ML20084P584

Responds to NRC Re Notices of Violation & Deviation in IE Insp Repts.Corrective Actions:Qc Certification Program Training Accomplished & Documented in Each QC Engineer Training Record

ML20084P584
Person / Time
Site:	Palo Verde
Issue date:	05/10/1984
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
ANPP-29457-TDS, NUDOCS 8405180271
Download: ML20084P584 (12)

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Arizona Public Service Company May 9,-1984 ANPP-29457-TDS/TRB U. S. Nuclear Regulatory Commission

. Region V Creekside Oaks Office Park 1450 Maria Lane - Suite 210 Walnut Creek, CA 94596-5368 Attention: Mr. John B. Martin Regional Administrator

Subject:

Notice of Violation File: 84-019-026; D.4.33.2

Reference:

NRC's Letter to E. F. Van Brunt, Jr., dated April 10, 1984

Dear Sir:

This letter refers to the inspection conducted by Messrs. P. P. Narbut, J.'Burdoin, and D. Hollenbach between February 27, 1984 through March 9, 1984. Our response to the Notice of Violation and to the Notice of Deviation of the referenced letter is enclosed in Attachment A and Attachment B, respectively.

Very truly yours, CLL(

flLLl E. E. Van Brunt, Jr.

APS Vice President, Nuclear ANPP Project Director EEVB/TRB:ru Attachment TEM cc:

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ATTACHMENT A

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' NOTICE OF VIOLATION

~ Arizona Public. Service CompanyL Docket Nos. 50-528. 50-529, 50-530 Palo Verde Nuclear' Generating Station Construction Permit Nos.

CPPR-141, 142, 143

.f As a ' result of the inspection conducted between February 27 through

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' March' 9,1984, and in accordance with the NRC Enforcement Policy,10 CFR 2, i

e Appendix C,'the following violations were identified:

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.10' CFR 50 ' Appendix B Crite'rion V, as addressed in Section 17 of the PSAR,

-states, in part:

" Activities'affecting quality shall be prescribed by

documented' instructions,. procedures, for drawings of a type appropriate to the 1 circumstances and shall be-accomplished'in accordance.with these instructions, procedures, or-drawings

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' Procedure-QCI 2.4, Revision 3 " Quality Control Inspection' Instructions" l paragraph 5.1' states, in pa't, that "QC personnel utilized in the r

performance of inspection shall require certification prior to this

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assignment".

Procedure.QCI,8.0, Revision 9_" Qualification certification and Training.

of _ Quality Control Personnel" paragraph 5.2.3 shows that QC certification in'~the Mechanical / Piping Discipline is required for work on rotating equipment.and pres'ure vessels.

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' Contrary.co the above a.QC inspector who was not certified in the Mechanical / Piping' Discipline performed inspection verifications on

-rotating equipment 1 including the' Reactor Drain Pump, IM CHN P04B on

.May 2,.1983,.the Reator Drain Pump IM CHN P04A on April 10, 1983 the HPSI Pump:1M SIB P02 on March 3, _1983 the Reactor Coolant Pump 1M RCE POIC

'(RCP2A) on! April 29, 1983, the Auxiliary Feedwater. Pump IM-AF-A-P01 on e

March 3, _1983 'and the Spray Chemical Addition Pump 1M SIA P05 on 1 April 11, 1983. He~also~ performed acceptance inspection on the pressure vessel component, the Reactor Vessel Instrument Flange As'sembly 2M RC

.EX-03 on August :25, 1983.

This is a Severity IV. Violation, Supplement II applicable to Units 1 and 12.

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Attachment [A (Continued)

Page : Two RESPONSE TO NOTICE OF VIOLATION T

Corrective ~' Steps Taken And Results Achieved I

The. root problem was identified as being related to Quality Control Engineers, j'

within the welding. discipline,- being directed by the Project Quality Control Engineer: to perform mechanical inspections during their off-shift work when

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mechanical inspectors were not available.

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The-QC documentation has been reviewed,-and 11 instances have been documented where the inspector, as identified in the Notice of Viciation, had made acceptance inspections on items -for which he was 'not certified.

NCR MC-2101 was issued identifying eight (8) instances where the uncertified Linspections occurred.. In two (2) cases, the uncertified inspections had been l

. voided-due to sabsequent work and inspections were made by-a certified QCE.

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~The six (6) remaining instances have been-dispositioned by Project Engineering a s "re work".

-NCR' NC-1345 identifies one. (1) instance where uncertified inspections occurred. -(This' NCR has ' not yet been dispositioned by Project Engineering).

During-the investigation of the named inspector's work one (1) more instance was-discovered involving three (3)-QCE's, working off-shifts, performing

'nechajical inspections for which they were not certified.

L LNCR NA-1276'has been issued identifying,the inspecticns to Project Engineering.- : This.NCR has been~ dispositioned "use-as-is" based on the

-: subsequent dissassembly, reassemblys.and reinspection by a certified inspector (documentation is on file).

c-All. Discipline QCE's are :being interviewed by. the PQCE to l determine:

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Their knowledge of what certifications they hold.

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.If, gin the past, they have made' inspections in areas they.were not-t certified.

~ Results of the interviews to 'date show no other inspections have been

~ performed.by uncertified QCE's.1

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Records of the interviews are being maintained in the PQCE's office.

The~ above-actions'show the'~ root problem in-every case to have involved.the Welding Quality Control Discipline. ' Consequently, the following further-Jaction willebe taken:

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Attachment A (Continued)

Page Three 9

WQCE's no longer employed at the Palo Verde jobsite have been identified to the PQCE. The PQCE is currently reviewing mechanical documentation to determine. if-any of these WQCE's working on the of f-shif t, performed any uncertified inspections.

Corrective Steps Which Have Been Taken To Avoid Further Noncompliance Quality Control Directive #2 was issued from the Project Quality Control Engineer's office on February 29, 1984. This directive prohibits an inspector from performing inspections in disciplines for which he is not qualified.

It provided instructions to the Quality Control Engineers on the requirements of

-the Quality Control Certification Program. This directive also instructed all Lead Quality Control Engineers to provide training to their Quality Control Engineers on'this subject. This training has been accomplished and is documented in each Quality Control Engineer's training record.

Date When Fu11' Compliance Will Be Achieved Full. compliance to the Construction Quality Control Program for certification was reaffirmed with the issuance of Quality Control Directive #2 (Rev. 1) on February 29, 1984,.and subsequent training to all QC Engineers. The remaining interviews of Discipline QCE's and the review of mechanical documentation will be completed by June 19, 1984.

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Attachment'A-(Continued)-

.Page Four

B.s Waldinger Procedure FQCP-10,2,3,1, Revision 8 " Inspection Fabrication and Installation of Quality Class Q HVAC Support", requires, in Para-

' graph 6, a fabrication and installation inspection of HVAC Supports in which QC-verifies proper welding and bolting.

IBechtel Drawing 13-C-00C-003, Revision 9. "HVAC Support Details",

requires, in Note 12, that shim plates may be used, not to exceed two inches (2") in thickness.

, o Contrary to the above, the following HVAC Supports were verified to be satisfactory by QC with the. improper conditions as.specified. Support TWC-301-24-185 had apparent lack of fusion in a weld and was accepted on.May 26, 1982. Support TWC-301-35T-221, accepted on July 18, 1980 had. improper bolting of Mark 28 and 32 in that a one-half inch (h")

gap existed between the~ bolted members and should have had a shim

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.. plate installed.

Support TWC-301-35T-220, accepted on July 11 and 18, "1980 for welding and bolting, respectively, had a. fillet weld (Mark 41;

to 23land 24) which had no size specified on the Drawing and, there-fore, could not be properly verified as the' correct size. The support Ealso'had a shim pack between Mark _35 and 29 which measured two' and one-quarter Linches -(2k"). -exceeding the two-inch (2") maximum. Support TWC-302-35-258, accepted on May 2, 1980 and January 14, 1981, had severely misaligned bolts resulting'in a three-sixteenths inch (3/16")

. maximum gap between the bolt head and; member.-

LThis.is a Severity Level IV Violation, Supplement II, applicable to Unit #2.

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-RESPONSE TO NOTICE OF VIOLATION Corrective Steps.Which Have Been Taken and Results Achieved E.The four (4)' specific supports identified-by the NRC Inspector have been l documented as-follows:

Support No.

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Action s301-24-185-The lack of fusion problem has been

.; 7 identified on Waldinger NCR 810F.

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301-35T-221 -

The situation identified is in conformance with Bechtel Drawing 13-C-00C-032. which permits a gap,'not'to exceed one inch (l"),

on longitudinal bracing._ No further action

. will beltaken.

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j Attachment A (Continued).

Page Five

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Support >No.

Action 301-35T-220 The shim pack has been identified on Waldinger NCR 795F. The weld reported as having no size specified on the Drawing is specified on Drawing 13-C-00C-011, Detail 5.

The hanger drawing

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references this drawing. The detail specifies a five-sixteenths inch ~(5/16")

fillet for the weld. The actual weld size is three-sixteenths inch (3/16").

Waldinger has issued NRC 811F documenting this condition.

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302-35-258 Bechtel Quality Control has identified the misaligned bolting to Waldinger on the Surveillance Inspection Report.

Potential deficiencies in other HVAC installations which have been previously inspected and accepted are being identified, evaluated and resolved as follows:

A.

A sample reinspection and evaluation of results-is being performed in-the area of welding.

B.

The seismic adequacy of supports is being determined by an engineering walkdown and' evaluation.

C.

Areas of shim inconsistencies are being evaluated by Engineering to determine the acceptance criteria and rework to be performed as appropriate.

Each of these activities is described below:

The project was aware that several possible problems exist in the as-built HVAC supports as a result of a previous investigation by Waldinger.

(Refer-ence Bechtel Document No. 13-10407-M598-205B-1, dated February 1, 1984.

This condition was caused by either the misinterpretation and/or nonconformance of existing Bechtel-established criteria by Waldinger or a lack of specific Engineering criteria by Bechtel. Consequently, a Deficiency Evaluation Report (DER) No. 84-13 was initiated on February 28, 1984 and notification to the

'NRC made by APS.

This DER resulted in Bechtel evaluating the problems and generating additional acceptance criteria as required. This acceptance criteria is part of the five (5) Design Change Packages (DCP's (ISM, 2SM, 3CM) - HA-030, HD-009 HF-014, HC-040, HJ-035) which have been issued for the on-going project validation walkdown of the HVAC supports.

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All nonconforming installations identified during these walkdowns will be documented ~and analyzed on a case-by-case' basis. In the event that any I

installation is not-acceptable by calculation or analysis, the installation shall be reworked or modified to an acceptable condition.

To' determine and evaluate the extent of the nonconforming condition in the i

area _of welding, the subcontractor will perform a reinspection of twenty t

percent-(20%):of-the Unit #1 safety-related hangers selected at random.

Prior to the reinspection..the QC Inspectors will receive retraining. The l

l' inspection will be performed to AWS D-1.1-77,as supplemented by Attach-j ment DU of Specification _13-MH-598.

All deficiencies will be documented i

on nonconformance reports. In addition,' Bechtel QC will perform an inspec-tion of ten percent (10%) of the Waldinger samples to verify adequacy of

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inspection. Engineering will evaluate the results of this reinspection activity and determine the need for additional inspection and required corrective action.

In several' areas -the acceptance criteria is being reviewed and evaluated j

as follows:-

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. Two (2) additional NCR's (796F and 797F) have been written by

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the Waldinger Company.to identify instances where shimming has been used in gaps-in excess of two inches (2").

The Waldinger I

Company-has issued a Subcontract Change Request (SCCR No. FW-562) requesting Bechtel Engineering clarification of the acceptance-criteria. The need for further inspection will Ix: evaluated, based upon the Engineering resolution of the SCCR.

' Waldinger has requested Bechtel Engineering,'on SCCR No. FW-564, to provide a clarification of acceptance criteria for-misaligned

~ bolting situations. This will be the basis for Waldinger dis-position of Bechtel QC's Surveillance Inspection Report on Support 302-35-258. The need for reinspection and additional corrective action will be decided, based upon the Engineering criteria.

' Corrective Steps Taken To Avoid Further' Noncompliance

.The Waldinger Company.has purchased additional inspection aids, has provided orientation and indoctrination to welders, foremen and engineers and is presently indoctrinating inspectors as part of an on-going training program.

.These training sessions include all aspects of quality and attention to

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' details of the design requirements._ Training records are on file in Waldinger's QC office.

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Page Seven.

The= current Bechtel'QC Program requires surveillance inspections to verify Waldinger.. compliance to-their Quality Program. To ensure adequacy of sub-

- contracto'rfinspections, this Program will be upgraded by revisions to the

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WPP/QCI No. 153.0 to require the assigned Quality Control Engineer to sur-

- veil the subcontractor daily when safety-related work is in process.

0bservation of those daily surveillances will be documented weekly on a

- surveillance report... Included in the surveillance, will be verification-of= hardware installation in accordance with the same. acceptance criteria used by the subcontractor.

Additionally, the Final Report for DER 84-13 will provide any other corrective actions necessary.to preclude recurrence based on deficiencies identified on the walkdowns.

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-Date When Full Compliance Will Be Achieved Engineering willLclarify the additional acceptance criteria by June 1, 1984.

. Any. reinspection and rework required by this clarification, as well as the welding. reinspection and rework, will be completed by September 19, 1984.

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The Final Report for DER 84-13 will identify all corrective action covering Units #1, #2 and #3 and will be issued by December 14, 1984. However, all j

Unit #1 items will be reselved by September'19, 1984.

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ATTACHMENT B NOTICE OF DEVIATION Arizona Public Service Company Docket Nos. 50-528, 50-529, 50-530 Palo Verde Nuclear Generating Station Construction Permit No. CPPR-141, 142, 143 As a result of the Inspection conducted on February 27-March 9, 1984 and in accordance with the NRC Enforcement Policy 10CFR2, Appendix C, the following Deviation was identified.

FSAR, Section 1.8, states that' Regulatory Guide 1.52 applies to the Control Building and Fuel Building essential ventilation systems.

Regulatory Guide 1.52, Paragraph 2e, states, in part, that the effects of radiation should be considersd for any-joining compounds-that, arc necessary for operation during a postulated DBA.

Contrary to this commitment, no-documentary evidence was available to demonstrate that the duct sealant, Scotch-Seal Product 1168. used as a gasketing material for instrumentation connections to duct was suitable for environmental' conditions. The sealant is:used in Control Building, Fuel Handling Building, Auxiliary Building and the Containment environments.

RESPONSE TO NOTICE OF DEVIATION Corrective Steps-Taken and Results Achieved The Waldinger Corporation is conducting a review of overall usage of sealant in duct systems.

In the specific case cited by the Deviation, The Waldinger Corporation is taking the following action:

1.

Identification of where sealant has been used.

2.

Verification that the sealant used was Scotch Seal 1168.

3.

Obtaining environmental qualification of Scotch Seal 1168.

To date, The Waldinger Corporation has identified eleven (11) instances where sealant has been used in~ unauthorized application. These installations have occurred in the Unit #2 and #3 Control Buildings. These instances have been documented by'TWC Nonconformance Reports. Additionally, The Waldinger Corporation will verify the type of sealant utilized in each unauthorized application.

Scotch Seal 1168 will be submitted to an approved, independent engineering test laboratory for environmental qualification in accordance with Specifi-cation 13-MM-598.

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Page Two i

L Corrective Steps Which Will Be Taken To Avoid Further Noncompliances

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.The need for additional inspections,.and administrative or in-process controls, to control the use of sealant by the subcontractor, The Waldinger Corporation, will be determined based on the results of the action speci-

.fied above.

The Waldinger. Corporation will conduct training sessions with foremen, engineers and quality control inspectors. This training will include all aspects of quality and attention to detail of the design requirements, l

including the use of sealant.

Date When Full Compliance Will Be Achieved Compliance will be achieved by August 1, 1984..

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STATE OF ARIZONA )

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COUNTY OF MARICOPA)

I, Edwin=E. Van Brunt, Jr., represent that I am Vice President, Nuclear Projects of Arizona Public' Service Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company uith 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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Edwin E. Van Brunt, Jr.

I Sworn to before me this 9/4 day of h jj 1984.

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~ptaryPublic^

My Commission Expires:

My Commission Empires April 8.1987 I

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