ML20082D976
| ML20082D976 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/30/1988 |
| From: | ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | |
| Shared Package | |
| ML20081E364 | List: |
| References | |
| FOIA-90-570 NUDOCS 9107300219 | |
| Download: ML20082D976 (17) | |
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U EE580 Field Verification Supplement to Final Report "l
T Reference NRC Allegation RV-87-A-047 C
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1 Palo Verde Nuclear Generating Station lC October 1988
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J Bechtel Power Corporation,10040 North 43rd Avenue Suite 1-1, Glendale, Az 5304 (602) 842-8500 FAX (602) 842-8526 i
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REPORT OF EE580 VERIFICA110!i i
SUPPLEMENT TO FINAL REPORT REFERENCE !<n. ALLEGATION RV-87-A-%7 JOB ORDER 172 l
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TABLE OF C0!; TENTS 4
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SUMMARY
i II PURP0SE..................................................
E III METHODOLOGY..............................................
IV FINDINGS........................
Y CONCLUSION...............................................
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SECTION I E
SUMMARY
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___r EE580 FIELD VERIFICATION SUPPLEMENT TO FINAL REPORT DATED MAY 1988 REFERENCE NRC ALLEGATIONS RV-37-A-047 I.
SUMMARY
Phase I of the EE580 verifi. cation program resulted in a report of the findings and an open item list which required further evaluation to minimize field walkdowns.
Prlor to starting Phase II evaluation of the open item list, the files were restructured and thoroughly reviewed which resulted in an active file of 12,332 compor,ents. Out of 12.332 components, 4 g 2ards were identified as not in the vault (no card was found in the vault or microfilm).
Therefore these cards could not be reviewed against existing documentation circe there was no evidence as to the as-built condition at the ti=e the last card was signed-off which failed to be received by the vault. Since a review could not be accomplished these cards were identified on a separate listing for ANPP evaluation.
The remaining I
8,093 cards was the basis for the Phase II review of the EE580 data base against the latest configuration documentation.
Out of B,093 cards, 5,136 cards from the *C and class 1E data base were considered related to the NRC allegation.
The remainin3_2,957 ca.rd_s 1
l were related to design revisions between the latest card in the l
l vault and the EE580 data base.
The following provides a summary l
breakdown of the components reviewed.
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5,136 of the cards were re]ated to the NBC allegations.
Based i
j cn the results of the review, 4,668 cards were determined to be in agreement with the EE580 data Lacs.
The remaining 468 cards were identified aa requiring further engineering evaluation by A?S or field walkdown.
I 2.
2,957 cards were reviewed due to the difference in design revision between the card and the EE580 data base.
Of these i
cards, 1,480,were deter =ined to be in agreement with the EE580 data base. The remaining 1,477 cards were idertified as requiring further engineering evaluation by APS ca fie'.d walkdown.
1 In summary, this field verification effort was able to successfully status 6,148 of the 8,09 cards h y al of 1,945 cards were vw
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identified for further action, therefore h ding to4,23;yitem not found in the uult results in a total of' 6,184 components. hat require further action which are identified in the attached open 1
a item list in the form of EE580 reports.
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The 'C and DR notation for the components that were successfully i
statused has been removed from the data base currently leaving these items within configuration. EE580 cards were generated for the
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DR and Class 1E components that were determined tc be in agreement with the EE580 data base and evaluated to be papar change only.
These cards were sta= ped as PCO and transmitted to the vaults.
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"I SECTION 11 5
PURPOSE g
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1 II.
PURPOSE 1
Bechtel as recuested under Job Order No. 172 to verify the installation configuration of the EE580 Circuit and Raceway Tracking System for Units 1, 2, and 3 The task was cocpleted and a report subtitted dated May 1988.
The review conducted in the first phase was completed within the time allocated and resulted in approximately 12,500 component:; identified for further action.
It was indicated that further review of these components by means of docu=entation search could result in further reduction of the final number of component.s requiring evaluation by APS or walkdown.
This method could not be utilhed during the initial phase due to the amount of time required for the documentation search which could not have been accomplished in the time allocated to initially adcress the allegations.
Therefore, it was concluded to continue the EE580 review in Phase _II to the extunt posible to minimite the components requiring further action 1.
. walkdown the component for as-built verifica tion.
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SECTION 111 1
METHODOLOGY y.
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l III.
METHODOLOGY I
The components identified for ft.r*.her review were the results of the Phase I review of outstanding installation cards ('C), Class 1E installation cards and design revision (DR) cards.
In order to further verify the adequacy of these compor.ents the following types of docu:::ents were reviewed where applicable.
I 1.
DCP's were reviewed for verification of the co=ponent status.
Closed DCP's either hard copy or :::icrofilm were reviewed for indication of the EE580 as-built condition in the for= of copies 1
of signed-off EE580 installation cards. The card was then reviewed against the EE580 data base and if the data was in agreement, the latest revision EE580 card was generated and statused as a PCO.
1 2.
Work Orders were reviewed for copies of the EE580 installation cards. Based on the agreecent of the EE580 cards in the Work Order and the EE580 data base the latest revision EE580 card was generated and statused as a PCO.
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Vault cards were reviewed where cross-referencing was applicable. When a raceway card was shown with new links or some la ks were deleted from the EE580 Data Base, tr.e la te s t card from the vault for the adjoining / deleted link was reviewed.
i If the link was determined to be in agreement with the EE580 card and data base, the latest revision EE580 card was generated and processed as a PC0 card for the vault.
4 4.
Field change Requests (FCR) were reviewed and approved for PCO processing only if they were part of an appropriate work package that demonstrated the work accomplished was in agreement with the EE580 data base.
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lion-Conformance Reports (llCR) were reviewed when referenced against the EE580 data base ano latest card available. Wnere the change in the llCR was in agreement with the EE580 data tace lI which indicated the as-built condition, the latest revision EE580 card was generated and processed as a PCO card for the vault.
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Startup Field Reports (OFR) were reviewed wnere applicable. If no evidence was found that indicated the work was cocpleted in agreccent with the EE580 data base. the card was considered to require a walkdown to verify the as-built condition, otherwise the latest revision EZ580 card was generated and processed as a PCC card.
1 7.
Plant Change Requests (PCR) were reviewed where applicable.
On]y PCR's that were closed or were in the process of closing were given consideration.
If the PCR documented a paper change only for as-built conditions and was in 36reement with the EE580 data base, the latest revision EE580 card was generat.ed and p: > cessed as a PCO.
If tris could not be confirmed then the cocponent was considered as requiring a walkdown to verify the as-built condition.
1 8.
Engineering Evaluation Requests (EER) were reviewed when appropriate reference was identified.
The EER, however, would have to refer to an appropriate document i.e. work order, that 1
required the performance of work to incorporate the request. If it was determined the work was complete and the associated documentation confirmed agreement with EE580 data base, a card was generated and processed as a PCO card.
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9 Design Change Notices (DCN) were considered only when tney could be confir:cd to have been worked pnycically in accordance with tae appropriate work document (SFR, NC3 etc.) and also in agreement with the EE580 data base.
When this was confirmed the latest revision EE580 card was generated and was processec as a PCO for the vault, i
- 10. Startup Wori: Authorization (SWA) and Startup Work Per=1ts (SWP).
When these documents authorized physical changes to be made and were bought-off appropriately, as well as being in agreement with the EE580 data base the component was approved as a PCO.
The latest revision EE580 card was generated and processed as a PC0 for the vault.
- 11. Termin9 tion lift and reland sheets were verified only if associated with a closed work document.
If terminations were confirmed to be in agreement'with the EE580 data base the latest revision card was generated and processed as a FC0 card.
If agreement could not be verified between the above documentation and the EE580 data base, the component was considered as requiring further ANPP evaluation or walkdown to verify the as-built condition.
As a result of reviewing the above documentation, if components were verified as applicable they were statused as " Paper Change Only".
Inese cards were stamped and the associated document (SFR, NCR, Work Order etc.) was referenced in the remarks section of the card where applicable.
All PC0 cards were forwarded to Records Management Cc puter System Group (RMCS) to i
place in the vault.
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I SECTION IV FINDINGS j
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l IV.
FINDINGS As a result of this EE580 verification program, the following provides a detailed breakdown of the cards reviewed.
OUTSTAtIDING INSTALLATION CARDS ('C) o Number of items with no further action required 201 Action items requiring further action b
Items on Engineering Hold i -
Work Order Items Still Open 45 1j Evaluation /Walkdown itees y
TOTAL 407 o
CLASS 1E INSTALLATION _ CARDS Number of items with no further action required 4,467 Action items requiring Evaluation /Walkdown 262
. TOTAL 4,729
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Total items related to the NRC allegation
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DESIGN REyISION _INSTA_LLATION CARDS
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Number of items with no further action required 1,480 Action items requiring further action 9
Work Order Items Still Open 100 Items on Engineering Hold 1 g3fj}
Evaluation /Walkdown items 2,957 TOTAL Total items requiring further action Pnase II 1,945 4 239 Total items requiring. further action Phase I t
(3,686 a:/1E, 553 DR) 6,184 Total items for further action It is Bechtel's understanding that. ANPP' is to evaluate the components requiring further action to determine if items can be reduced by documentation or other information ANPP may have pertaining.to the components. The final listing will require a walkdown to determine the as-built condition relative to the - EE580 data. base. -If the-as-built condition l
1s in agreement with the EE580 data base, the latest revision EE580 card l
should be-generr t ed and placed in the vault for as-built -verification.
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f the as-built is not in agreement with the EE580 data base then appropriate action should be'taken'such as generating'the necessary documentation to determine and resolve discrepancies.
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i SECTION V CONCLUSION 1
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CONCLUSION Based on the field verification program it appears there was a prob 5em of assuring that the appropriate EE580 cards were returned to the vault upon completion cf work. However, as state $ in the-original report there appears to be a higher awareness of the criticality for maintaining the EE580 system.
Additionally, results are positive apparently u a result of the traininc implemented by-ANPP to personnel utilizing the EE580 system.
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