC or industry notification.
There is evioence of APS management's awareness of problems in the PVNGS Startup program and of its efforts to evaluate and resolve them; and some remedial steps had been taken prior to the end of the CAT Inspection.
(See Attachment A, pp. 2-3).
2.6 The factor of multiple occurrences referred to in Section IV.B. of 10 CFR Part 2, Appendix C is not applicable to Section I. A. of the Notice, because each of the examples cited is distinguis'hable from the others.
2.6.1 The first example (capped containment pressure sensing lines) is an undocu-mented condition in an instrumentation system that existed during Preopera-tional Testing.
The condition would have been nonconforming during opera-tion.
It was not the result of an un-authorized work activity; on the con-trary, it was a prudent action which was consistent with established practice implemented during construction and Preoperational Testing.
The only missing element was the lack of documentation which was not required.
2.6.2 The second example (the disassembled and improperly reassembled remote actuator on valve SI 470) resulted from an unau-thorized work activity during Preopera-tional Testing in violation of estab-lished work procedures.
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t ATTACHMENT E Page 10 2.6.3 The third example (valve SI V402 with a position indicator that prevented full open valve operation) was a condition existing in a piping system during Pre-operational Testing.
2.6.4 The fourth example (bolting of MCC's) was a condition in the electrical system which resulted from a construction ac-tivity.
This construction activity did not violate any drawing or specifica-tion.
The condition was not nonconform-ing because it did not affect the struc-tural integrity of the component in-volved.
3.
Finally, APS requests assignment of the severity level of the deficiencies noted in Section I.A. be reduced to Severity Level IV or V, and the concomitant remission of the civil penalty, because at least three of the four examples cited in Section I. A. have.been analyzed to have no safety significance even if left uncorrected.
Consequently, none of these, singly or collectively, meet the criteria established for assignment of Severity Level III by Appendix C to 10 Ch. Part 2.
With respect to the first example cited in Section I.A.,
it can only be treated as significant to safety if it is assumed that future inspections and future implementation of Regulatory Requirements will be in-effective in detecting and correcting the capped con-ditions of the containment pressure sensing line.
It is improper to assign safety significance to the capped condition solely on the basis of such assumption.
It is equally improper to assign Severity Level III to the
ATTACHMENT E Page 11 lack of docunentation covering the capred condition and to assess a civil penalty for the absence of such docu-mentation.
Further, collectively, the four examples do not fall within the category of " multiple occurrences" as defined in paragraph C., Supplement II of Appendix C, 10 CFR Part 2 as set forth in Section 1.3 of this Attachment, pages 3, 4.
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ATTACHMENT F ALLEGED IMPROPER COMPLET.10N OF ONE OR MORE ELECTRICAL TERMINATION CARDS t
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ATTACHMENT F Page 1 ALLEGED IMPROPER COMPLETION OF ONE OR MORE ELECTRICAL TERMINATION CARDS Section I.B.
of the Notice of Violation alleges that a. violation of Criteria V and XVII of Appendix B to 10 CFR Part 50 resulted from the improper completion of one electrical termination card and possibly 50 to 100 addi-tional cards.
The alleged improprieties in the completion of such card (or cards) were (i) the signature of an elec-trician indicating that he had made the electrical termina-tion described on the card when, in fact, he had not done so, and (ii) the identification of a crimping tool by serial number as having been used to make the termination crimp when, in fact, a different crimping tool had actually been used.
This matter was not the subject of the CAT Inspec-tion, but arose from an allegation made by an individucl who then was or previously had been employed at Palo Verde.
The the allegation, which was made to two Region V investigators and one Region V inspector on June 2, 1982, and some of the results and conclusions of the ensuing investigation are in-cluded in the Report of the Special NRC Inspection issued l
April 22, 1983.
Such report coverc the period of the special in-l spection and investigations of several allegations conducted
ATTACHMENT F Page 2 from June 1, 1982, through March 11, 1983.
The report, while disclosing the allegation respecting termination cards, did not disclose the name of the alleger nor the names of employees interviewed in the course of the special inspection.M No further disclosures of the special in-spection and investigations have been made to APS.
We have been informed that the NRC Office of Investigation has also made a report of its investigation, and has referred the matter to the Department of Justice for review.
The Re-gional Administrator was unable to discuss the report of the Office of Investigation at the Enforcement Conference, because it was under review by the U.S.
Department of Justice.
Following receipt of the April 22, 1983, Inspec-tion Report, APS conducted a limited review of the matter.
l This review of the matter was limited, because, on advice of counsel, it was deemed that any attempt to contact and in-terview employees who might be the subject of the investiga-tion could be construed as interference in a federal inves-1 tigation.
On the basis of the limited review (principally a l
review of the April 22, 1983, Inspection Report and a record l
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The alleger disclosed his identity at a news conference in Phoenix on July 14, 1983.
The report referred to some of the employees interviewed as:
"A",
"B",
"C",
"D",
"E",
"F",
"G",
"H" and "J".
1 1
l
ATTACHMENT F Page 3 c
check), it appears to the best of APS' information and be-lief that the matter arose as a result of the'need to re-place certain electrical termination cards which had been lost and the absence of any procedure governing the replace-ment of such lost cards. This deficiency in procedures was corrected by revision of Work Plan Procedure / Quality Control Inspection Instruction (WPP/QCI) 255.0 on July 12, 1982.
The follcwing explanation of this procedure will assist in the understanding of this problem.
i WPP/QCI 255.0 requires the craftsman performing a termination to complete the front side of a termination card where the termination is identified by (i) recording the date when the termination is made and the serial number of the crimping tool used and (ii) signing the card.
The date, serial number and the craftsman's signature is not required and is not used to establish the quality of any termination.
l Indeed, under Appendix B to 10 CFR Part 50 quality control inspections of any work may not be conducted by any persons performing or responsible for the work.
Thus, the signature l
of the craftsman and the crimping tool serial number are not and cannot be used or relied upon under NRC regulations to establish the acceptability of a termination.
The acceptability of a termination is determined and verified by visual inspections performed first by a Termination Engineer and subsequently and independently by a Quality Control Engineer.
Each of these individuals is e
ATTACHMENT F j
Page 4 required by WPP/QCI 255.0 to inspect each termination, and, if the termination ir found to be acceptable, to record such fact by initialing, signing, and/or stamping appropriate spaces on the back of the termination card.
These inspec-tions are conducted in accordance with specifications set forth in 13-EM-306, and the acceptance criteria used are those established by Amp Special Industries for ring tongue terminals which are acceptable for use in nuclear power plants.
The crimp tool serial number and date recorded on the front of termination cards provides a means for identi-fying specific crimps accomplished during certain time pe-riods.
By utilizing this number and dates a total listing of all terminations made by a specific tool during a given time period may be obtained from the computerized data base developed from the information on the front of the termina-tion cards.
The capability to obtain such a listing is not required or usefal for quality control purposes.
It can be useful, however, if or when a crimping tool is found to be out of calibration, to identify the terminations made by that tool in the period between calibrations which will have to be reinspected.
The termination identified in the Notice of Viola-tion, has been inspected and wa.'
found to be acceptable.
The quality control inspection was documented in accordance with WPP/QCI 255.0.
To the best of our knowledge, there has
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ATTACHMENT F Page 5 been no substantiated allegation that either a Termination Engineer or a Quality Control Engineer has improperly stamped, initialed or signed any termination card.
(See April 22,
- 1983, Inspection Report.)
- Further, as the April 22, 1983, Inspection Report shows, each of the ter-minations for which a replacement card was prepared was in-spected by a Quality Control Engineer after the craftsman had signed the replacement card.
It is apparent from the April 22, 1983, Inspection Report that there was no intent on the part of any craftsman or his foreman or other supervisor to violate any NRC reg-ulation since his signature and crimp tool serial number are t
not required by any such regulation.
Nor could there be any intent to violate the required quality control inspection, I
i because he did not and could not perform that function.
The i
most adverse effect that could have flowed from an improper l
signature and the improper recording of a crimp tool serial l
number would be the need to recheck an excessive number of 3
terminations if there was evidence that during the period I
when the termination was actually performed, crimping tools l
which were out of calibration were in use.
Investigation of the calibration records for crimping tools used at Palo Verde has not revealed any case where any crimping tool was out of calibration by a margin wide enough to affect the acceptability of crimps made with the tool.
In fact, tests conducted to determine the effec-l l
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I
r ATTACHMENT F Page 6
^'
tiveness of the crimping tools has shown that none of the total of 27 crimping tools which have been rejected for project use were damaged or out of calibration severely enoagh to produce an unsatisfactory termination.
Accordingly, in the absence of any information to the contrary as may be contained in the report of the Office of Investigation (which has not been disclosed), APS is of the opinion and belief that there is no evidence that any termination card was improperly completed by any craftsman, either on his own initiative or as a result of any direction of his foreman or other supervisor, with the intent to vio-late, defect or circumvent any Regulatory Requirement.
APS has also found no evidence, nor has any evi-dence been made available, to indicate that any inspection record completed by a quality control inspection was not completed in accordance with Regulatory Requirements.
Addi-tionally, APS has found no evidence, nor has any evidence been made available, that there are any terninations at PVNGS which are defective as a result of the alleged viola-l l
tion in Section I.B. of the Notice.
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