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=. o. s o x zie s e pwocmx.amizosa esose February 18, 1977 ANPP-7920 U. S. Nuclear Regulatory Commission Office of Inspection 6 Enforcement, Region V 1990 North California Boulevard, Suite 202 Walnut Creek, California 94596 Attention:
Mr. G. S. Spencer, Chief l
Reactor Construction 6 Engineering Support Branch
Dear Sir:
This refers to the inspection conducted by Messrs. R. J. Pate and D. F. Kirsch on December 14-17, 1976 as documented in your letter dated January 19, 1977, of activities authori:ed by the Nuclear Regulatory Commission (NRC) Construction Permits Nos. CPPR-141, 142 and 143.
As a rest $1t of this inspection, a ' Notice of Violation was written
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against the Palo Verde Nuclear Generating Station (PVNGS).
Enclosed as Appendix A to this letter is our response to this notice indicating:
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Corrective steps which have been taken and the l
results achieved; 2.
Corrective steps which will be taken to avoid further noncompliances; and 3.
The date full compliance was achieved.
i Additionally, you requested that we describe in particular, those actions taken or planned to improve the effectiveness of our Quality Assurance Program. The specific actions taken by APS management are included in Attachment B to this letter.
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Ari:ona Public Service Company continues to recogni:e its respon-k sibility for assuring that the PVNGS is engineered, designed,
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i U. S. Nuclear Regulatory Commission February IS,1977 ANPP-79 0 Page Two constructed and operated in such a manner as to provide for the l
health and safety of the public. The importance of an effective Quality Assurance Program as a means to achieve these responsibilities is also recogni:ed.
Very truly yours, T.T. au_1%P
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E. E. Van Brunt, Jr.
l APS Vice President l
i Construction Projects ANPP Project Director EEVBJr/BSK/pb Attachments l
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APPENDIX A Docket No. 50-528 Construction Permit No. CPPR-141 NOTICE OF VIOLATION Based on the results of an NRC inspection conducted on December 14-17, 1976, it appears that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:
(A) 10CFR 50, Appendix B, Criterion XV, as implemented by PSAR (Chapter 17), requires that nonconforming materials be controlled to prevent their inadvertent use or installation.
Contrary to the above requirement, on December 14, 1976, concrete with nonconforming slump, identified by testing performed on batch trip ticket Nos. 00611, 00622 and 00634, was placed in the Unit No.1 Reactor Pit Basemat (Lift 1C010-0).
~ This is an infra 6 tion.
RESPONSE
A Nonconformance Report was issued on December 15, 1976 to identify the nonconforming slump.
Based on the satisfac-tory test results of the 28 day compressive strength test, which demonstrated that the strength of the concrete exceeded the strength required by the design mix, Engineering has accepted the concrete with the high slump.
This infraction occurred because the concrete test samples were taken at the placement and not at the batch plant as origina,lly planned. Additionally, Engineering Testing Laboratory technicians who were testing samples during the placement, were not instructed to notify appropriate Bechtel 1
personnel if a batch of concrete was nonconforming.
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APPENDIX A
'Page 2
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To avoid further noncompliances, effective December 15, 1976, Bechtel Quality Control engineers were assigned to the concrete testing areas during all pours with authority to reject all nonconforming concrete.
In addition, Engineering Testing Laboratory was instructed verbally on December 15, 1976 and in writing on February 2,1977 to immediately notify a Bechtel Field Engineer or Quality Control Engineer when noncon-forming concrete is identified.
NOTICE OF VIOLATION (B) 10CFR 50, Appendix B, Criterion V, as implemented by PSAR (Chapter 17), requires that activities affecting quality be accomplished as prescribed by documented instructions and procedures.
Construction Specification No.13-CM-191 (Testing of Concrete Materials) requires that testing for air content,-
temperature and slump be accomplished once for every fifty cubic yards placed and testing for ccmpressive strength be performed for every one hundred cubic yards placed.
Contrary to the above requirements, on December 14, 1976, tests for air content, temperature, slump and compressive strength were performed less frequent than specified on concrete placed in the Unit No. 1 Reactor Pit Basemat (Lift 1C010-0).
This is an infraction.
RESPONSE
The concrete that was not tested at the frequency stated in Specification 13-CM-191. A review of all of the. concrete records for Unit No.1 Reactor Pit Basemat (Lift 1C010-0) revealed that (while the frequency of testing was not in compliance with 13-CM-191), a sufficient number of tests on the total pour were performed as follows:
1.
23 tests for air content, temperature and slump.
2.
11 tests for compressive strength.
APPENDIX A Page 3 A Nonconformance Report was issued on December 15 1976 to indicate the out of sequence testing for this lift.
Since the total number of tests required were made and all of the concrete characteristics were within the specification require-ments, the concrete was accepted as is.
This infrac' tion occurred because the concrete test samples were taken at the placement and not at the batch plant as originally planned. There was insufficient communication as to which placement locations were to perform the tests which resulted in several missed or out of frequency tests. This occurred three times for the slump test and once for the compressive test.
Although the total required tests were made, they were not of the correct frequency.
Further violations will be avoided by a new procedure that requires the batch plant QCE (Bechtel) to identify on the batch ticket when testing is required. This procedure was instituted on December 15, 1976.
In addition, the placement QCE will notify the batch plant QCE when a load has been rejected.
The batch plant QCE will require the next load be tested.
NOTICE OF VIOLATION (C) 10CFR 50, Appendix B, Criterion VI, as implemented by the PSAR (Chapter 17), the Palo Verde Nuclear Generating Station QA Manual (QAD 6.0), and the Bechtel Procedures (WP/P 3.0), requires that changes to documents, such as drawings, be distributed to the work locations.
Contrary to the above requirement, change OCN No. 5 to Drawing 13-C-ZAS-116, Revision 4, dated November 4,1976, had not been distributed to the work stations by December 15, 1976.
This is an infraction.
RESPONSE
A review of the infraction revealed that there was an error in the NRC Report in listing the DCN and corresponding drawing.
Drawing 13-C-ZAS-116, Revision 4, dated November 4,1976 1
APPENDIX A Page 4 had a DCN No. 5 to Revision 2, not Revision 4.
The infraction should reference Drawing 13-C-ZAS-110, Revision 4, dated November 4, 1976.
The later drawing DCN was posted on December 16, 1976 to immediately correct the :tror.
DCN No. 5 was originally received at the job site, logged in and distributed.
It was then discovered that DCN No. 5 was not properly completed.
The DCN was recalled and returned to Engineering for correction.
However, the log entry on the original transmittal was not removed.
After correction and transmittal back to the field, an incorrect assumption was made that DCN No. 5 had been distributed.
Effective December 17, 1976, a new procedure was implemented which required that if for any reason a document is returned to Engineering by DDCC, it must be logged out on the Engineering Drawing Control Register.
This procedure is currently in effect and the formal revision to Bechtel WPP/QCI 3.0 will be issued February 15, 1977.
The DDCC staff has also been increased to relieve the supervisor of routine work duties to allow ~for more training, auditing and supervisory functions.
The Project QA Engineer conducted a training session for all DDCC personnel on document control.
APPENDIX S Docket No.50-52S Construction Permit CPPR-141 The specific' actions taken by APS management to improve the effectiveness of our Quality Assurance Program consisted of letters, meetings and training programs aimed at reemphasizi,ng to Bechtel management the importance of following the details of the Project procedures and instructions and the importance of management's attention to quality assurance matters. These actions include the following:
A.
Action by APS Management 1.
As a result of the exit interview a letter was issued to Bechtel on December 21, 1976 stating our concern of their lack of implementing timely and satisfactory resolutions to items previously identified and requested a response as to what actions will be taken on their part to preclude a repetition of these and similar items.
2.
Meetings were held with Bechtel management on January 21 and February 4,1977 to discuss the implementation of the Bechtel Quality Assurance Program. Bechtel management was warned of the seriousness of not meeting the PSAR and specification requirements and was directed
' by APS to be more' actively involved in these matters.
In addition, subjects covered in detail during this meeting were drawing control, training of crafts and supervision, and management awareness and management support of the Quality Assurance Program.
3.
Special training sessions were conducted by the APS QA Manager on February 1 and 2,1977 at the PVNGS site for all Bechtel Field Engineers, Quality Control and Quality Assurance personnel, Superintendents, General Foremen and Foremen.
These training sessions covered the reSulatory process and the consequences of noncompliance. Ten sessions were held with a total attendance of 263. The attendance records of those who attended are on file.
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- ?PENDIX B Page 2 Specific subjects included in the training sessions were:
a)
The PSAR, what it is and what it represents, b)
The C'onstruction Permit and the Project's responsibilities relative to the Permit.
c)
The Quality Assurance Program, its relation to the PSAR and its importance in the implementation of the requirements of the PSAR.
d)
Nuclear Regulatory Comission, Office of Inspection and Enforcement, their role and what kinds of enforcement action can be initiated.
e)
Strict attention to detail at all levels of activity and the necessity to neticulously follow the instructions, procedures and drawings.
' Additional training of crafts is being planned and will be scheduled in March and April, 1977.
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4.
Discussions were held with the Bechtel Division QA Manager relative to the implementation of the Quality Assurance Programs.
5.
In accordance with the APS Field QA Manning Plan an additional site QA engineer with a discipline background of civil construction has been hired and will report to the APS site QA unit when reporting to work on February 22, 1977.
B.
As a result of the activities described in A above, Bechtel management comitted to take the following actions now and in the future to continue their involvement in Quality Assurance matters to assure a more effective program.
1.
The Project Engineer will analyze Field Change Requests (FCR's) no less frequently than quarterly i
to identify any significant trends and take any additional corrective action.
His analysis and actions will be reviewed by Bechtel management and appropriate action will be taken if necessary.
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APPENDIX 5 Page a 2.
The present Quality Assurance Program requires that the Bechtel' Project Quality Assurance Engineer (PQAE) analyzes Nonconformance Reports (NCR's) to identify any significant trends and recontend corrective actions to the discipline involved. This analysis will now be brought to the direct attention of the PVNGS Project Manager. Bechtel management will also monitor the NCR's and take appropriate action as necessary.
3.
Bechtel management will audit the training procedures and their effectiveness, If warranted, additional training activities will be initiated.
4.
Cor'rective Action Requests showing recurring problems will be reviewed by the Project Manager, Division Department Heads and the Southwest Area Opera-tions Manager. Appropriate actions will be initiated to minimize repetitive Correction Action Requests (CAR's).
5.
Bechtel management will analyze the problems identified at other construction jobs to assure that these problems are not and will not occur on the PVNGS.
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