ML20093K773

Forwards Response to 840622 Notice of Violation from Insp on 840501-0601.Corrective Actions:Const Procedures Wpp/Qci 12.0,31.5 & 31.6 Will Be Revised & Project Team Formed to Provide Procedural Enhancements

ML20093K773
Person / Time
Site:	Palo Verde
Issue date:	07/20/1984
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
ANPP-30011-WFQ, NUDOCS 8407310192
Download: ML20093K773 (10)

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TECEIVEP Imc Arizona Public Service Company 03 J123 kl 9 42 July 20, 1984 UECIO+'l VIId ANPP-30011-WFQ/TJB U.S. Nuclear Regulatory Commission Region V-Creekside Oaks Office Park-1450 Maria Lane, Suite 210 Walnut Creek, CA- 94596-5368 Attention: Mr. T. W. Bishop Division of Reactor Safety and Projects

Subject:

Notice of Violation -

File: 84-019-026; D.4.33.2

Reference:

NRC's Letter from T. W. Bishop to E. E. Van Brunt, Jr. dated June 22, 1984 4

4 This letter refers to the inspection conducted by Meners. R. Zimmerman, G. Fiore111, and C. Bosted between May 1 - June 1, 1984. Our response to the Notices of Violation of the ~ referenced letter is encioned in Attachment A.

Very truly yours,

. W AQ l E. E. Van Brunt, Jr. I APS Vice President Nuclear Production ANPP Project Director l-EEVB/TJB:db i

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0407310192 840720

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J Mr. T. W. Bishop ANPP-30011 Page.Two cc: 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 i

A. C. Rogers L. A. Souza D. E. Fowler T. D. Shriver C. N. Russo J. Voreen

. 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. Hawkinnon W. F. Quinn S. R. Front K. W. Gross D. Canady R. P. Zimmermen L. E. Vorderbrueggen E. A. Licitra Records Center Institute of Nuclear Power Operations

1100 Circle 75 Parkway, Suite 1500 Atlanta, GA 30339 l

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, a STATE OF ARIZONA )

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COUNTY OF MARICOPA)

I, Edwin E. Van Brunt, Jr. , represent that I am Vice President,

. Nuclear Production 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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Edwin E. Van Brunt, Jr.

Sworn to before'me this J d j day of g7]s , 1984.

% d %AdbL Notary Public My Commission Expires:

MyCommissia Eghs April 8,1987 4

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ATTACHNENT A NOTICE OF VIOLATION

-2.- 10CFR50,' Appendix B, ' Criterion XV, Nonconforming Materials, Parts for -

Components, requires that controla shall be established for the identification, documentation, and disposition of nonconforming itema.

Bechtel Work Plan Procedure / Quality Control Instruction - 5.0, Nonconforming Materials, Parts or Components, Reviaion 25, dated February 3,1984 requires in paragrapha 2.2 and 9.1 that a Nonconformance Report be generated to disposition _ nonconforming items and that auch items he identified by Hold Tags, markings or other clear i means of identification.

Contrary to the above, on May 3, 1984-two conconforming mechanical

' seals, removed from the "A" High Pressure Safety Injection Pump on April 27 and 28, 1984 were not properly controlled in that Nonconformance Reports were not generated to disposition the nonconforming neals and the seals were not identified by Hold Tags, 4 markings, or other cient means of identification.

This is a Severity Level IV Violation (Supplement II).

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. .n Attachment A (Continued)

Page Two RESPONSE TO NOTICE OF VIOLATION

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I. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

On August'22, 1983, Startup NCR SM-2712 was issued describing a

. nonconforming seal on LPSI Pump. A in Unit 1. The' disposition was to

' replace the seal upon completion of the test that was in progrens. In mid April of 1984, SWA 20205 was initiated referencing the Startup NCR and it was also dispositioned to replace the seal. Subsequently, Construction disassembled the pump, removed the defective seal and replaced it with a new neal.

I Construction's procedure, WPP/QCI 31.5, limits Construction's

responsibility for preparing a conconformance report to exclude those

conditions already dencribed on a nonconformance report issued by j another organization; in this cane, Startup. Consequently, the removed '

l seal was considered to be under the jurisdiction of the Startup conconformance report. No new nonconformance report was initiated by Conntesction nor was a construction NCR Hold Tag placed on the neal.

4 The seal was set aside to await further disposition instructions from i Startup. The Startup NCR procedure does not require the tagging of a 1 nonconforming ites.

l After reanneshly of the pump with the new seal, it could not be rotated by hand. At that time Construction NCR N-A-1336 was prepared to

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document thin problem. A Construction NCR Hold Tag was prepared and

< SRayt on the pump body. The interim disposition required disassembly of b

j the pump to investigate the binding problem.

i Af ter disassembly, it was determined that the second seal was defective. The final disposition on NCR N-A-1336 was to replace the

{ second geal with a third seal and deliver the unacceptable second seal

! to Combuntion Engineering. APS supplied a third seal to he inatalled in the pump.

Bechtel Construction was in error hf not transferring the NRC Hold Tag from the pump body to the second defective seal as required by procedure WPP/QCI 5.0. On May 3, 1994, when the Resident NRC Inspector l identified the problem to Construction, NCR Hold Tags were subsequently '

i attached to both defective seals.

Clarifying the stated findings, there were conconformance reports generated to document both nonconforming neals. The first neal under the Startup NCR and the second under the Construction NCR. The situation leading to the finding by the NRC Resident Inspector was a 1ack of clearly established procedural requirements for tagging.

The construction error han been discussed with the Field Engineering and Quality Control personnel that were involved in the replacement of these sealm to be sure they clearly understand the requirements for

, tagging conconforming material.

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Attachment A (Continued)

Page Three 4

II. CORRECTIVE STEPS TAKEN TO AVOID RECURRENCE:

In order to prevent recurrence' of this type of problem in the future, the following corrective actions are being taken:

1. WPP/QCI 12.0 will be revised to include the requirement for applying the Construction Materia 1LControl Tag to remove parts or components that are identified an conconforming on a Startup or Operations NCR referenced in or attached to a SEA or CWO.

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2. WPP/QCI 31.5 for SWAs and 31.6 for CW0s will be revised to require material control. tagging for any nonconforming components removed while working to either of thone' documents (SWAa, CW0s) when those removed components are not otherwise tagged under the Bechtel work control program.

l Therefore, with the exception of consumable materials or expendables that will be discarded upon removal, other components removed during j the dinansembly of equipeent will be tagged by one of the following:

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1. A Construction-NCR Tag for those items identified on a Construction Nonconformance Report.

2. By a Material Control Tag for reuseable iteen.

3. By a Material Control Tag for those items identified'on synteen l

under either Startup or Operations jurisdiction.

The Material Control Tag applied to those iteam identified in a Startup or Operttions conconformance report will specifically note that the item in nonconforming per the specific NCR.

4 As an additional measure, the changes to procedures affecting the control of material, both from a working standpoint as well as related to housekeeping, will be summarized for presentation in a Bechtel

" Quality Talk" session prior to the end of August. The " Quality Talk"

. is planned to augment the training sessions committed to below and in notice of Violation Number 3 to achieve the widest dissemination of I information as ponsthie, i

III. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The procedure changea described above will be innued and ni.hsequently Field Engineers and QC Engineers will be trained on these new requirementa. The proceuren will be in effect and the training completed by August 31, 1984. ,

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Attachment A (Continued)

Page Four NOTICE OF VIOLATION 3.. 10CFR50, Appendix B, Criterion VIII, Identification and Control of Materials, Parts and Components, requires that measures shall be entsh11shed for the identification and control of materials, . parts and components.

Bechtel' Work Plan Procedure / Quality Control Instruction - 12.0 Storage Control of Permanent Plant Items, Revision 17, dated March 30, 1984, prescribes in paragraph 8.1 that when it is required to remove or disassemble a uniquely identified component or iten in the unit after installation, and the removed or disassembled item will be left unattended or must be stored for a period of time, a Material Control Tag shall be prepared and attached to the material.

Contrary to the above, on May 17, 1984 the following examples of failure to control safety-related components and parts were observed:

An untagged pump seal and two temperature sersing units were stored on the floor of the B Low Pressure Safety Injection Pump Room among scattered tools and debris. No maintenance waa in progress at the time.

An untagged pump wearing ring was randomly stored among uncontrolled material on the 80 foot level west corridor of the. Auxiliary Building. No maintenance was in progress at the time.

An assortment of untagged flexitallic gaskets were stored in several rooms of the Auxiliary Building. No maintenance associated with the gaskets was in progress at the time.

This is a Severity IV Level Violation (Supplement II).

i Attachment A (Continued)

Page Five RESPONSE TO NOTICE OF VIOLATION I. CORRECTIVE STEPS AND RESULTS ACHIEVED:

The requirements of the material control tagging procedure were formalized with the issuance of Revision 17, WPP/QCI 12.0, on April 5,1984. It cannot be determined that the untagged items found by the NRC Resident Inspector on May 17, 1984 had been removed from their installed locations before or af ter the issuance of the tagging program. In any case, when the procedure was issued, there was no attempt to walkdawn or inspect the units to identify any-untagged or uncontrolled material.

After the Resident Inspector's Exit Interview on May 31, 1984. APS Quality Assurance issued CAR CA-84-0154 to provide for the investigation and corrective action of concerna identified in the exit meeting.

The corrective action taken in Unit 1 includes the establishing of a walkdown team with representatives from each discipline. This team walked down the entire unit looking for housekeeping problems, for untagged or loose material, for tools not in une and to identify any unnecennary scaffolding still erected in the unit. All these types of items were identified and tagged or removed from the unit se appropriate.

All manual and nonmanual personnel in Unit I have been trained on the requirements of WPP/QCI 12.0 and 13.0 for material control and housekeeping respectively, thin training was completed on July 6,1984.

In Unit 2 a Superintendent is assigned to each building or group of buildings an a honnekeeping " Marshall". All nonmanual personnel have been instructed to look for housekeeping discrepancies during the performance of their annigned work in the unit and they have been trained on the requirements of WPP/QCI 12.0 and 13.0 and the issues raised in CAR CA 84-0154.

Unit 3 han reinspected the power block, yard storage trailers, personnel trailers and the laydown arean. Any housekeeping or material storage problems that were identied are in the process of being resolved. All Unit 3 nonmanual personnel have been trained to the requirements of WPP/QCI 12.0 and 13.0 and the innuen raised in CAR CA 84-0154.

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' Attachment A (Continued)

Page Six

~ II. . CORRECTIVE STEPS TAKIN TO AVOID RECURRENCE:

l A. The corrective action taken on Violation 2 above is also applicable

. on this violation.

In addition, WPP/QCI 12.0 will be revised to addrena the disposition of consumable and expendable materials that would normally be removed and discarded and replaced with new material during the dimensembly and reassembly process. Those materials not specifically identified an nonconforming, yet are materials that must be replaced during the reassembly process, will be required to be discarded, or if inft unattended, tagged with the Material Control Tags.

j The procedure will also be changed to require that material not j re-used in the reassembly of a component (that has not- been 1 specifically dispositioned on the work control documents) be 1 delivered to the Startup Meterial Control Group in the case of Systema jurisdictionally controlled by Startup and to APS Material Control in the case of systems jurisdictionally controlled by operations. When these procedure changes are issued, appropriate personnel training will be conducted.

Material, components or equipment that will be delivered as -

described above will be tagged in.accordance with WPP/QCI 12.0 until they are received by the Startup Material Control Group or APS Material Control. The transfer of that material from the work area to the appropriate warehouse will be documented on the Request for Stored Items (RSI) form in accordance with WPP/QCI 12.0.

B. Additionally, in mid May, 1984, APS Quality Assurance initiated a review of project proceuures/ programs concerning material control.

The neope of this review included Construction, Startup, and Operations, emphasizing the interface controla established between i

organizations, as well an evaluating the effectivenean of the program from a project-wide viewpoint.

This review identified neveral arean where procedural enhancements

are required to control materials at the interface junctures between organizations. A preliminary report van prepared in mid June,1984, and organizations informally apprised of its contents. Bened on this preliminary evaluation, APS QA convened project team meetings on July 11, 1984 and July 16, 1984 to addrena the material control l innuen on a project-wide basis and to establish a coordinated plan

of action. A project team has been formed to provide the necessary l procedural and programmatic enhancements.

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Attachment A (Continued)

Page Seven a III. DATE WHEN FULL COMPLIANCE WILL'BE ACHIEVED:

A. The procedure changes described in II. A. above will be issued and subsequently Field Engineers and QC Engineers will be trained on these new requirements. The procedures will be in effect and the training completed by August 31, 1984.

B. The necessary procedural / programmatic enhancements required as a result of the effort described in II. B. above are expected to be completed by September 15, 1984.

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