ML20090H020
| ML20090H020 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/13/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| REF-PT21-84-375-000 ANPP-29955-TDS, DER-80-21, DER-84-07, DER-84-7, PT21-84-375, PT21-84-375-000, NUDOCS 8407260054 | |
| Download: ML20090H020 (5) | |
Text
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RECEIVED
~ NRC Anzona Public Service Company Bin Jt!!. I6 PN 2: I7
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July 13,1984 ggggy,gg ANPP-29955-TDShRB U.
S.' Nuclear. Regulatory Commission Region V.
Creekside Oaka Office Park 1450 Maria Lane - Suite 210 Walnut Creek, CA 94596-5368 Attention: Mr. T. W.' Bishop, Director
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Division of Resident Reactor Projects. and Engineering Programs
Subject:
Final Report - DER 84-07 A 50.55(e) Reportable Condition Relating To Failure To Provide Corrective Action As Stated In DER 80-21.
~ File: 84-019-026; D.4.33.2
Reference:
A) Telephone Conversat: ion between P. Narbut.and T. Bradish on February 9, 1984
- B)- ANFP-28996, dated March '2,1984- (Interim Report) -
C) ANPP-29283, dated April 12, 1904 (Time Extension)
.D) ANPP-29607',. dated May 29,.1984 (Time Extension)
Dear Sir:
Attached is our final written report.of the Reportable Deficiency under 10CFR50.55(e), referenced above.
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Very truly y urs,.
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- h. k A CW E. E. Van Brunt, Jr.-
APS Vice President Nuclear Production
. ANPP Project Director-EEVB/TRB:db Attachment-cc See Page Two B407260054 8407:3 PDR ADOCK 05000528..
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Mr. T. W. Bishop-LDL 84-07 Page Two ec:
Richard DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 T. G. Woods, Jr.
D. B. Karner W. E. Ide D. B. Fasnacht A. C. Rogers L. A. Souza D. E. Fowler T. D. Shriver C. N. Russo J. Vorees J. R. Bynum J..M. Allen J. A. Brand A. C. Gehr W. J. Stubblefield W. G. Bingham R. L. Patterson R.' W. Welcher H. D. Foster D. R. Hawkinson L. E. Vorderbrueggen R. P. Zimmerman S. R. Frost
' J. Self D. Canady T. J.. Bloom
- Recorda Center Institute of Nuclear Power Operations 1100. Circle 75 Parkway, Suite 1500 Atlanta, GA 30339 f
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FINAL REPORT - DER 84-07
- DEFICIENCY EVALUATION 50.55. (e)
ARIZONA PUBLIC SERVICE COMPANY (APS) l PVNGS UNITS 1, 2 & 3 I.
Description of Deficiency This report was initiated to document the failure to complete corrective action as contained in DER 80-21, described in _Part A helow. This failure was a result of an inadequate tracking program l
- for DER commitments. As a result of this condition, a 100%
I investigation of all corrective action commitments was completed for all'DERs issued by the PVNGS. ;This investigation revealed one other condition of incomplete implementation of corrective action. This condition is described in Part B.
Part A The corrective = action for DER 80-21 called for modification -of certain Borg-Warner valves in Units 1, 2 and 3 by means of Bechtel NCR PX-1412. The deficiency of DER.80-21 was previously evaluated i
as' reportableLunder 10CFR50.55(e) and Part 21.
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l The valves in Unit 1 were modified on August 29, 1980 as documented by the disposition of NCR PX-1412/QCE Stamp 115.
Subsequently, Borg-Warner directed -further modification of these.
- same valves, and NCR NA-372 was-issued to accommodate. this additional rework. The following sequence of events occurred:.
On June. 15,'1981,- all of the valves in Unit 1 were reworked.
per NCR NA-372/QCE Stamp 115.
On June 15, 1981, some of the valves in Units 2 and 3 were -
modified for the first time per'NCR PX-1412/QCE Stamp 115.-
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On October 21, 1981, NCR MA-372 (for the additional rework)~
-was revised to state that it. superseded. NCR PX-1412 (for the
-original modification). This deleted "the original -
modification'for those valves in Units 2 and-3 which wereinot modified on June 15,-1981.
Since block 15 of : DER.80-21 had been closed by the. issuance of NCR PX-1412, the latter oversight eradicated all documented '
- requirements for the original modificaticus to the following valves; in Units 2'and:3:
2JSIBUV665:
3JSIBUV668-
'2JSIBU?668-3JSIBUV636
~2JSIAUV669.
23JSIAUV637 2JCHEHV255 3JSIBUV646-T
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ib' Mr.'TJ W. Bishop
' ' ANPP-29955 Page.Two LAs a renuit of the.100% review of all corrective. action commitmenta contained in DERs this condition has been determined to'he an inolated error by personnel implementating the NCR system. Mont NCR's ' address'a aingle Unit, and the individuals responsible for superneding NCR PX-1412 failed to note that it applied to three Unita.. There. existed no' check to preclude this from happening.
This deficiency.was diacovered during QA reverification of DERn _per
- Quality Annurance. Department Procedure 7.11.
Part B DER 83-43 documented a deficiency associated with twelve (12)
Auxiliary Relay Cabineta (ARCS) manufactured by the liarlo
' Corpora tion. These ARCn were all in Unit 1.
The deficiency of DER 83-43 was-previously evaluated an reportable under 10CFR50.55(e) and Part 21.
Revision 0 of the Final Report (dated 23AU83) called for the followings.
(a) An inspection of all Class 1E and Non-1E ARCn in Units 1, 2, and 3.
(b) The rework of deficiencien in twelve (12) ARCa in Unit.1
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(c) "Th'e innuance of future NCRs (which would cross-reference DER 83-43) to correct ~any subsequent deficiencies found.
Revision 1 (dated 270c83) revined the corrective action to:
(a) Document the issuance of NCRs'SE-3148 and EA-3548 for the
- anme' (12) ARCn in Unita 2 and 3.
(b) Delete the provision to innue future NCRs as required.
Since additional NCRn;were required to correct ARCS in addition to the original.12 and the DER had heen cloned,.
1 "APS Corrective - Action Report S-44-006-N was innued 'to.
< document this conflict.
levision 2 (dated (17FE84): revised-the corrective action to
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reinstate the provision to. issue future' NCRa t to correct.
additional discovery.
9 The -corrective action 'of Revision.0'wan not sufficiently, defined in
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' that no document was issued = to require - the. inspection. of ;all Class IE and Non-1E^ ARCS in Unita :1,12, and 3,: and a mialeading 'atatement.
was made in Revision l' when the provision to; issue -future NCRs was.
" deleted.
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.Mr. T. W. Bishop ANPP-29955 Page ' Three II.
Analysis of' Safety Implications DER 80-21 and DER 83-43 have previously been evaluat-d as reportable in the respective Final r ports as submitted -to the NRC..
e The fail lre to properly complete corrective action. committed to in the Deficiency Evaluation Reports is evaluated as reportalle under-10CFR50.55(e).
III. Corrective - Action 1.
NCRs NA-1251'and NA-1252 for Units 3 and 2 respectively have been-initiated to reinstate the rework requirement specified in DER 80-21.
Bechtel has dispositioned the NCRs to inspect the remaining valves to determine if the modificatious were performed. Those ialves that have not received-the required modifications will be modified as required by these NCRs.
2.
The Project Quality Program Manual (PQPM) Section 16.0, Corrective Action, was revised on January 31, 1984 to provide a corrective action reverification program.
This program provides and assures the follow-up and completion verification of corrective action as committed by DERs and/or corrective action reports.
3.
Bechtel Quality Assurance has reviewed the corrective action
. commitments of all prev' asly issued DER's and has implemented a' tracking. system to et.sure completion of allL commitments.
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Action to preclude recurrence includes a review of'.this DER by the renponsible individuals in Engineering and Quality
- Assurance.
5.
- CAR S-84-006-N has been completed.
f-6.
Should any additional corrective action conditions similar to-this report he identified,'they stall be identified by
. issuance -of a Corrective Action Report.
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