ML20116N787

Responds to NRC 850131 Request for Investigation of Concern RV-84-A-087 Re Downgrading of Test Equipment Specs.Basis of Accuracy Specs to Rod Oven Thermometers,Micrometers & Ashcroft Pressure Gauges Discussed

ML20116N787
Person / Time
Site:	Palo Verde
Issue date:	04/15/1985
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
ANPP-32396-EEVB, NUDOCS 8505070350
Download: ML20116N787 (5)

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via Arizona Nuclear Power ProjectEU /

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P.O. BCX 52034

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April 15, 1985,,,

ANPP-32396-EEVB.fr'/WSI/WFQ U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane - Suite 210 Walnut Creek, California 94596-5368 Attention:

Mr. D. F. Kirsch, Acting Director Division of Reactor Safety and Projects

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket No. 50-528 (License No. NPF-34)/529/530 Investigation of Allegation NRC Concern RV-84-A-087; No. 154 File:

85-019-026; D.4.33.2

Reference:

(A) NRC Letter from D. F. Kirsch to E. E. Van Brunt, Jr.,

dated January 31, 1985 (B) ANPP Letter ANPP-32088-EEVBJr/WEI/WFQ, dated March 7, 1985

Dear Sir:

As per Reference (A), ANPP was requested to investigate the concerns expressed by a confidential alleger. Reference (B) provided the ANPP response to the referenced concerns with the exception that one >

concern required further investigation. Attachment A provides the response to that concern.

If there are questions regarding,these investigations or the results, please contact us.

Very truly yours, 85050 8h0b5 PDR O 00 S28 :

E. E. Van Brunt, Jr.

G PDR Executive Vice President Project Director EEVBJr/WEI/ske Attachment cc:

L. F. Miller L. A. Souza R. P. Zimmerman N. W. Lossing D. B. Karner,;

W.,F. Quinn A. C. Gehr W.11. Wilson J. R. Bynum W. G. Bingham R. M. Butler W. J..Stubbleficid' D. B. Fasnacht-D. R. llawkinson

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J. D. Houchen Y

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V ATTACHMENT A l

. Downgrading of; Test' Equipment Specifications i

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(RV-84-A-87; No.154; Concern 1)

. Concern:

-Test Equipment Sp,ccifications-Were Arbitrarily Modified (e.g. Rod Oven Thermometers, Micrometers, Holiday" Detectors and Ashcroft Pressure Cages):

Investigation R'esu'lts:-

[ Work Plan [Proce' dure, WPP 7.0, entitled 1" Calibration and Control of Construction' Measuring and Test Equipment", allows the Instrument Cali-bration Laboratory Engineer (ICLE) to establish accuracies for Measuring 4

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-and. Testing Equipment based on Project requirements.. This accuracy may

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be differ'ent than that.specified by:the manufacturer, depending on the i

.use_of..the Measuring and Testing Equipment. A review was conducted of

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the equipment specified.in this concern to identify if the accuracy speci-

'fied by the. ICLE was different than that specified.by the. instrument manu.-

facturer. : The results of that review indicate the following:

a. 1 Rod: Oven Thermometers:

The manufacturer's specified accuracy,is I 10' F.

The

' accuracy specified by the ICLE-for use at.PVNGS was-

20' F; k

Rod oven-thermometers are used to ensure that weld rod' ovens are maintained st'a temperature which.will prevent thelpotential moisture gain in E7018 electrodes resulting.

from high humidity environments'.'...This-requirement' exists

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to prevent' under bead cracking and toL minimize porosity

. when the weld rod is used. -Bechtel. Specification WFMC-1 forswald electrodes = establishes a. rod: oven' holding temper-

'acure.of.200*~F to 350' F.

With thezlow. humidity conditions present'at.the Palo' Verde ~

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ijobsite, maintenance of weld rod at less than the prescribed:

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. holding temperature can be. demonstrated by'BechtelzM&QS' test 3

~ data to not have anl adverse-affeet.on'the quality'.of the~

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completed weld.-

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U f As' a follow -up to this investigation.- a review of weld ' rod 1

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' holding-oven temperat'ure monitoring logs has revealed that

-l irecorded; temperatures in a few cases.(approximately'seven (7).

instances 'out of ; approximately-. ten f thousand "(10,000) records) -

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2were less.than the minimum 200 *F ' required., Bechtel Field -

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--Engineering. will' review this ~ condition { and will ensure the -

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Attrchment AL ANPP-32396-WEI/EEVBJr Apri1=15, 1985 Page'2:

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noted' discrepancies are/or were previously reported on Nonconformance Reports. Instances in which the recorded temperatures'are less than 220' F but greater than 200* F could. allow the_ actual temperature to be below 200* F in

.the worst case, even with the thermometer within the.cali-bration range. Engineering;has evaluated'the condition as havingLno safety significance,' therefore, no further review of this issue will be taken.

b.

Micrometers:

1 In the previous review, as described in Reference (B)~, one case was noted in which an error, that exceeded the manu-fact.ur'er's tolerance, was accepted. This deficiency was documented on a Defective Instrument Report, DIR-92.

This specific case has been determined not to affect any previous installation.

- To determine the extent and significance of this problem, Bechtel Engineering will evaluate a sample of M&TE calibra-Etion records which accepted an out-of-tolerance condition.

.The sar:le size will be determined by Project Engineering.

and the results of the review will be evaluated for safety.

significance.

The above review and evaluation will be completed by May 17, 1985.

Hol'iday Detectors:

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The resolution of this concern'wac-fully addressed in'

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Reference (B).

d.

Ashcroft Pressure Gages:

Ashcroft Pressure Cage'Model 1320A has a manufacturer's specified accuracy of I h%.-LThe required accuracy at PVNGS has been specified bylthe ICLE as. 11%..

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Hydrostatic tests'are performed in compliance,with Project E specifications and based cm Code requirements..The minimum'

' test pressure is determined by the design pressure, multiplied by:a factor of 1.25 and/orzi.5, depending on the' applicable Code. l Project: Engineering allows the ' test pressure.to exceed the minimum' required-by_a_ maximum of + 6%.-

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TAttichment A'

,ANPP-323964WEI/EEVBJr

~ April-15, 1985

'Page 3 A.re'iew of documented hydrostatic-test' records and v

. discussions with responsible individuals revealed that the minimum / maximum. test. ranges are determined by the design' pressure,' multiplied by the-required factor.

Maximsm pressure is. established-by the' test pressure,

plus ! 6%, to compensate for 'possible. gage e'rror.,The

-recorded. test pressures in'the do~cumentation reviewed were in the mid-range:between the minimum / maximum allowed.

There was no case where the I.1%^ accuracy could have had an adverse effect'on'the test results.

Records included documentation'of pre-test and post-test calib' rations, percent' accuracy of-test. gages and. calibra-

. tion' equipment us'ed.. Test gages were identified to have '

. ~1% acc'uracy, calibration gages were' recorded to be:

.1%/.25% accurate. The-test records; reviewed meet these requirements.

.,There is no evidence of an arbitrary modification of.

1 calibration accuracies-that do not. meet Project require-ments.-

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Based on the results of the review of Measuring and Testing Equipment conducted to date..it has been: determined that in a few' instances'the Bechtel' Calibration Lab has calibratedfor accepted Measuring and; Testing

. Equipment to an accuracy range' greater than that re' commended by'the manu-facturer. ' The evaluation of! affect on Project. installations has not been

-documented.. The'.use or acceptance of M&TE calibration accuracies greater

-than-those recommended by the manufacturer.may have an impact on'the acceptance criteria established in the' Project design documents.

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The. root cause of'this situation has been' determined to be:

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LA.: Bechtel's Construction Work Plan: Procedure, (WPP ;7.0)H for 1

LMeasuring'and Testing Equipment-(M&TE) calibration allowed t

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.the Bechtel-InstrumentfCalibration Laboratory, Engineer l(ICLE).to utilize _a calibration accuracy range different i

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.than that recommended;byfthe' manufacturer,without docu-

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'menting the; effects'onuProject insta11ation or? review by s

.. Project Engineer.

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. Bechtel's' Calibration Lab personnel'made errors!in isolated B.'7 fcasesfby accepting outrof-tolerance M&TE returne'd'from the.

.m' ifield-without proper evaluation.-

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'Attschment A

ANPP--32396'-WEI/EEVBJr April 15, 1985 Page.4

- To resolve ~these deficiencies, the_following corrective actions will be taken:

~ A.

Bechtiel Construction Procedure, WPP c7.0, will be revised

'by April.16, 1985 to require Bechtel Engineering approval

'for any change to..M&TE calibration accuracy ranges.'The

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basis of-the evaluation will be documented.

B.- Bechtel Engitieering will-review and evaluate all instances in which M&TE calibration accuracy ranges were previously.

increased by.the ICLE. This review will be completed by-May 3,~ 1985.

C.-

Bechtel Engineering will evaluate the effect on plant-

' installation of a sample of M&TE calibration records which accepted an out-of-tolerance condition without a proper evaluation.- This review will:be completed by May 17., 1985.

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