ML20095B288
| ML20095B288 | |
| 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) |
| Shared Package | |
| ML20095B209 | List: |
| References | |
| ANPP-30011-WFQ, NUDOCS 8408220071 | |
| Download: ML20095B288 (10) | |
Text
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TlE0EIVED li.CC
-i Arizona Public Service Company 035 J.". 23 A!! 9 4 July 20, 1984 E!MCE ANPP-30011-WM/TJB -
U.S. Nuclear Regulatory Commission Region V-Creeknide 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 This letter refars to the inspection conducted by Messrs. R. Zimmarman, 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, l
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E. E. Van Brunt, Jr.
i APS Vice President Nuclear Production ANPP Project Director EEVB/TJB:db At tachment cc:
See Page Two 8408220071 840016 PDR ADOCK 05000528 l
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Mr. T. W. Bishop ANPP-30011 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. Hewkinson W. F. Quinn S. R. Prost K. W. Gross D. Canady R. P. Zimmerman L. E. Vorderbrueggen E. A. Licitra Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, GA 30339
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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 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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La28us c Edwin E. Van Brunt, Jr.
Sworn to before me this N O J day of Ady
, 1984.
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AlyCommissia Empires April 6,1987
ATTACHMENT 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 iteam.
Bechtel Work Plan Procedure / Quality Control. Instruction - 5.0, Nonconforming Materials, Parts or Components, Reviaion 25, dated February 3,1984 requires in paragraphs 2.2 and 9.1 that a Nonconformance Report be generated to disposition nonconforming items and that such iteam he identified by Hold Tags, markings or other clear means of identification.
Contrary to the above, on May 3,1984 two nonconforming mechanical seals, removed from the "A" High Pressure Safety Iniection Pump on April 27 and 28, 1984 were not properly controlled in that Nonconformance Reports were not generated to disposition the nonconforming meals and the seals were not identified by Hold Tage, markinga, or other clear means of identification.
j-This is a Severity IAvel IV Violation (Supplement II).
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9 Attachment A (Continued)
Page Two RESPONSE TO NOTICE OF VIOLATION I.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
On August'22, 1983, Startup NCR SM-2712 was issued describing a nonconforming seal on LPSI Puep A in Unit 1.
The disposition was to replace the seal upon completion of the test that van in progress. In aid April of 1984, SEA 20205 was initiated referencing the Startup NCR and it van also dispecitioned to replace the seal. Suhnequently, Construction disassenhied the pump, removed the defective seal and
. replaced it with a new neal.
Construction's procedure, WPP/QCI 31.5, limits construction's responsibility for preparing a nonconformance report to exclude those conditions already described on a nonconformance report issued by another organization; in this case, Startup. Consequently, the removed seal was considered to be under the jurisdiction of the Startup conconformance report. No new nonconformance report was initiated by Constniction nor was a construction NCR Hold Tag placed on the neal.
The seal was set aside to avait further disposition instructions from Startup.. The Startuo NCR Drocedure does not require the tagging of a nonconforming item._
v Af ter reansembly of the pump with the new seal, it could not be rotated 4
by hand. At that time Construction NCR N-A-1336 was prepared to document this probles. A Construction NCR Hold Tag was prepared and hung on the pump body. The interia disposition required disassembly of the pump to investigate the binding probles.
After disassembly, it was determined that the second seal was defective. The final disposition on NCR N-A-1336 was to replace the second neal with a third seal and deliver the unacceptable second seal to combuntion Engineering. APS supplied a third seal to be installed in the pump.
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Bechtel Construction was in error by 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 3,1984, when the Resident NRC Inspector
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identified the probles to Construction, NCR Hold Tags were subsequently attached to both defective seals.
r Clarifying the stated findings, there were nonconformance reports generated to document both conconforming seals. The first seal under the Startup NCR and the second under the Construction NCR. The situation leading to the finding by the NRC Resident Inspector was a lack of clearly established procedural requirements for tagging.
l The construction error has been discussed with the Field Engineering and Quality Control personnel that were involved in the replacement of l
these seals to be sure they clearly understand the requirements for tagging nonconforming material.
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Attachment A (Continued)
Page Three 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 Material Control Tag to remove parts or components that are identified as conconforming on a Startup or Operations NCR referenct. in or attached to a SEA or CWO.
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 those documents (SWAa, CW0s) when those removed components are not otherwise tagged under the Bechtel work control program.
Therefore, with the exception of consumable materials or expendables that will be discarded upon removal, other components removed during the dinansembly of equipment will be tagged by one of the following:
- 1. A Construction NCR Tag for those.,tteas identified on a Construction N nconformance Report, f
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- 2. By a Material Control Tag for reuseable' items.
- 3. By a Material Control Tag for those items identified on synteen under either Startup or Operations jurisdiction.
The Material Control Tag applied to those items identified in a Startup or Operations conconformance report will specifically note that the item in nonconforming per the specific NCR.
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 information as possible.
III. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The' procedure changen described above will be innued and subsequently Field Engineers and QC Engineers will be trained on these new require menta. 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.
10CFE50, Appendix B, Criterion VIII, Identification and Control of Materials, Parts and Components, requires that measures shall he esteh11shed 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, prescriben 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 disassenhied item will be lef t unattended or must be stored for a period of time, a Material Control Tag shall be prepared and attached to the asterial.
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 sensing units were stored on the floor of the B Low Pressure Safety Injection Pump Room among scattered tools and debris. No maintenance was 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).
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Attachment A (Continued)
Page Pive 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 itees found by the NRC Resident Inspector on May 17, 1984 had been removed from their installed locations before or after the issuance of the tagging program. In any case, when the procedure was issued, there was no attempt to walkdown or inspect the units to identify any untagged or uncontrolled saterial.
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 concerns 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 tess 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 thene types of items were identified and tagged or removed from the unit as appropriate.
All =anual and noneanual 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 housekeeping " Marshall". All noneanual personnel have been instructed to look for housekeeping discrepancies during the performance of their asaigned work in the unit and they have been trained on the requirements of VPP/QCI 12.0 and 13.0 and the issues 1
raised in CAR CA 84-0154.
Unit 3 han reinspected the power block, yard storage trailers, personnel trailers and the laydown areas. Any housekeeping or material storage probless that were identied are in the process of being resolved. All Unit 3 noneanual personnel have been trained to the requirements of WPP/QCI 12.0 and 13.0 and the inaues raised in CAR CA 84-0154.
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Page Sir II.
CORRECTIVE STEPS TAKEN TO AVOID RECURRENCE:
A. The corrective action taken on Violation 2 above is also applicable on this violation.
In addition, WPP/QCI 12.0 will he revised to address the disposition of consumable and expendable materials that would normally be removed and discarded and replaced with new material during the disassembly and reassembly process. Those materials not specifically identified as nonconforming, yet are materials that must be replaced during the reassembly process, will be required to he discarded, or if left unattended, tagged with the Material Control Tags.
The procedure will also be changed to require that material not re-used in the reassembly of a component (that has not been specifically diapositioned on the work control documents) be delivered to the Startup Material Control Group in the case of Systems jurisdictionally controlled by Startup and to APS Material 4
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 he documented on the Request for Stored Items (RSI) form in accordance with WPP/QCI 12.0.
B. Additionally, in aid May, 1984, APS Quality Assurance initiated a review of project procedures /programa concerning material control.
The scope of this review included Construction, Startup, and Operations, emphasizing the interface controls established between l
organizations, an well an evaluating the effectiveness of the program from a project-wide viewpoint.
This review identified neveral aream where procedural enhancements are required to control materisis at the interface junctures between organizations. A preliminary report van prepared in aid 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 address the material control i
innues on a project-wide basis and to establish a coordinated plan of action. A project team has been formed to provide the necessary procedural and programmatic enhancements.
Attachment A (Continued)
Page Seven 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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