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1993 N. CALIFORNIA BOULEVARD
,o WALNUT CREEK. CALIFORN4A 94894 Docket Nos. 50-528 0071a gn 50-529 50-530 Arizona Public Service Ccmpany P. O. Box 21666 Phoenix, Arizona 85036 Attention: Mr. E. E. Van Brunt, Jr.
APS Vice President Construction Projects ANPP Project Director Gentlemen:
Subject:
Notice of Violation Resulting from NRC Inspection of July 17-21,1978 Thank you for your letter dated September 7,1978 and the amended Attachment A to that letter which was forwarded to this office with your letter dated October 4,1978. The amended Attachment A informed us of the steps you have taken to correct the items which we brought to your attention in our letter dated August 4,1978. With regard to the response to Item 4.8 of Attachment A, it is our understanding that you intend to have the changes associated with Tasks 1.1 and 9.1 implemented by November 1,1978. Your corrective cetions will be verified during a future inspection.
Your cooperation with us is appreciated.
Sincerely, 4
G. S. Sp'encer, Chief Reactor Construction and 1
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October 4, 1978 y
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ef, U. S. Nuclear Regulatory Commission
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,'J-Walnut Creek Plaza - Suite 202 1990 North California Boulevard Walnut Creek, California 94596 Attention: Mr. G. S. Spencer, Chief Reactor Construction and Engineering Support Branch
Subject:
NRC I&E Inspection of July 17-21, 1978 File: 78-019-026
Reference:
Letter ANPP-11698-JAR, dated September 7,1978, same subject Dear Sir Enclosed, is our amended Attachment A to our letter of September 7,1978 referenced above. The amended Attachment A is our response to your in-spection findings of July 17-21, 1978.
t Very truly yours, 1 J E. E. Van Brunt, r.
APS Vice President Construction Projects ANPP Project Director EEVBJr/ JAR ske t
Enclosure cc R. L. Robb W. M. Petro R. L. Hand S. 8. Esplan I
A. C. Gehr W. M. Wilson W. J. Stubblefield J. E. Bashore C. Betshold c,
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.ted September 7. 1978 Docket Nos. 50-528, 529, 530 NOTICE OF VIO!.ATION Based on the results of the Inspection conducted on July 17-21, 1978, it appears that certain of your activities were not conducted in full com-pliance with NRC requirements as indicated below:
on July 19-21, 1978, NRC inspectors examined ITait 1 post-tensioning trumplate and sheathing installation and inspection activities. The following conditions were identif,ied 1.
Bechtel Work Plan Procedure / Quality Control Instruction No.
66, Revision 2 " Post-Tensioning Trumplate and Sheathing Installatior and Inspection", provides for accomplishing work in accordance with specified procedures, instructions and drawings, as required by 10CPR30, Appendix B, Criterion V, the PSAP. Section 17.1A.5 and the Palo Verde Nuclear Generating Station Quality Assurance Manual, Chapter 5, all entitled, " Instructions, Procedures and Drawings".
Contrary to these requirements, the following enspies of nonconforming work were observed e
A.
Vertical and horizontal tendon sheaths installed for placement IC109 were wire tied at intervals greater than the maximum interval of 3'-6", specified in WPP/
QCI No. 66.
B.
Six trumplate extensions were found to be unwired at their ends contrary to the requirements of WPF/QCI No. 66.
C.
Two vertical sheaths (the 17th and 19th clockwise from the center of the equipment hatch) were found to be out of alignment by 2" in 10', whereas Drawing 13-C-ZCS-175, Revision 2 DCN 1, specifies a maximum misalignment of 3/4" in 10'.
D.
Horizontal sheaths above the equipeent hatch were found to be within lis" of each other, whereas Drawing 13-C-ZCS-175 Revision 2, DCN 1, specifies a minimua l
clearance of 3" in this area.
This is an infraction.
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RESPONSE
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A. through C.
has items were corrected by Bechtel prior to making the concrete placement IC109. N se items were left uncorrected prior to "jumpias" the concrete forms with the intent of' I
making the corrections af ter jumping the forms. This was i
done without documented formal approval which is not in i.
accordance with the accepted procedures.
r Bechtel Construction Supervision was informed by AFS that deviation from the approved procedures must be done la accordance with the existing procedures prior to perforetag the work.
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h Bechtel Field Construction Manager has written.a letter, j
dated October,3, 1978, to construction management personnel indicating that no deviations from existing procedures will 4
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be tolerated without utilising the' formal dociment chsage
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allowed by procedures.
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D.
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Bechtel Construction was avere that the spacing of horisontal j
sheaths over the' equipment opening were within li" s, contrary j
to the 3" expressed on Drawing 13-C-ZC8-175. Revision 2. DCN 1.
i At the time of NBC's Inspection, field data was being prepared to develop a Field Change Request (FCR) 2379-C to accept the i.
i sheathing spacing. h FCR, dated July 20, 1978, was finally t
approved on July 21,.1978 by Bechtel Engineering prior to the i
concrete placement.
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2.
l Sechtel Work Plan Procedure / Quality Control. Instruction No.
66, Revision 2, " Post-Tensionias Trumplate and Sheathing In-sta11ation and Inspection", provides for the performance of i
acceptance inspections, as required by 10CFR$0, Appendix B, Criterion X, the Palo Verda Nuclear Generating Station quality l
Assurance Manuel, Chapter 10, and the PSAR gestion 17.1A.10 i
all entitled, " Inspection".
contrary to these requirements, mandatory inspection hold i
points for the drilling of sheathing vent holes, installation i
of vent piping, wiring of sheathing and, positioning of sheath-ing were performed in a random sampling manner lastead of 'the j
full coverage required by WFP/QCI No. 66.
This is an infraction.
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' Amended Act cent A Notice of Violation
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RESPONSE
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The acceptance inspections as performed by Bechtel' Quality Control was in conformance of WPF/QCI No. 64. Revision 2.
The portion of the WPF/QCI entitled Western Concrete Struc-tures (WCS) Quality Control Procedure (QCP) No. 3. Para-l l
graph 3.1, " Contractor Inspection", subparagraph 3.1.1 specifies...."100% inspection of Trumplate installations fort position,, deformation, bolt mounting, tightness to l
forms and rust." Subparagraph 3.1.2 specifies...."1001 inspection of Ridge Extension installations fort seating,
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tapias, ands tied off, alignment and position, deformation and rust."
4 We have investigated the concerns expressed by the NRC sad feel that it would be prudent to change the procedure Con-struction Inapeution Plannias (CIF) to require 1002 inspec-j tion of all other items specified in the referenced proce-f dure and the impleneatation of mandatory hold points to be inspected ladividually at the completion of each step of the installation.
FCN No. 4 tn WFF/QCI'No. 64, Revision 2, was generated I
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July.21, 1973, which provided for requirements for Quality.
Control inspection and acceptance of sheathing installation 3
on the CIF referenced in WCS Post-Tensioning Procedure No. S.
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Bechtel Work Plan Procedure / Quality Control Instruction No.
64, Revision 2. " Post-Tensioning Trumplate and Sheathing
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i Installation and Inspection", provides for properly docu-i meeting and dispositioatsg nonconforasaces, as required by 10CFRSO, Appendia E, Criterios XV, the Palo Verde Nuclear j..
Generating Station quality Assurance Nanual, Chapter 13, and
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the PSAR section 17.1A.15, all entitled, " Nonconforming Wa-terials, Parte or Componenta"..
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Centrary to these requirements, records for sheathing installed for concrete placement 1C103 indicate a Wencon-i; foresace Report was not issued for the existing abrupt L
i alignment change in vertical tendon sheath Y-79.
l This is an infraction..
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At the time of the NRC Inspection, the field construction activities related to the sheathing were not complete. The l
normel work sequence results in survey verification of the L
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!ocice of VA.Aation Page 4 sheathing locations approximately 24 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the placement. This verification is accomplished prior to the next concrete placement and identifies out-of-tolerance conditions in both the present and the previous placements.
A Nonconformance Report (NCR) C-C-72 was prepared, disposi-tiened and approved by Engineering on July 21, 1978 prior to the concrete placement 1C109.
We have addressed your concerns and initiated Procedure Change Notice No. 7 to verify the location of the protruding vertical sheathing af ter each concrete placement rather than wait until the final inspections of the next concrete place-ment.
.f 4.
The APS QA Program as set forth in the PSAR Section 17.1A.17 and the Palo Verde Nuclear Generating Station Quality Assur-ance Manual Chapter 17, both entitled " Quality Assurance Records", establishes requisites for developing and usintain-ing sufficient records to provide evidence of activities affecting quality, as required by 10CyR50, Appendix B, Cri-4 terion XVII.
Contrary to these requirements, sufficient qualf ty assurance records were not maintained as indicated below:
A.
As indicated in 2. above, mandatory inspection hold t
points were inspected in a sampling manner, instead of 100% inspection. No quality records, however, were maintained for even the sampling inspections which would identify items inspected and the date and results of inspections.
B.
Records for inspections of trusplate installation for J
concrete placement 1C104 were not signed-off by Quality Control Engineers prior to the placement of concrete.
' This is, a deficiency.
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A.
Our investigation of your finding revealed that the Bechtel Quality Control Inspectors were documenting their in-process inspections on a drawing in a manner that was not adequate.
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Since your inspection, Bechtel has implemented a program, prior to placement of.1C110, that provides for adequata communication between shifts and shows what inspections have been completed.
4.
B.
Documentation of Task 1.1 and 9.1 on the vall buttress and dome installation inspection CIP were completed as required, but do not provide the necessary continuity and 'visitility of inspection verification.
't Task 1.1 will be changed to two tasks to provide separate signatures; one for Quality Control Procedure (QCP) No. 3, Paragraph 3.1.1, Inspection, and one for Post-Tensioning Procedure (PTP) No. 5, Paragraph 5.2.2 Installation Yeri-fication.
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Task 9.1 inspection criteria, Western Concrete Structures (WCS) QCP No. 3, Paragraph 3.1.4, is in error in that it l
cannot be. accot:plished after concrete placement. This conditiott is caused by misunderstandiits of WCS's use of the word "placecent" in sheathing work and not concrete work.
Paragraph 3.1.4, inspection is verified in Task 3.2 in Bechtel's CIP for tendon sheathing fastallation. Task 9.1 will be corrected.
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Septuber 7, 1978
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U. S. Nuclear Regulatory Commission p, ' '. -
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Region V Walnut Creek Plaza - Suite 202
'i 1990 North California Boulevard N
Walnut Creek, California 94596 Attention:
Mr. G. S. Spencer, Chief Reactor Construction and Engineering Support Branch-
Subject:
NRC I&E Inspection of July 17-21, 1978 File: 78-019-026
Dear Sir:
This letter refers to the Inspection conducted by Messrs. L. J.
Garvin, L.' E. Vorderbrueggen and T. W. Bishop on July 17-21, 1978, i
as documented in your letter of August 4, 1978, of activities authorized by Nuclear Regulatory Connaission (NRC) Construction Permits Nos. CPPR-141, 142 and.143.
We'have carefully reviewed your Inspection Report and Notice of
' Violation relating to your Inspection of. July 17-21, 1978 and have addressed each of your specific findings in Attachment A i
to this letter. However, as a result of this review, we are concerned that.there may be some misunderstandings relating to the checks and balances provided by the APS Quality Assurance Program.
In the case of the tendon sheathing installation, we feel that your findings did not take into consideration that this work was "in-process" at the time of your inspection and had not yet been physically completed.- In this context, our program requires at least two more formal inspection and sign-off points before the particular concrete placement could~be made. None of these in-
.spection points were completed nor was the physical work at a point where these inspections should or could have been performed.-
Therefore, since the inspection prc.:ess was not yet completed and the concrete placement had not been released, we do not believe it can be concluded that the final product would have been in non-conformance.
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'J. 3. Nucle Regulaccry Commission httention:
.fr. G. S. Spencer, Chief ANPP-11698-JAR September 7, 1978 Page 2 Specifically, the APS Quality Assurance Program requires a final i
quality control sign-off for the tendon sheathing installation and a preplacement check for concrete placement 1C109 before the 4
concrete pour can proceed. Both of these inspections and sign-off points require a final check of the work involved and for the resolution of any discrepancies. These sign-offs were accomplished on July 21, 1978.
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i In response to your concerns relating to the management control of site activities, Bechtel site supervision has rereviewed and dis-cussed with construction personnel their responsibilities and the i
clarification of tasks relating to tendon sheathing installation and inspections. This meeting.was held July 24, 1978. Also, in
. order to provide additional management support to these construc-4 tion activities, a Senior Civil Engineer was transferred to the containment area.
1 1
4 In this connection, the concrete placement IC109 had actually been officially postponed by the Bechtel Superintendent at 12:00 Thurs-day, July 19, 1978, but he had knowingly not. informed the crafts or their supervision of this action so that the work would proceed i
as if the pour was to take place. The Quality Assurance Manager i
had also informed the Site Quality Assurance personnel on Thursday, i
July 19,1978, not to allow the concrete placement IC109 to take place unless they (APS QA) were fully convinced that the specifi-cation requirements had been met.
Therefore, we feel we had control of the situation and was allowing the work 'to proceed so that it could be accomplished, but would not and did not allow concrete placement IC109 to be made until all concerns had been
-satisfactorily resolved. As indicated previously, all inspections
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'and sign-offs related to this concrete placement were satisfactorily completed in a controlled manner and the concrete placement IC109 was made about mid-night July 21,11978 in the presence of APS Site Quality Assurance after it was determined that all concerns were fully resolved.
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In your Inspection Report, you also expressed a concern that Bechtel E
and APS' Site Quality Assurance groups had not taken action when it
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was apparent that corrective action was necessary.- As we expressed l
to you during the exit interview, we take exception to this in that j
i APS Quality Assurance has the. authority to stop work-by numerous means and has done so in-the past.. We are concerned that~we apparently failed to. properly communicate with your inspectors during this inspection. With this in mind,E we have taken steps to assure that we have positive and. meaningful understandings during
' future inspections.
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L'. S. Nuc'~Tr Ragulatorf Co=1ssion Attention.
Mr. G. S. Spencer, Chief ANPP-il698-JAR September 7, 1978 Page 3 Attachment A to this letter contains Arizona Public Service's-responses to the specific findings identified during your In-spection of July 17-21, 1978.
Very trulv yours,
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E. T.
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NUN E. E. Van Brunt, Jr.
APS Vice President Construction Projects
' ANPP Project Director EEVBJr/ JAR:ske Attachment cc:
R. L. Robb W. M. Petro R. L. Hand B. S. Kaplan A. C. Gehr W. H. Wilson W. J. Stubblefield J. E. Bashore C. Betzhold i
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i ATTACEMENT A APPENDIX A Docket Nos. 50-528, 529, 530 2
NOTICE OF VIOLATION Based on the results of the Inspection conducted on July 17-21, 1978, it appears that certain of your activities were not con-1 ducted in fu11 ' compliance with NRC requirements as indicated R
below:
On July 19-20, 1978, NRC inspectors examined Unit 1 post-tensioning trumplate and sheathing installation and inspection activities. The following conditions were identified:
1.
Bechtel Work Plan Procedure / Quality Control Instruction No. 66 Revision 2 " Post-Tensioning Trumplace and 4
Sheathing Installation and Inspection", provides for accomplishing work in accordance with specified pro-cedures, instructions and drawings, as required by 10CFR50, Appendix B Criterion V, the PSAR Section 17.1A.5 and the Palo Verde Nuclear Generating Station Quality Assurance Manual, Chapter 5, all entitled, i.
" Instructions, Procedures and Drawings".
Contrary to these requirements, the following examples of nonconforming work were observed:
)
A.
Vertical and horizontal tendon sheaths installed for placement IC109 were wire tied at intervals greater than the maximum interval' of 3'-6",.
specified in WPP/QCI No. 66.
B.
Six trumplate extensions were found to be unwired at their ends contrary to the requirements of WPP/QCI No. 66.
C.
Two vertical sheaths (the 17th and 19th clockwise from the. center of the equipment hatch) were found
.to be out of alignment by 2" in 10', whereas Draw-
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ing 13-C-ZCS-175, Revision 2, DCN 1, specifies a maximum misalignment of 3/4" in 10'..
D.
Horizontal sheaths above the equipment hatch were found to be within 1 " of each other, whereas
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Drawing 13-C-ZCS-175, Revision 2,.DCN 1, specifies
-a minimum clearance of 3" in this area.
This is an infraction.
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a t tach =c e Appendix a Notice of Violation Page 2
RESPONSE
1.
A.-C.
i-During the time of the NRC Inspection, field construction l
activities relating to securing the tendon sheathing, i
trumplate extensions and sheathing alignment were in-process and not complete. Field Engineering had not completed their inspections nor had Quality Control conducted their final inspection. The work was being i
performed as described in Work Plans Procedures / Quality-Control Instruction (WPF/QCI) No. 66.
Therefore, since i
the work had not been completed and finally inspected, we do not believe it can be concluded that the final product would have been in nonconformance.
1.
D.
Bechtel Construction was aware that the spacing of i
horizontal sheaths over the equipment opening were i
within 1 " contrary to the 3" expressed on Drawing i
13-C-ZCS-175, Revision 2, DCN 1.' At'the time of NRC's Inspection, field data was being prepared to develop a Field Change Request (FCR) 2379-C to accept the sheathing spacing. The FCR, dated July 20, 1978, was finally ap-i proved on July.21, 1978 by Bechtel Engineering prior to
'the concrete placement.
4 Based on our subsequent investigations and the information available to us, we do not believe that in this area
- there was a violation of the Bechtel procedures or Quality Assurance Program requirements.-
2.
Bechtel Work Plan Procedure / Quality Control Instruction
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l No. 66, Revision 2, " Post-Tensioning Trumplace and i
Sheathing Installation ~and Inspection", provides for the i
performance of acceptance inspections, as required by 10CFR50, Appendix B, Criterion X, the Palo Verde Nuclear -
Generating Station Quality Assurance Manual, Chapter 10 and.the PSAR Section 17.1A.10, all entitled, " Inspection".
IL Contrary to these requirements, mandatory inspection hold points for the drilling of sheathing vent holes, instal-lation of vent piping, wiring of sheathing and position-
'A ing of sheathing were performed in a random sampling manner instead of the full coverage required by WPP/QCI
-No. 66.
This is an infraction.
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Attach =ent Appendix A Notice of Violation Page 3
RESPONSE
2.
The acceptance inspections as performed by Bechtel Quality Control was in conformance of WPP/QCI No. 66, Revision 2.
The portion of the WPP/QCI entitled Western Concrete Structures (WCS) Quality Control Procedure (QCP) No. 3, Paragraph 3.1, " Contractor Inspection", Subparagraph 3.1.1 i
specifies...."100% inspection of Trumplate installations for: position, deformation, bolt mounting, tightness to forms and rust."
Subparagraph 3.1.2 specifies...."100%
inspection of Ridge Extenaion installations for: seating, taping, ends tied of f, alignment and position, deformation and rust."
There is no specified frequency of inspections for the other items and activities described in the WCS Quality Control Procedures or WPP/QCI No. 66, Revision 2.
Appropriate inspection was being accomplished on the items 4
listed for 100% inspection. The other inspections were performed on a random basis as stated.
We have investigated the concerns expressed by the NRC and feel that it would be prudent to change-the procedure Construction Inspection Planning (CIP) to require 100%
inspection of all other items specified in the referenced procedure and the implementation of mandatory hold points to be inspected individually at the completion of each l
j step of the installation.
PCN No. 4 to WPP/QCI No. 66, Revision 2, was generated July 21, 1978, which provided for requirements for Quality Control inspection and acceptance of sheathing installa-tion on the CIP referenced in WCS Post-Tensioning Proca-dure No. 5.
3.
Bechtel Work Plan Procedure / Quality Control Instruction No. 66, Revision 2, " Post-Tensioning Trumplate and Sheathing Installation and Inspection", provides for properly documenting and dispositioning nonconformances, as required by 10CFR50, Appendix B, Criterion XV, the-Palo Verde Nuclear Generating Station Quality Assurance Manual, Chapter 15 and the PSAR Section 17. LA.15, all entitled, " Nonconforming Materials, Parts or Components".
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At:achzent Appendix 4.
Notice of Violation Page 4 Contrary to these requirements, records for sheathing installed'for concrete placement IC108 indicate a Nonconformance Report was not issued for the existing abrupt alignment change in vertical tendon sheath V-79.
This is an infraction.
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RESPONSE
3.
At the time of the NRC Inspection, the field construction activities related to the sheathing were not complete.
The normal work sequence results in survey verification of the sheathing locations approximately 24 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the placement. This verification is accomplished prior to the next concrete placement and identifies out-of-colerance conditions in both the present and the pre-vious placements. We would expect that the out-of-alignment 2" in 10' rather than 3/4" in 10' as required would have been found during this survey verification.
A Nonconformance Report (NCR) C-C-72 was prepared, dispositioned and approved by Engineering on July 21, 1978 prior to the concrete placement IC109.
Based on the available infor=ation, we do not believe there has been a violation of the Bechtel procedures; however, we have addressed your concerns and initiated Procedure Change Notice No. 7 to verify the location of the protruding vertical sheathing after each concrete placement rather than wait until the final inspections of the next concrete placement.
4.
The APS QA Program as set forth in the PSAR Section 17.1A.17 and the Palo Verde Nuclear Generating Station Quality Assurance Manual, Chapter 17, both entitled,
" Quality Assurance Records", establishes requisites for developing and maintaining sufficient records to provide evidence of activities affecting quality, as required by 10CFRSO, Appendix B, Critorion XVII.
. Contrary to these requirements, sufficient quality assurance records were not maintained as indicated below:
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. Appendix A Notice of Violation Page 5 A.
As indicated in 2. above, mandatory inspection hold points were inspected in a sampling manner, instead of 100% inspection. No quality records, however, _were maintained for even the sampling inspections which would identify items inspected and the date and results of inspections.
B.
Records for inspections of trumplate installation for concrete placement IC108 were not signed-off by Quality Control Engineers prior to the place-ment of concrete.
This is a deficiency.
RESPONSE
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A.
t Our investigation of your finding revealed that the Bechtel Qualtiy Control.Inspectorn were documenting their in-process inspections on a drawing in a manner j
that was not adequate. Since your inspection, Bechtel has implemented a program that provides for adequate 1
communication between shifts and shows what inspections l
have been completed.
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4.
B.
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The results of our investigation indicates that the items in question were (1) Task No.1.1, " Replace Plastic Plugs with Thread Protectors" and (2) Task No. 9.3, "WCS Certificate of Inspection Completed".
1 Both of these items were for the previous concrete i
placement IC108 and they were signed-off on July 14, i
1978 and July 20, 1978. Item (1), Task No.1.1, cannot I
be done until after the concrete placement. Item (2),-
i Task No. 9.3, also cannot be done until after concrete placement and was held open pending the return of the WCS Representative to the jobsite to correct an error in the number of the concrete pours by WCS on the certificate. This was completed on July 20, 1978.
l Based on the information available, we believe that Item 4.B was not a violation of the procedures and, therefore, not_a deficiency.
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UNITED STATES c,
.[4 NUCLEAR REGULATORY CO,'. MISSION y-I REGION V
{4 SulTE 202. WALNUT CREEK PLAZA D
g 1990 N. CALlPORNIA BOULEVARD 9***e*g' o
t W ALNUT CREEM. CALIFORNI A 94596 AU2 4F2 i
Docket Nos. 50-528, 50-529 50-530 Arizona Public Service Company P. O. Box 21666 Phoenix, Arizona 85036 Attention: Mr. E. E. Van Brunt, Jr.
Vice President, Construction Projects and ANPP Director Gentlemen; i
Subject:
NRC Inspection - Palo Verde Units 1, 2 and 3 This refers to the inspection conducted by Messrs. L. J. Garvin, L. E. Vorderbrueggen and T. W. Bishop of this office on July 14-21, 1978 of activities authorized by NRC Construction Permit Nos. CPPR-141,142 and 143, and to the discussion of our findings held by Mr. Garvin with you and other members of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the enclosed
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inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, inter-views with personnel, and observations by the inspectors.
Based on the results of this inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, j
as set forth in the Notice of Violation, enclosed herewith as Appendix A.
The items of noncompliance have been categorized into a level as de-scribed in our correspondence to all NRC licensees dated December 31, 1974.
This notice is sent to you pursuant to the provisions of Section 2.201, of the NRC's " Rules of Practice," Part 2. Title 10. Code of Federal Regulations. Section 2.201 requires you to submit to this office, within thirty (30) days of your receipt of this notice, a written state-ment or explanation in reply including (1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full a
AUG 4 1973 -
. : Arizona Public Service Company Additionally, in your reply please describe compliance will be achieved.
in particular those actions taken or planned to strengthen management control of your construction activities to assure that they are accomplished in accordance with design requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice,"
Part 2 Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Pub to be proprietary, it is necessary that you submit a written application Document Room.
to this office, within 30 days of the date of this letter, requestingThe application j
that such.information be withheld from public disclosure.
must include a full statement of the reasons why it is claimed that the The application should be prepared so that i
information is proprietary.
any proprietary infonnation identified is contained in an enclosure to the application, since the application without the enclosure will also If we do not hear from you in be placed in the Public Document Room.this regard within the speci l
the Public Document Room.
j Should you have any questions concerning this inspection, we will be glad to discuss them with you.
Sincerely, du G.
S.- Spencer, Chief I
Reactor Construction and Engineering Support Branch
Enclosures:
A.
'B.
IE Inspection Report Nos. 50-528/78-05, 50-529/78-04 50-530/78-04 9
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1 APPEiiDIX A i
l Arizona Public Service Company
'l P. O. Box 21666 Phoenix, Arizona 85036 i
Docket No. 50-528 j
NOTICE OF VIOLATION Based o'n the results of the inspection conducted on July 17-21,1978, it l
appears that certain of your activities were not conducted in full compliance with NRC requirements as indicated below.
1 On July 19 end 20,1978 NRC inspectors examined Unit 1 post-tensioning trumplate and sheathing installation and inspection activities.
The following conditions were identified:
i l
1.
Bechtel Work Plan Procedure / Quality Control Instruction No. 66, i
Rev. 2, " Post-tensioning Trumplate and Sheathin0 Installation and.
Inspection," provides for accomplishing work in accordance with 1
specified procedures, instructions, and drawings, as required by 10
{
CFR 50, Appendix B, Criterion V, the PSAR Section 17.lA.5, and the l
Palo Ver.ie Nuclear Generating Station Quality Assurance manual Chapter 5, all entitled " Instructions, Procedures, and Drawings."
t j
Contrary to these requirements, the following examples of non-conforming work were observed:.
A.
Vertical and horizontal tendon sheaths installed for placement l
No. IC109 were wire tied at intervals greater than the maximum interval of 3'6", specified in WPP/QCI 66.
l.
I B.
Six trumplate extensions were found to be unwired at their
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ends contrary to the requirements of WPP/QCI 66.
1 C.
Two vertical sheaths (the 17th and 19th clockwise from 'the i
center of the equipment hatch) were found to be out of align-1 ment by 2" in 10 feet, whereas drawing 13-C-ZCS-175 Rev. 2, DCN 1 specifies a maximum misalignment of 3/4" in 10 feet.
D.
Horizontal sheaths above the equipment hatch were found to be within 1-1/2" of each other, whereas drawing 13-C-ZCS-175, Rev. 2. DCN 1 specifies a minimum clearance of 3" in this area.
This is an -infraction.
).
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5 2
Appendix A E Arizona Public Service Company Docket flo. 528 j
l 2.
Bechtel Work Plan Procedure / Quality Control Instruction No. 66, Rev. 2. " Post-tensioning trumplate and Sheathing Installation and Inspection," provides for the performance of acceptance inspections, i
j-as required by 10 CFR~50, Appendix B, Criterion X, the Palo Verde Nuclear Generating Station Quality Assurance Manual Chapter 10, and
)
_ the PSAR Section 17.lA.10, all entitled " Inspection."
Contrary to these requirements, mandatory inspection hold points for the drilling of sheathing vent holes, installation of vent i
piping, wiring of sheathing, and positioning of sheathing were performed in a random sampling manner instead of the full coverage, required by WPP/QCI 66.
This is an infraction.
3.
Bechtel Work Plan Procedure / Quality Control Instruction No. 66, Rev. 2. " Post-tensioning Trumplate and Sheathing Installation and Inspection," provides for properly documenting and dispositioning nonconformances, as required by 10 CFR 50, Appendix B, Criterion XV.
the Palo Verde Nuclear Generating Station Quality Assurance Manual F
Chapter 15, and the PSAR Section 17.lA.15, all entitled " Nonconforming Materials, Parts, or Components."
Contrary to these requirements, records for sheathing installed for concrete placement IC108 indicate a Nonconformance Report was not i
issued for the existing abrupt alignment change in vertical tendon sheath V-79.
This is an infraction.
4.
The APS QA program as set forth in the PSAR Section 17.lA.17 and the Palo Verde Nuclear Generating Station Quality Assurance Manual Chapter 17, both entitled " Quality Assurance Records," establishes requisites for developing and maintaining sufficient records to l
provide evidence of activities affecting quality, as required by 10 CFR 50 Appendix B, Criterion XVII.
U
Appendix A Arizona Public Service Company Docket No. 528 I
Contrary to these requirements, sufficient quality assurance records were not maintrined as indicated below:
A.
As indicated in 2 above, mandatory inspection hold points were inspected in a sampling manner, instead of 100% inspection.
No quality records, however, were maintained for even the j
sampling inspections, which would identify items inspected, j
and the date and results of inspections.
B.
Records for inspections of trumplate installation for concrete placement 1C108 were not signed off by Quality Control Engineers prior to the placement of concrete.
l This is a deficiency.
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U. S. NUCLEAR REGULATORY COLSION 0FFICE OF INSPECTION AND ENFORCEMENT i
50-528/78-05 REGION V 50-529/78-04 Report No. 50-530/78-04 Docket No. 50-529. 529. 530 License NoCPPR-141.142 & 143 Safeguards Group i
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Licensee:. Arizona Public Service Company P. O. Sox 21666
' Phoenix, Arizona 85036 Facility Name: Palo Verde Units 1, 2 and 3 3
Inspection at: Palo Verde Site. Maricopa County. Arizona i
Inspection conducted:
July 14-21.1978 Inspectors:
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9 78 L. J. Garvirf, Rea tor Inspector Date% Signed i
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- 41. )df p Vord egcen, Reactor Inspector Date (sned
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ndia, O e A 78 4
T. W. Bishop, React %r Inspector
/ at's signed D
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Approved By:
N G. S. Spencer, Ohtef, Reactor Construction and Data Signed 1
Engineering Support Branch j
Summary:
j Inspection on July 14-21,1978 (Report No. 50-528/78-05, 50-529/78-04 1
50-530/78-04 l
Areas Inspected: Routine, unannounced inspection of construction
{
activities including: Follow-up items, tour, audits, nonconforming l
reports, containment welding, tendon sheath installation, drawing control and pipe welding. The inspection involved 90 inspector-hours
)
onsite by three NRC inspectors.
Resul ts: Four items of noncompliance were identified in the area of tendon sheath installation and inspection.
No items of noncompliance or deviations were identified in the other areas inspected, b
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1 6 ins;\\,O RV Form 219 (2).
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DETAILS _
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1.
Persons Contacted
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- E. E. Van Brunt, Jr., Vice President / Project Director
- J. A. Roedel, Quality Assurance Manager
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- W.' M. Petro, ANPP Construction Manager l-
- R. L. Robb, Assistant Project Director-
- B. S. Kaplan, Quality Systems Supervisor
- W. E. Ide, Quality-Systems Engineer D. D. Webster, Quality Assurance Engineer l
G._ Pankonin, Quality Assurance Engineer
- R. D. Forrester, Quality Assurance Engineer Bechtel Power Corporation W. G. Bingham, Project Engineering Manager i
J. A. Packard, Field Construction Manager
- S. M. Nickell, Project Superintendent l
- A. K. Priest, Project Field Engineer l
S. R. Abraham, Resident Engineer
- J. E. Braun, Quality Assurance Engineer
- C. F. Gaither, Field Project Engineer l
J. R. Beers, Lead Civil Engineer M. McCormick, Assistant Project Field Engineer l
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- H. P. Smith, Project Field Q.C. Engineer L. Afek, Lead Mechanical Engineer G. Pattan, Auxiliary Building Area Engineer t-R. Rubick, Containment Area Engineer R. Maturani, Field Weld Engineer _
M. Valdo, Group Leader Welding Engineer j
L. B. Mayville, Assistant Welding Superintendent.
R. McConkey, Lead Field Welding Engineer s
l L. Blackburn, Quality Assurance
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L. Wikie, Quality As:urance Engineer j
M. Creager, Civil Engineer (Containment)
E. Kovacevich, Field Engineer - Codes and Standards G. Beaugrand, Field Engineer - Codes and Standards.
R. Randels, Construction Liaison Engineer.
G. Engels, Field Engineer - Piping G. Patton, Lead Field Engineer - Mechanical V. Ducket,. Lead Field Engineer'- Mechanical Western Concrete C. Spievak, QC Inspector
- Denotes those present at the exit interview.
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2.
Licensee Action'on previous Inspection Findings a.
(0 pen) Noncompliance (50-528/78-03): A Marathon drawing change notice was not distributed to or used at the location where the work was being performed.
i Although the licensee's written response to _ the Notice of Violation had not been received as of the current inspection, preliminary constructor's action had been completed, and was examined. As corrective action, the constructor had revised WPP/QCI 3.0, " field Control of Design Documents," to allow area engineers (AEs) to determine where, and to whom, individual document changes are to be issued. This action creates some concerns in that incomplete, and out-of-date, drawings are now allowed to be in the field. A sampling of 25 drawings in use in the field revealed seven which did not include the latest changes.
It is also noted that the AE is not required to document the issuance of individual changes so that it is not possible to effectively audit the revised document control program. The above concerns were acknowledged by licensee representatives. This item will be further examined upon receipt of the licensee's written response to the Notice of Violation.
b.
(Closed) Open Item (50-528/78-03): Non-rotating equipment in storage did not have procedures defining storage requirements.
The procedure has -been developed and observed equipment appeared to be stored acceptably.
c.
(Closed) Open Item (50-528/78-03): An inspection manual has been prepared to organize the pipe welding inspection procedures.
d.
(Closed) Open Item (50-528/78-03): Pipe welding QC inspectors have received training in the procedures contained in the pipe welding inspection manual.
e.
(0 pen) Open Item (50-529/78-02): The Unit 2 reactor vessel was dropped at the manufacturer's shop while being moved between work stations. Volumetric examination of welds will be performed to assure that no hidden damage resulted.
f.
(Closed) Open Item (50-528/78-03): A provision allowing inprocess inspection documentation has been incorporated into QCI 2.4.
g.
(Closed) Open Item (50-528, 529, 530/78-01):
Rejection of major component hold-down bolts.
2 NRC CC713 was initiated to evaluate the subject of the improper installation of several of the hold-down bolts. The bolts were accepted-as-is (due to sufficient strength). The NCR will remain open to assure that proper attention is given the tensioning of the bolts.
h.
(0 pen) Open Item (50-528/78-04):
Existing procedures for translating engineering directions noted on SDDR's to con-struction or QC forces are inadequate. Procedures were being revised to incorporate provisions to assure that the construction forces were informed.
i.
(0 pen) Open Item (50-S28/78-03): Seismic qualif t' cation of Uni-Strut electrical tray supports. This item was not inspected.
J.
(0 pen) Open Item (50-528/78-04): Codes and standards used in the construction of the containment lines.
Discussions were held with the licensee regarding the con-struction codes and standards used in containment lines erection.
The licensee was still developing a list to be submitted to the Region V office.
k.
(Closed) Open Item (50-528/78-04): Containment welder records.
Records of containment liner welder identity were not sufficient in all cases to identify the exact areas welded by each welder.
"As-built Welding Control System" Procedure WPP/QCI 101.4 was developed to correct this problem.
1.
(Closed) Open Item (50-528/78-04): Radiographic examination of containment liner welds. The licensee stated that the PSAR reference to regulatory guide would continue to be in force.
3.
Construction Status The licensee reported that Unit 1 was 26.8%, Unit 2 wac 6.3%, and Unit 3 was 0.5% complete as of July 1,1978. The overall project was reported to be 12.3% complete.
4.
Facility Tour Equipment storage, housekeeping, concrete curing, reinforcing steel placement, backfilling, pipe welds, equipment installation and cable tray installation were observed.
Several large nuts were noted laying in the dirt without thread protection near primary coolant pump hold-down bolts in Unit 1.
Before the end of the inspection, the threads had been protected and the nuts were attached to the pump hold-down bolts.
No other items of concern were noted.
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4 5.
- Containment Liner Welding Welding on the first ring of: Unit 2 containment liner was visually examined. Also examined were horizontal and vertical seams on rings 9,10 and 11, uni-strut welded to liner, crane rail support attachments and welding on penetrations in the containment of Unit 1.
I The welder identity markings on Unit 2 seemed to be sufficient to trace the welder qualification and testing records. On the upper rings of the Unit 1 containment, the welder identity markings had 1
improved so that identity was easily traced (Ref. Report 50-528/78-04).
For the most part, the welding that was visually examined appeared to meet requirements.' The areas that did not meet require-ments had not been inspected by the quality control inspectors.
Radiographs of. approximately ten feet of liner plate welds were examined. No anomalies were noted.during -the examination.
s 6.
Containment (Prestressing System)
I-a.-
Review of Quality Implementing Procedures Installation Specification No.'13-CM-37, Rev. 2, and Work Plan Procedure / Quality Control Instruction No. 66. Rev.2, for the 4
post-tensioning trumplate assemblies and sheathing were ex-amined with the.following items noted.
V (1) The Construction Inspection Planning (CIP) sheets attached to WPP/QCI 66 do not clearly reference each of designated t
U inspection hold points listed.in the procedure.
The l
CIP's are used to document required inspection activities.
(2)
Inspection descriptions in the CIP are misleading, for example, one description reads " Replace ' plastic plugs with thread protectors,".whereas the referenced procedure paragraph (3.1.1 of Exhibit 660-5) deals with the posi-tioning of trumplates, deformations, installation of mounting bolts, tightners 'to forms, and rust.
(3) Designated inspections are not listed on the CIP.
For 4
example, the inspection of vents and drains (Paragraph 3.1.5 of Exhibit 66.0-5) is not listed on the CIP.:
i (4) The CIP calls for inspections which are not required and cannot be readily performed. For example Item 9.1 of p
Exhibit 66.0-6 calls for post concrete placement inspection of. sheathing positioning, alignment and-installation, h
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, -. -..,,,... ~ ~.. -
referencing Paragraph 3.1.4 of Exhibit 66.0-5.
Para-graph 3.1.4 calls for pre-concrete placement inspection of sheathing position and alignment, wire tie-offs, and taping of sheathing couplers. These inspections cannot be readily performed after concrete placement.
b.
Observations of Work and Work Activities 4
Unit 1 trumplate, trumplate extension, and sheathing instal-lation activities were observed.
The installation was in preparation of concrete placement No.1C109.
The activities inspected included sheathing positioning and alignment, wire tie-off, coupler taping, vent line installations, sheathing condition, and inspection coverage. The observations were conducted on July 18, 19, and 20, 1978. Many items of in-complete work were observed on July 18 and 19. The concrete
. jump forms had only been' positioned on a portion of the i
containment at that time. The inspector was advised by constructor representatives that most of the incomplete items would be completed prior to final form positioning. However, 1-on July 20 -1978, after form positioning was completed, numerous J
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items of incomplete work were found to be still in existance.
In addition, several items contrary to the requirements of specifications, procedures, and drawings were observed.
These included:
4 (1) Vertical and horizontal sheaths in each of the buttresses were tied at intervals greater that the maximum interval of 3'6" specified in WPP/QCI 66.0.-
It was noted that action had been taken to correctly tie the sheathing toward the top of the forms, but sheathing at the bottom was found to be untied for distances up to eight feet.
Numerous other-improperly tied vertical and horizontal sheaths were identified to licensee and constructor representatives.
l (2) Six trumplate extensions were found to be unwired at their ends contrary to the requirements of WPP/QCI 66.0.
(3) Fittings, which appeared to be non-galvanized, were installed in the vent lines Nos. H21-023, and H21-025.
WPP/QCI 66.0 specifies the use of galvanized fittings.
l The fittings in question were subsequently removed and replaced with galvanized fittings.
j (4)' Two vertical sheathings (the.17th and 19th clockwise from the center of the equipment hatch) were found to be i
firmly wired in position, yet out of alignment by two inches in ten feet, whereas Drawing 13-C-ZCS-175, Rev. 2 DCH.1 specifies a maximum misalignment of 3/4" within ten feet.
4
i (5) A hole was found in the lowest visible horizontal sheath at a location approximately ten feet to the left of buttress No. 3.
This hole was reportedly repaired, but upon observation by the inspector was found to be un-repaired.
The hole was subsequently repaired.
(6) Horizontal sheaths above the equipment hatch were found to be firmly wired in position, yet they were within 1-1/2" of each other, whereas Drawing 13-C-ZCS-175, Rev. 2 DCN 1 specifies a minimum clearance of three inches in this area.
(7) Vertical tendon sheath No. V-79 was found to have an abrupt change in alignment of approximately three inches.
This sheath was installed in conjunction with the previous concrete lift (No.1C108) on July 7,1978.
Tolerances in effect at that time limited misalignment to + 3/4 inch.
This tolerance was subsequently changed to +I3 inches, but with no abrupt changes.
Discussions with cognizant Quality Control and Field Engineers on July 19, 1978 revealed that mandatory in-spection hold points were not executed as required by WPP/QCI 66.0, Rev. 2.
Specifically, the engineers stated that the hold points for drilling of vent holes, instal-lation of vent piping, wiring of sheathing, and positioning of sheathing were inspected on a random basis only.
It was also reported that no irprocess records of the random inspections were generated. Accordingly, it is not possible to identify which items were inspected, even on the random basis.
It was noted also, that WPP/QCI 66.0 specifies that inspections for position, alignment, vents, and tie wiring are to be conducted prior to placement of the concrete forms. Contrary to this requirement, the forms were positioned in place on July 20, 1978 prior to completion.
c.
Review of Quality Records As of noon, July 20, 1978, no quality records had been generated for the sheathing installation associated with Unit 1 containment
. wall placement No. IC109, despite the fact that the placement was planned for the night of July 20, 1978. As noted in Paragraph 6.b, Quality Control Engineers had not documented their inprocess inspections or hold point inspections performed on the sheathing installation.
The lack of inprocess inspection records, and documentation of those inspection hold points that were inspected, is contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVII and the PSAR Section 17 which require inspection records.
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The Construction Inspection Plan (CIP) addressing (sheathingNo.1C1 installation for the previous concrete placement J
was' examined.
It was noted that both Survey and Field Engineering had signed-off the CIP indicating correct sheathing (tie-wiring, taping, etc) was verified after concrete placement.
4 It is not clear how such an inspection could have been performed.
I It was further noted that no Nonconformance Report had been 1
issued for the abrupt change in alignment existing in vertical sheath V-79. The failure to properly document the nonconforming condition to prevent its inadvertent use is contrary to the requirements of 10 CFR 50, Appendix 8. Criterion XV and the PSAR Section 17.
7.
Safety Related Piping During a tour of the auxiliary building, several installed piping 1
sections were seen to have shrinkage distortions that appeared to 4
be associated with welds joining individual shop-furnished spools.
One of particular interest was associated with a 20-inch LPSI j
system spool No.1-SI-194-S-105 at the 40-foot elevaticn in the auxiliary building. Two other spools in the outdoor storage yard j.
which appeared to have similar weld strinkage condit ons were also d
1 i
examined. These were 24-inch, schedule 30, 0.562-inch wall thickness j
spool No. 1-51-307-5-005, and 20-inch schedule 20, 0.375-inch wall i
thickness spool No. CH-142-S-011.
Upon further investigation, it j
was learned that this weld shrinkage condition had been an item of concern to Bechtel and NCR No. PA-126 was issued on December 14, t
1977 to investigate the situation.
Bechtel performed an engineering 4
i -
analysis of the distortion configuration to determine its effect on j
flow characteristics and joint stresses, and destructively analyzed i
typical specimens for metallurgical attributes.
In addition, personnel from Bechtel, Combustion Engineering and Nuclear Engineering Services met with the supplier, Pullman Power Products, to discuss the matter and resolve any issues associated with surface preparation l
to properly provide for. in-service inspection.
According to Bechtel personnel, the shrinkage distortion phenomenon is associated only with large diameter, thin wall stainless steel pipe and is caused by the application of weld overlay to the outside i
surface of the spool piece and, when necessary, the weld overlay process is the approved method for satisfying specification re-
- quirements pertaining to I.D. and wall thickness dimensions subsequent to the weld prep counterbore operation.
Bechtel concluded from their analyses that flow characteristic and stress level effects t
were well within design margins, that the shrinkage distortion did not impair the-perfomance 'of ISI and radiographic examination, and i
that the distortion was metallurgically acceptable.
The inspector
. agreed that ASME code requirements were not compromised, and informed 2
I the licensee that the subject was considered closed.
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8.
Safety Related Structures The inspector examined the foundations for the Train A safety injection pumps and the records associated with the installation.
Concrete placement 1A05 served the HPSI pump and placement lA06 was for the LPSI The records included the Construction Inspection Plans (CIP's) pump.for concrete preplacement, placement, and post-placement, concrete delivery tickets, and cylinder break strength test reports. No anomalies were noted.
9.
Exit Interview At the conclusion of the inspection, a meeting was held with the licensee and contractor representatives denoted in Paragraph 1.
Tne areas covered during the inspection, and the observations and conclusions of the inspectors were reviewed.
The inspectors ex-pressed strong concern in regard to quality systemt that allowed the tendon sheath installation to deteriorate to the level _found by the inspectors. The inspectors also expressed concern that the Bechtel and APS Quality Assurance site groups had not taken action on July 19 or 20th when it was apparent that extreme corrective action was nc:essary.
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,4 umTED STATES k
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NUCLEAR REGULATORY COMMISSION j
REGION V tse0 N. CALIFORNIA SOULEVARO g-
%, ** V /a sulTE 202.WAL*iUT CREEK PLAZA CE O WALNUT CMEEM. CALIFORNIA 94808 Docket Nos. 50-523, 50-529, 50-530 AUG E2 GSO Arizona Public Servka Company P. O. Box 21566 1
Phoenix, Arizona 85036 i
Attention: Mr. E. E. Van Brunt Jr., Vice President j
Nuclear Projects Management Gentlemen:
Subject:
NRC Regional Evaluation of Licensee Performance Palo Verde Units No. 1, 2 and 3 1
i This refers to the meeting held at the Arizona Public Service Company's Office l
in Deer Valley, Arizona on June 10, 1980, between Mr. R. H. Engelken and members i
of the Region V staff wit.h Mr. E. E. Van Brunt, Jr., and other ANPP principal j
staff personnel. The purpose cf this meeting was to discuss the results of
{
NRC't regional evaluation of licensee perfornance regarding activities authorized by NRC Construction Pemit Nos. CPPR-141,142 and 143. A copy of this evaluation and supporting data are enclosed for your information.-
Items discussed during the meeting included a description of NRC's program for evaluation of licensee perfomnce, a sununary of the findings and evaluation p
j of the NRC regional review board regarding compliance with NRC requirementt at Palo Verde Units Nos. 1, 2 and 3 during the period May 1979 througn May
{
1980, and reporting requirements of 10 CFR 50.55(e).
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed report will be placed in the NRC's Public Document Room.
)
Should you have any questions concerning this report, we will be glad to discuss them with you.
b Sincerely, i
do,e 1
R. H. Engelken Director
Enclosures:
1 IE Inspection Report Nos. 50-528/80-11 1
50-529/80-11 i
50-530/80-11
, um F0fA-H-133 Y,'
G39 o
-s U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION V Report Nos. 50-528/80-11, 50-529/80-11 and 50-530/80-11 Docket Nos. 50-528, 50-529 & 50-530 License Nos. CPPR-141, CPPR-142 & CPPR-143 Licensee: Arizona Public Service Comoany P. O. Box 21666 i
Phoenix, Arizona 850~6 Facility Name: Palo Verde Nuclear Generating Station - Units 1, 2 and 3 Management Meeting at: Licensee's Headquarters Office, Phoenix, Arizona Meeting Conducted: June 10, 1980 m
Pho/Po
Participants:
[
R. H. Engelken, Director Date Signed
),
f/
olP G. S. Spencery Chief Date Sign' d e
Reactor Construction & Engineering Support Branch JMJ r/.e /n m.
L. E. Vorcerorueggen, Date Signed
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Resident Reactor Inspector Reviewed By:
7/4
G. S. Spencert', Chief Date Signed Reactor Construction & Engineering Support Branch Suwary:
Manacement Maeting on June 10, 1980 (Recort Nos. 50-528/80-11, 50-529/80-11, 50-530/80-11).
1 Meeting held at the Licensee's corporate office to discuss results of the Licensee's performance evaluation by Region V for the period May 1979 through May 1980; three (3) areas to be given increased NRC attention were identified to the Licensee; reporting requirements of 10 CFR 50.55(e) were also discussed.
yoi, i,
CETAILS 1.
Meetino Attendees a)
Arizona public Service Cemoany E. E. Van Brunt, Jr., Vice President, Nuclear Projects Management J. M. Allen, Nuclear Services Engineering Manager, Elect, and 1
Instrumentation A. C. Rogers, Nuclear Services Engineering Manager, Civil and Mechanical B. S. Kaplan, Quality Systems Supervisor D. B. Fasnacht, Site Construction Manager W. E. Ide, Site Quality Assurance Supervisor b)
NRC-Region V R. H. Engelken, Director G. S. Spencer, Chief, Reactor Construction and Engineering Sucport Branch L. E. Vorderbrueggen, Palo Verde Resident Reactor Inspector 2.
SALP Prcoram Oescriotion The agenda shown on Enclosure A guided the progress of the meeting.
Mr. Engelken explained that one of the NRC action items that resulted frm. studies of the TMI-2 accident was the establishment of a program for Systematic Assessment of Licensee Performance (SALP) with the following stated objectives:
a.
Identify exceptional or unacceptable licensee performance, b.
Improve licensee perfomance, c.
Improve the IE Inspection Program, d.
Provide a basis for management's allocation of NRC resources, and e.
Achieve regional consistency by evaluating licensee performance from a national perspective.
To implement this program, a femal appraisal process has been developed for the Regional Offices consisting of semi annual evaluations of licensee performance. These evaluations are conducted by a Review Board made up of individuals who are involved in the inspection and licensing activities pertaining to the licensee, i.e., resident inspectors, regional inspectors, regional managers, and, as appropriate, NRR project managers. The perfomance evaluations are intended to judge the licensee's technical and management perfomance, and his safety attitude in selected areas covered by the IE inspection program. The evaluations consider inspection findings, enforcement history, licensee event / deficiency reports, and the collective judgement of the inspectors and managers who are knowledgeable of the licensee's activities. The evaluation results, along with a proposed action plan defined by regional management, is fomarded to IE Headquarters for appraisal by a senior SALP Review Group. The Regional Office is to hold an annual meeting with licensee management to discuss the results of the evaluations and identify those areas of the licensee's operation which demonstrate a need for improvement and additional inspection attention.
e
. L.
4 l
3.
Perfomance Evaluation Results Mr. Spencer identified the individuals composing the Regional Review Board and sumarized the perforance factors considered in the review (Enclosure B). He stated that the evaluation results indicated generally
+
satisfactory perforance by the licensee, and that continued strong effort by the licensee and the other project participants should ensure adequate control of future work activities. Three areas were identified where I
NRC inspection effort will be intensified and the reasons therefore.
They are component storage and maintenance after warehouse release for construction, pipe hangers and supports, and, containment dome liner l
installation for Units 2 and 3.
Also, since good control has been demon-strated in regard to substructure foundations and concrete. NRC plans to deemphasize the inspection effort in these areas. The licensee was also cautioned to continue close control of vendors and subcontractors in order to avoid problems similar to those which have occurred on other nuclear plant projects.
4 10 CFR 50.55(e) Reoortino At the licensee's request, a discussion was conducted in regard to the recently issued NRC guidance on reporting of items that may have potential 50.55(e) significance. The licensee was provided clarification in regard to oral and written report timing, and how the 14-days allowed for investigating the " potential" of an item factors into the reporting i
process. The need for documenting the reportability review by the licensee l
was also discussed.
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t.M c L O S URE n
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AGENDA
- ,.,i LICENSEE
- Arizona Public Service Company FACILITY: Palo Verde Nuclear Generating Station DATE AND TIME OF MEETING: June 10, 1980, 1:00 p.m.
LOCATION: APS Headquarters, Phoenix, Arizona
SUBJECT:
NRC REGIONAL EVALUATION OF LICENSEE PERFORMANCE FOR THE PERIOD OF MAY 1979 THROUGH MAY 1980 l.
Introduction - R. H. Engelken, Regional Director, NRC:RV 2.
Ce'scription of NRC's Systematic Assessment of Licensee Perfomance (SALP) - R. H. Engelken 3.
Identification NRC:RV Review Board members, statement of scope and general conclusions - R. H. Engelken 4.
Summary of findings of current review -
G. S. Spencer, Chief, Reactor Construction and Engineering Support Branch a.
Enforcement history b.
Bulletins, reporting c.
Changes in NRC inspection program 5.
Specific areas of concern - G. S. Spencer and L. E. Vorderbrueggen 6 ~. Questions / comments - all
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UNITED STATES l ,
NUCLEAR REGULATORY COMMISSION
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3 REGION V o'
O 1990 N. CALIFORNIA BOULEVARD
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SUITE 202. WALNUT CR EEK PLAZA WALNUT CasEK. CALIFORNfA 94S96 MEMORANDUM FOR:
G. S. Spencer, Chief, Reacto/ Construction and Engineering Support Branch FROM:
Regional Evaluation Review Board - Palo Verde
SUBJECT:
SEMI-ANNUAL REGIONAL EVALUATION OF PALO VERDE
, UNITS 1, 2 AND 3 The Regional Evaluation Review Board for Palo Verde met on May 30, 1980, to perfom the evaluation of project activities for the period of May 1979 through May 1980. The board reviewed the following areas:
a.
Previous enforcement actions and results (including escalated enforcement actions).
b.
Licensee's responsiveness and ability to execute corrective actions identified by the NRC and licensee management systems.
c.
Licensee actions in the area of IE Bulletins, licensee event (Part 21 and 50.55(e)) reports.
It is the opinion of the Board, based on the results of the review..
that the licensee's perfomance is generally satisfactory and that I
strong effort by the 7fcensee should continue to ensure that current and future work is adequately controlled.
In addition, it is the opinion of the Board that NRC:RV inspection efforts should be increased in the areas of containment dome liner installation, piping hangers and supports, and component storage and maintenance. Rationale for these actions is provided in the enclosed Palo Verde Evaluation Form.
I
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- G. S. Spencer Licensee actions related to IE Bulletins and licensee event reports were generally satisfactory. No specific change in licensee programs or NRC inspections in these areas is recomended at this time.
Regional Review Board Members:
5 R. T. Dodds, Chief. Engineering Support Section irl J/A /f rt. Eckhardt, Resctor Inspector k
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l E. Vorderorueggen,/ Resident Inspector
Enclosure:
Palo Verde Evaluation Fom for Appraisal P.eriod 5/79-5/80 l
i e
i MC 2955 l E.
Manaoement Conferences Held During Past Twelve Months 5/11/79 Meeting held in Region V office concerning Unit I dome liner plate.
I F.
Justification of Evaluations of Functional Areas Categorized as Recuiring an Increase in Insoection Frequency / Scope (See evaluation sheet)
. Containment Dome Liner Installation - Units 2 & 3 On Unit 1, severe misfit of dome segments led to Region V concern, and development of additional procedures and construction tolerances to prevent building in high residual stresses in the liner plate.
Pioing Hangers and Supports To date there have been occasions where weld sizes have not been in compliance with requirements.
In addition, 50.55(e) reports have identified problems with support design and welding. This is not just a Palo Verde problem, but appears to be industry wide and needs additional inspection effort.
j Comoonent Storage After Warehouse Release Problems have been encountered with leaving pipe openings uncovered, installed equipment improperly covered, pipe spools and weld electrodic carelessly handled / controlled.
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5.0.: i'5.
Inspection
.Frecuenc: amiJor Scoce TCICTIC;!.\\f. MI.\\
Incr:ssc No. Change Decrease 1.
Qiaa t i:7.isaurance..'!snsgesant Fu Training y.
2.
Substructure a 1'mindations y
i 3.
canereta X
4.
Liner (Cont.sinment & Others)
K(Dome Lineh 3
s.21 sty.-etat.ec :structuren y
. rip :g a rtangers (Maactor Coolant
/Hangersand
& Others) g\\ Supports /
7.
Safecy-Related Compoannts (Vessel, Internals & EVAC) y 8.
Elert.rical Equiprnent, y
i 9: Electrical (Tray & Wire)
X 10.
Instrument.2 tion X-l
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11.
Fire Protect. ion Y
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- 12. Preservice Inspection X
- 13. Reporting y
14.
Storage / housekeeping X
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- !C 2055 APFEITDI'( B REGION V
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(.,TCE);.y,dB PEFIOPf_t;CE IV.U.IfATICN(CONSTRUCT, TON)
F.u:ll f Lf:
Palo Verde Nuclear Generating Station T.icensee:
Arizona Public Service Company t!ait. Identification:
Units 1, 2 and 3-Docket No.
CP 1To. /D. ate, ot' Issuance U_ pit. No.
CPPR-141 - May 25, '1976 1
50-528 50-529 CPPR-142 - May 25, 1976 2
50-530 CPPR-143 - May 25, 1976 3
1' Reactor Infor: nation:
Unit 1 Unit 2 Unit 3 21555 CE(System 80)
CE(System 80)
CE(System 80) i
.%'t 3800 MWt 3800 MWt 3800 MWt 1307 MWe 1307 MWe 1307 MWe j
Appraial Feriod:
May 1979 - May 1980 (Inclusive)
Appealsal Completion naLc:
May 30, 1980 Review P.o.seil !t lser::
R. T. Dodds, Chief, Engineering Support Section J. H. Eckhardt, Reactor Inspector L. E. Vorderbrueggen, Resident Inspector b'
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Number seul ! sture e,f No:co 2nl1.ini e Itces NonenriLiance catagory:
!! nit 1 Ugi,LJ Unit 3 Violations 0
0 0
infractions 5
3 0
2 1
0 Deficiascins Areas of Nonccmpliance:
Unit 1 Unic 2 Unit 3 (List Areas As Required)
( Po i n t.n).
(Points)
(Points)
See attache'd chart.
50 30 0
Totsi Points Ni2=ber and !!atur,q,of, Deficiese r Reports See attached chart.
i C.
Bulletins I
All applicable bulletins have been responded to in a satisfactorially and timely manner.
D.
Escal.stod Eni*orrement Actions Civil Pensl Lie,s, None Orders None I rseiliate Act iun T.ct.,t.crs Memo of understanding issued 5/9/79 concerning Unit 1 dome liner plate (attached).
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J U. S. MUCLEAR REGULATORY CCtHISSICN OFFICE OF INSPECTION AND ENFORCEMENT i
i REGION Y l
Recort Mos 50-523/81-02, 50-529/81-02 and 50-530/81-02 Occket Nos. 50-528, 50-529, 50-530 License Nos. CPPR-141 -142, -143 i
Licensee: Arizona Public Service Company f
P. O. Box 21666 Phoenix, Arizona 85036 Facility Name: Palo Verde Nuclear Generating Station - Units 1, 2 and 3 Inspection at: Palo Verde Construction Site Wintersb'urg, Arizona f
1 Inspection condu
- January 26 - February 5,1981 i
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Inspectors:
I R.' T "Oct:os Team Leaosr Dalia Signed l
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L.~ E. Vorcerbruegged Datv 51gnea' j
Resid nt Reactor In ector j
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//~PMb Ld, eactor Inspector 4A/er
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Datt STgned 1
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P. P. Narou Reactor Inspector Date 51gnec
$ 0.
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(/J. O. Elin, Reactor Inspector Date 5fgneo Approved by:
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7 R. T. Doods Chief Reactor Projects Data' 514nec' Section 2. Reactor Construction Projects Branch Summary:
Inscoction on January 26 - Februarv 5.1981 (Recort Nos. 50-528/81-02. 50-529/
81-02 anc 50-530/81-0Z).
j Areas Inscocted: Special construction assessment team inspection of quality assurance, oesign controls, procurement controls, construction controls and project management of constructior, at the Palo Verde site. The inspection involved 356 inspector hours on-site by five NRC inspectors.
Results: No items of noncompliance were identified. The following perceived strengths and weaknesses were identified.
Fo/A-54-1'W l ti c G Cmo 3N '
Lhe S
St.=ary (c:nt. )
2 I
Perceived Streneths:
(1) Management visibility; (2) management comunicatien witn tne staff / workers; (3) strong QA/QC project image - staff / workers appear i
to be working towards a comen goal for a quality product; and (4) strong construction management.
Perceived Weaknesses: (1) Perfonnance of receiving inspection function (paragraph corponents (paragraph 6.b.(2)); and (3) g or inspection requirements for 5.b.ll)); (z) control of special handlin storage and maintenance of equiperent (paragraph 6.c.(3)).
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CETAILS 1.
Persens Centacted 4
a.
Arizona Public Service Comany (APS)
- E. E. Van Brunt, Jr., Vice President, Nuclear Project Management
- J. A. Roedel, Quality Assurance Manager
- J. M. Allen, Nuclear Engineering Manager
- 0. 8. Fasnacht, Nuclear Construction Manager
- A. Carter Rogers, Nuclear Engineering Manager
- R. J. Kinnel, Field Engineering Supervisor N. E. Ide Site QA Supervisor
- G. Pankonin, QA Engineer
- 0. E. Fowler, QA Engineer Bruce S. Kaplan, Quality Systens Supervisor L. Souza. QA Engineer D. Wittas QA Engineer i
D. flugent, Site Procurement Supervisor R. Forrester, QA Engineer i
b.
Bechtel Power Corocration (Bechtel)
W. J. Stubblefield, Construction Manager
- R. L. Patterson, Division Manager. Quality Assurance
- 0. T. Krisha, QA Panager, Projects
'J. D. Houchen Assistant Project P.anager i
- S. M. Nickell, Project Superintendent
- A. K. Priest, Project Field Engineer
- 0. R. Hawkinson, Project GA Supervisor
- R. M. Grant Project Field QC Engineer J. Black, Resident Engineer J. Pfunder, Pmject QA Engineer R. Doskocil, QA Engineer R. Roehn, QA Engineer R. Rosen, QA Engineer R. Condie, QA Engineer A. Moore, Receiving / Storage QC Supervisor D. Hess, Design Doewent Control Center Supervisor H. Klopp, Project Field Procurement Manager G. Brush, Rod Room Coordinator G. Dannenburg. Unit 1 Superintendent l
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Censustion Engineerino (CE)
S. Mager, Site Manager A. Kalfas, Assistant Site Manager S. Knight. QA Engineer P. De Grief, Internals Installation Supervisor d.
The Waldincer Corocration (Waldincer)
R. Yarges, QA Supervisor G. Clapper, QA Engineer J. Love, Technical Supervisor In addition various field engineers, craftsmen, inspection personnel, and other QA engineers were contacted.
Denotes those attending exit meeting.
2.
Quality Assurance a.
Quality Assurance Program and Program Adecuacy The documentation that establishes and defines the Palo Verds Quality i
Assurance Program was reviewed. These documents included the APS Quality Assurance Manual, the Bechtel Quality Program Manual, the APS Pmject Procedures Manual, and Chapter 17 of the PSAR.
The APS OA Manual contains a policy statement from the APS President and Chief Executive Officer that states "...the management of APS,
... recognizes its responsibility for assuring that the PVNGS is designed, constructed, and ooerated in such a manner as to provide for the health and safety of the public. The importance of quality assurance in contribut.ing to this safety as well as contributing to station reliabi1*'.y is also recognized." QA Directive 2.0 of the QA Manual provides an overall description of the QA Program which consists ',( (1) a forum 1, documented sy(stem of administrative 2 contmls ove activities affecting quality, and (3) ratity assurance.
It defines the QA roles of AP5, Sechtel, and s m liers. The program appears to be adequately defined, interface conto 1 between the various organizations is established, and the lagram description contains a matrix of coenitments to 10 CFR 50 4
Aopendix B requirements. Also, QAD-2.0 provides for the Vica President, Nuclear Project Management,to review the status and adequacy of the QA program annually.
Organization charts are provided in QAD-1.0 that clearly define lines of authority and responsibility. Also, the independence of the QA organization from design and construction is clearly indicated, with 1
3-the APS QA Manager reporting directly to the Vice President, Nuclear frejects Managetmmt. Written position descriptions exist for the President and Chief Executive Officer, the Operations Executive VP, the VP-Nuclear Projects Management, the QA Manager, the Quality Systems Supervisor, and the Site QA Supervisor. These job descriptions appear consistent with the organizational structure and define responsibilities and interfacing.
b.
CualitY Assurance Proorts Implementation Various aspects of the quality assurance program were examinad to verify that the written program is being adequately implemented.
i Specific areas examined included planning, organization, and activity review.
1)
Plannine OA planning was examined to ascertain censistency with project
)
status and adequacy to monitor the project activities in an effective manner. Presently the onsite APS QA organization consists of five QA engineers (QAEs) and a supervisor, plus j
one tenparary QAE. The home office APS QA organization consists of four QAEs and a supervisor. The onsite Bechtel CA organization consists of sixteen QAEs and a supervisor. Although this appears to be an effective nimeer of QAEs for the present i
activities, the projected increased workload due to Unit 1 system turnover and startuo CA activities could possibly result in a decrease in eenitoring of future construction activities.
Also, there is no femal provisicn for providing for a temporary increase in QA a npower. Although no firm plans had been established to increase manpower, the APS QA Manager was aware of the possible i
QA manpower shortage when Unit 1 system turnover and startup activities are undemay, and indicated that provisiens would be made to increase senpower when necessary.
The morale of the QAEs (both APS and Bechtel) appears to be good and is reflected in the high retention rate of QAEs. Approx <mately l
60 percent of the QAEs have been at Palo Verde for three years or more.
The APS and Bechtel QA organizations plan their activities l
based on the projected project activities. Construction schedules and project status reports are utilized for planning activities.
QA also participates in pre-planning of cosplex construction activities such as reactor vessel installation and containment tendon installation. Audit and surveillance schedules are i
then based on this input.
r l
e
, i A review of both APS and Bechtel site QA audit schedules for i
'1960, indicated that audits were perfomed as scheduled.
l l
that schedules are realistic and that the QA staff level is appropriate for presamt activity. The audit checklists appeared l
to be adequately planned and they incorporated previous audit findings and suspected problem amas.
2)
Organization The QA organization as implemented appears to be consistent with the organization as described in applicable manuals.
In the past year no o anization changes had been sede and the tuntover rate of has been low.
I
)
3)
Activity Review In order to verify the implementation of QA activities, the inspector reviewed supporting doctmentation, observed activities, j
and held discussions with QA personnel.
j a)
OA Review of Desian/ Procurement Documents Bechtel sita QA reviews Field Change Requests and field generated Procurement Documents. The review process was discussed with Bechtel and documents are examined to verify that the reviews had been accomplished. Approximately eight to tan FCRs and/or Procurement Documents per week are being reviewed.
i b)
Audits Both the Bechtal and APS audit prograss were examined to ascertain compliance with the applicable QA unuals.
There are three on-sita audit groups who perfom audits of site activities.
APS sita QA perfoms audits of Bechtel's and other contractor's activities.
Bechtel sita QA perfoms audits of Bechtal activities.
Bechtal site QA perfonus audits of subcontractor activities.
The 1980 and 1981 audit schedules for these orgnizations were reviewed and they indicated that all appl' cable elements and subcontractors were audited in 1980 and are scheduled for audit in 1981.
In addition, selected audit reports for 1980 were reviewed. The audit checklists appeared to be comprehensive and applicable to the activity being e
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5-4 audited. The reports indicated that the audits were documented in a tirely manner, exit interviews were conducted, i
and the audit results were comunicated prongtly in writing to the concerned organization.
In addition to the on-site QA audit organizations, the APS home office quality systems organization audits the APS site QA activities as well as auditing Combustion Engineering and Bechtel home office activities. The 1980 and 1981 audit schedules for this organization were reviewed.
The auditor and lead auditor qualification records of Bechtel and APS site QAEs were reviewed to ensure qualification criteria are being met. Also, seven QAEs were interviewed i
to ascertain their understanding of auditing.
c)
Surveillance Both the APS and Bechtel surveillance programs were examined.
APS QA does not have a fomal surveillance schedule but does perform surveillances based on the construction activities in progress, NRC Bulletins and Circulars, Sechtel l
QA Bulletins, and other industry problems. Each of these surveillances is docuranted with a copy given to Sechtel QA if the surveillance results in a finding. All findings are followed up to verify that corrective action has been taken. Sechtel QA perfoms surveillances based on a schedule. Their surveillance schedule for the period of Januan 19 to February 13, 1981 included 20 surveillances.
For 1980, an average of 99 surveillances per month were perfomed by Bechtel QA.
On February 2,1981 the inspector accompanied and monitored a Bechtel QAE during a surveillance of weld rod control in Unit 2 containment. Prior to the surveillance, the QAE reviewed the WPP/QCI regarding weld rod control.
The surveillance consisted of an examination of one rod issue room and a check of rod control for six welders.
It msulted in three findings. The inspector considered the surveillance to have been conducted in a thorough and professional anner. The three findings were corrected on the spot, and surveillance of weld rod control was conducted the next day to ensure a generic problem did not exist.
c.
Management Involvement in 0A Interviews were conducted and records were examined to detemine the extent of eenagement involvement and understanding of QA functions and findings, and also to determine their attitude toward quality and the lange QA has at the project.
- ~ -, - - - -. - - - - - -
.n--
n
.. 1)
Project Originated Recorts
'One inforation channel used by APS c'anagenent to keep informed of CA activities is periodic project originated reports.
These reports include monthly Bechtel QA sumaries, quarterly APS QA susuaries APS and Bechtel audit reports that include findings, and Deficiency Evaluation Reocrts (DER) that result in 50.55(e) items. Additionally,APS QA writes an annual QA report and presents this annual sunnary to the APS President and Chief Executive Officer in a femal meeting.
2)
External Oricinated Recorts i
Management also receives external originated documents including NRC Bulletins and Circulars, NRC Inspection Reports, Bechtel CA Bulletins, and MRC inspection findings from other projects.
Where appropriate, problem area reports are transmitted to QA for action.
3)
Corrective Action i
corrective action was evaluated to determine the effectiveness i
l and influence of QA in the organization. This included corrective action regarding APS audit findings, Bechtel Corrective Action Requests (CAR), and NRC inspection findings and items of nonconpliance.
The followup systems to verify corrective action were also examinea.
Corrective action appeared to be timely and included long term corrective action as well as inmediate short tenn action.
In addition, the effectiveness of stop work orders was examined.
l In 1980, ten stop work notices were issued and they appeared to have been supported by construction anagement.
I 4)
Regulatory Interfacinc During NRC inspections, the QA Manager keeps informed on a daily basis of the progress of the inspection and is responsive to any NRC concems or findings. He also attends all NRC exit meetings. Also, the APS Vice President, Nuclear Projects Management, attends approximately 90 percent and the Bechtel Construction Manager approximstaly 50 percent of these meetings.
l 5) h It appeared that APS upper management and Bechtel construction annagement projected a strong positive attituda toward quality.
Interviews with QA and construction personnel indicated this same attitude with respect to the QA organization, realizing that they are a meaningful part of the construction function, i
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. The APS QA l'anager and Vice President, Nuclear Project Management
' visit the site frequently (usually more than once a week) and make their presence known to both construction and OA personnel.
These site visits include comunicstion with the QA personnel concerning the role of quality.
Additionally, the lines of comunication between APS management, CA, Bechtel construction management QC, and the craftsman appear to be very effective. All personnel interviewed indicated that pmblems could be readily discussed with nonagement and l
effective action would be taken if necessary.
i 3.
Desien Controls - Site i
n.
Procram The organizations involved in the design of the Palo Verde plant are as follows:
NS$5 - Con 6ustion EngineeHng. Inc.
HVAC - The Waldinger Corporation A/E & 80P - Bechtel Power Corporation j
All design activity by CE and Waldinger is perfomed at their home office engineering departments in Windsor, Connecticut and Des Moines, Iowa respectively. This includes the handling of all situations that involve a design interface. For field identified interferences, nonconforirances, and similar problem items that may involve a design J
change CE uses the Field Action Request (FAR) and Weldinger used a Supplies 4
Deviation Disposition Request (SDDR). The FAR documents the situation in detail and is sent to the CE home office for resolution. The 4
SDDR also identifies the situation in detail,'but it goes to Bechtel for resolution.
If the resolution involves a design change, it is detailed on a Waldinger Change Notice (WCN) which is then sent j
to Waldinger home office for initiation of a drawing change.
With regard to Sechtel, the only independent design work performed at the site is for temporary facilities / utilities, lighting layouts, yard piping (non-safety related), scaffolding, concrete fomwork systems, r' gging for hoisting activities, conduit routing details, and instrument tubing layout.
In the case of conduit and instrument tubing, basic requirements are established by Bechtel home office engineeHng. These design activities are perforined by Construction Department field engineers under the cognizance of the Project Field 1
Engineer.
The 8echtel Quality Program requires that design changes be subjected to the same level of internal project controls that are applied to the oH ginal design. Design changes are governed, just as original design, by the formal EngineeHng Department Procedures (EDP) and j.
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Project Internal Procedures (IP). Minor design changes that must be accomodated because of interferences, misfits, omissions, etc. which develop dudng installation are dispositioned at the site-using the Field Change Request (FCR). The design change is detailed on the FCR to the extent that the document can stand alone in identifying and resolving the situation. All FCR's must be reviewed and approved by home office engineering and, to expedite this review, the Project EngineeH ng Manager has establisned a Resident Engineer at the site. He supervises a staff of liaison engineers (g at the present time) with expertise in the various disciplines in accomplishing this approval function. All FCR's are subsequently sent to home office engineedng for second level (final) review and approval.
In cases where the Resident Engineer considers a change to be beyond the technical capabilities of his staff, he defers the approval, and sometimes the identification of the solution, to the Project Engineer.
The Nonconforance Report (NCR) is used for dispositioning defects, failures, deviations from procedures, or other deficiencies that render the quality of an item unacceptable or indetarwinata. The disposition of a nonconforming condition say be identified by Field EngineeHng, but any that are intended for "use-as-is" or " repair"
]
must have review and apprzvel of home offica engineeHng. This I
review and approval requirement is also fulfilled by the Resident l
Engineer.
l b.
Precram Adecuacy i
j The program manuals of 8echtal, CE, and Waldinger that contain the procedures which govern the respective actions described above 4
I were examined by the inspector. The procedures were found to be l,
of the latest revision, were appropMataly approved for use, and appeared to reflect good industry practices. The scope of the i
procedural coverage was such as to satisfy regulatory requirements and SAR commitments. The procedures also appeared to provida an adequate interface control systas between the organizations involved at the sita. The licensee has a comprehensive tabulation of structures.
systems and components which have a safety relationship to plant operation. This identification is extended to the vaHous design doctments. The listing is in both the Project Design CH teH a l
Manual and the PSAR. " hose documents also list the Regulatory l
Guides and Industry Standards applicable to the project.
Design changes developed through the sita design control process are veMfied during installation / erection by inspections performed l
by independent quality control engineers. This inspection function.
as well as the field design chans program, is audited by each i
organization's QA group and the 'iconsee's QA staff.
The licensee has a program in effect for reviewing, analyzing and reporting construction deficiencies. The Resident Engineer and the 8echtal home offica engineering team perform the principal technical role in this program.
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c.
Irelementation Site design control is effected through the use of the procedures contained in the Bechtel Engineering Department Procedures Manual, the Project Internal Procedures Manual, and the Field Construction and Quality Control Manual. The inspector vertfied that these procedures are readily available to, and are understood by, the involved individuals. The Project Design Critaria Manual and the SAR is also readily available. From a review of the contents of these manuals,(the inspector observed that detailed coverage was1) re included for:
4 reviewing supporting calculations; (3? adhering to codes, standards.
Regulatory Guides, and IE Bulletins; (4) document and drawing control; (5) deficiency corrective action; and (6) interfacing with the home office and the licensee. Also, a ' review of several procedures, drawings, specifications, and FCR's indicated that requirements were satisfied j
l and good engineeMng practices were being followed.
Two Bechtel liaison engineers on the Resident Engineer's staff were i
contacted, and the FCR approval activity they were currently involved in was discussed. One FCR related to modification of a pipe support and the other to a small-bore piping configuration change to avoid an interference. In each case, it was obvious that there was definite 1
need for the change, and the changes being mada did not congremise the original design intent. Both engineers demonstrated a good understanding of the change control procedures and were able to demonstrate that the design parameters were within the established critada. Independent checking and further acceptance review would be done in the home office upon receipt there of the coupleted FCR documents. The inspector examined several other previously coupleted FCA's and veMfied that the home office vedfication had been completed in timely fashion and that the parent design drawings had been revised to reflect the field change. The inspector l
also reviewed the technical qualifications of the two liaison engineers i
referred to above and found that they both were gradaats engineers, i
and each man had extensive expeMence in the particular task in which he was involved.
t From the mastar drawing control listing, five drawings were selected with current revisions in each of thne areas of installation (containment, mechanical piping and electMcal wirin In each case, the site Design Doceent Control Center (CDCC)g).
had on file i
the latest revision of the master reproducible drawing (microfilm).
The drawing distribution file also indicated that the latest revisions i
had been distHbuted to the field work stations in a timely manner.
The doceentation pertaining to the review and approval of the latest revisions appeared satisfactory, i
The techtal, CE, and Waldinger facilities utilized for permanent storage j
of drawings, specifications and procedures were examined. They e
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, l
. appeared to be adequate. Discussions were conducted with document control personnel at each facility and it appeared that their practices i
were in conforinanca with their procedures and conwitments. Ten drawings and two controlled manuals were selected at field work i
stations for each organization and compared with the master document list. All documents were found to be of the latest revision.
l The procedure for processing field generated nonconformance reports (NCR) orovides for prompt review for reportability to the NRC.
This review is perforined in a joint meeting of the Resident Engineer and the Project Quality Assurance Engineer, nomally within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the NCR is fritiated.
If the review shows that a reportable situation nay exist, the Bechtel Deficiency Evaluation Report (DER) is initiated by Bechtel QA and the licensee is innediately infomed so that telephone notification to the MRC can be effected. Disposition of all NCR's that constitute "use-as-is" or " repair" are reviewed and approved / rejected by the Resident Engineer in order that the oHginal design conservatism (margin) is not conpromised.
In those cases wherein Construction intends to depart from or modify a design document requireaant, an FCR is prepared and the NCR is dispositioned by that action. The inspector observed several of these situations and noted that the FCR dispositions wre appropriately reflected on the affected design drawings.
d.
Panacen nt involvement Because of the minor nature of design changes at the site, licensee j
nanagement does not have any day-to-day involvement in the change process other than the surveillance and audit activities by their site QA staff. Rechtel Project EngineeHng does have a coordinator who analyzes change requests on a monthly basis and issues a report i
to the Project Engineering Manager (PEM). An interoffice memorandte is then issued by the PEM to the Project Manager which indicates any quality trends and identifies any appropMate action that has been taken or recessended. These trend analyses are routinely discussed with the licensee duMng the monthly project review meetings.
4 Procurennt Controls - Site a.
Procram Irelementation The orianizations involved in installing safety-related perranent plant 'tems are CE, Waldinger and Bechtel. No procurement is perforined at the job site by CE and Waldinger, their materials / equipment are procured by their home office operations. The only procurement by Bechtel at the job site is for bulk type expendable materials, i
such as, nuts and bolts, weld filler satedals, flat steel plate, and structural steel shapes.
g
i i For Bechtel precurwents, they act as agent for the licensee in
' preparing the Field Material Requisition (FMR) and the resulting i
procurement documents. The actual Purchase Orders (P.O.), while issued by Bechtel, are actually the licensee's orders. Consequently, all FMR's and P.O.'s are reviewed and approved by the licensee.
This review and approval process is intended to assure that all procurement requirements are satisfied, including technical and quality program requirments. All FNt's and their subsequent P.O.'s are routed thmugh both Bechtel and licensee QA groups in order to assure that the proper QA program aspects are satisfied.
The inspector randomly selected seven P0 packages for examination.
Three were for weld filler mateHal, two were for A325 bolts, nuts t
l and washers, one was for A36 flat steel plate, and one was for l
structural steel angle.
In all cases, the FMR's had been reviewed by the appropriate discipline OA engineers and had the respective List of Aporoved Suppliers attached, as required. All suppliers that were listed had been audited by the licensee and/or Bechtel in order to be considered as " approved". Also, in all cases, the procurement package included the appropMate technical requirements i
and applicable industry codes and standards.
i i
The Bechtel procurement system utilizes a fom (G-321-V) which specifically identifies all docuentation that the supplier must furnish and.which also references the specification paragraph where the requirement is called out. This form is designed in such a manner that it c;n serve as the lechtal " source inspector's" release for i
i shipment occument, and as the supplier's Certificate of Conformance.
The fona identifies the supplier and the PO nuseer, has space for i
listing any of the procurerent requirements that were not met, and has a certification statement for signature by the supplier's authorized QA representative. This G-321-V fem was included in each of the seven PC packages examined by the inspector.
From the appropriate presence and location of signatures, recording in logs, orderly arrargement of files, and apparent adequacy of l
the seven P0 packages examined, the inspector concluded that the protection, handling and control of procurement specifications and i
purchasing documents was satisfactory.
b.
Receivinc Insoection All safety-related itess are inspected upon arHval by Bechtel i
Quality Control inspectors. For each shipment received, a Receiving Inspection Plan (RIP) is developed by the assigned inspector which identifies the PC nus6er, the supolier, th Material Receiving Report (MRR) nus6er, and describes the item. The RIP documents the conditions i
and characteristics found during the receiving inspection, and is filed in the QC doceentation vault along with the documents received from the supplier. The receiving inspection records are i
... filed by MRR number and are readily available for review. The QC inspector uses the procurement documents, particularly the technicai
. specifications, as his basis for completing the RIP. Standard verifications required by the RIP form are that the items are peccerly identified and marked. and the documentation required of the suoplier (including the Certificata of Conformance, as applicable) conglies with the specified requirements. The RIP also identifies the storage classification of the itam(s). The completed RIP serves to demonstrate cengliance with acceptanca requirements.
Items found to be nonconforming, either from a physical standpoint or because of missing or defective documentation, are tagged and segregated in an appropr' ate quarantine area; an NCR is prepared and must be cleared by the responsible discipline engineer before the itam can be used in the plant.
Regarding the supplier documentation, all mateHal test reports for ASME materials arw sent by the receiving inspector to the AuthoHzed Inspector for technical review and acceptance. The technical adequacy of other documentation is verified by the Bechtel Supplier Quality i
Representative (SQR) at the supplier's facility at the time he releases i
the itam(s) for shipment. Bechtel QA performs unscheduled audits i
of supplier documentation in the QC vault to ascertain the adequacy of the doceentation review perfonned by the SQR's. The NRC inspector reviewed the report of one such audit (No. US-5-80-10) that was i
perfcmed on March 3-7, 1980; the documentation for 73 itams was examined and no discrepancias were found. The auditor's qualifications were veMfied.
Audits are performed annually by the Rechtal Procurement Supplier Quality (PSQ) group on all suppliers of safety-related items.
i Bechtal or the licensee QA groups participate in these audits as deemed appropMate from the perfonnance history of the respective suppliers maintained in the Bechtal QA jobsite files.
The inspector examined the RIP's associated with the in-process receiving inspection of a shipment of shielded instrument cable (not sita procured) and a shipment of site-procured weld filler j
metal.
In each case the QC Inspector appeared knowledgeable in l
his assignment and the storage classification that the inspector had indicated on the RIP form agreed with that specified in the suster storage specification (13-M9-511, Storage Requirements).
The required certified Materials Test Report for the weld filter i
metal was stasped as acceptable by the Authorized Inspector. No discrepancies on either RIP form was observed by the NRC Inspector.*
c.
Eg33 The site has no need at the present time for class A storage facilities.
The facilities for Classes B, C and O appeared to be satisfactory i
at the present time.
It was pointed out to the licensee, however, that sose upper limit tosperature control provisions for class 8 storage may be necessary to accosmodata the safety-related storage Nota: See paragraph 8.b.(1) for perceived weaknesses identified during the enar nation of receiving inspection for electMcal components.
J
-13
-bat
- aries when they arrive on site. Prctective measures against damage during storage appeared adequate. Testing equipment for use on stored equipment is readily available and is suitable for the intanded use. Work and QA/QC procedures for storage related activities for class 8. C and D levels of storage were found to be generally adequate; huwever, a weakness in the follow-up of raintenance performed on stored equipment was pointed out to the licensee and immediate efforts were undertaken to upgrade that i
situatien.
Access to storage areas appeared to be appropriately controlled and limited to designated personnel. The areas reflected the application of good housekeeping practices. A large, chain-link fenced quarantine area in the large warehouse was toured by the inspector. The items in the area were observed to be " red-tagged
- and appropriately
- covered and arranged on pallets or shelves. The area is unintained in a padlocked condition with the key controlled by one designated i
individual.
5.
Weldino The inspector examined the general area of welding and the QA/0C program as it applied to welding. The specific areas examined, the criteria used, and the findings are detailed below.
a.
Pioino 1.aydown Areas The inspector examined the main targe bore pipir.g laydown area, laydown area, the small bore the srall bore piping subassembly (fnit 1 piping laydown area for pipe material rack area, and the 1
conformance to MSI M45.2.2, Regulatory Guide 1.38 and specification 13-PM-204, No items of noncomoliance or deviations were observed. The laydown i
areas were generally orderly, the pipe ends were capped and pipe was on danage or racks.
b.
Purchase Order Soecification for small Sore Pine and Fittinas The inspector examined the purchase order specification 10407-13-PM-307 Rev.12 " Nuclear Service Pipe and Fittinos 2 Inches and smaller" for compliance to PSM coeurittments and ASME B&PV code requirements.
No items of noncoupliance or deviations were observed, however the following two items were noted.
(1) The see item of asterial had two different meterial specificatiens called out in different parts of the purchase order. Ongage l
66 of the meterial list, Item 1735 is described as 2" x 1
-14 stainless steel sockolets to ASME !A 312 Gr 304 ASME $A 312 is a specificaticn for pioe. On page 4-3 paragraph 4.4.1.1 stainless steel socket weld fittings are required to be ASME l
SA 182 Gr F 304 SA-182 is a soecification for forged fittings.
The sockolets provided were SA 182 material. The responsible site personnel stated the call out for SA 312 material was probably an editorial error. Licensee personnel comitted to issue a specification change to correct the material callout.
Therefore this item will be inspected further during a future inspection.
(50-528/Cl-02/01)
(2) The body of the technical portion of the specifications require austenitic stainless steel materials to be furnished in a heat i
treated condition. However the specification includes a checklist.
Form G-321-0 " Quality Verification Docuament Requirements".
The checklist is used by source inspectors and receiving inspectors to verify the required documentation has t.een received. For specification 13-PM-307 the checklist does not include an item for heat treatment certification documentation. Paragraph 5.c. below describes a case where this specification problem rvsulted in delivery and acceptance of pipe nipples without heat treatment certification documentation. The action taken on this item is described in paragraph 5.c. below.
c.
Receiet Insoection The inspector interviewed receipt inspection personnel and reviewed the documentation and hardware for one delivery of fittints; stainless i
steel nipples and sockolets. The inspector verified chem' cal and physical test results met the mterial specifications. The documentation associated with the stainless steel nipples. Item 1533. MRR 103541 did not contain certific.ition that the nipples were heat treated as required by specification 13-PM-307 paragraph 4.4.4 As stated in paragraph 5.b.(2) above, the specification checklist used by source inspectors and receiving inspectors does not contain an item for I
heat treatment documentation. Subsequent to the inspector's finding, the heat treatment certification was provided by the vendor substantiating the fact that the nipoles were suitable for use. The licensee t
personnel wrote a Quality Assurance Finding (QAF.$F-41-2) recomanding i
corrective action and action to prevent recurrence. Therefore$0-528/
this item will be inspected further on a future inspection.
(
i 81-02/02)
The inspector examined a sagling of other fitting meterial receipt packages and determined that other fitting manufacturers had provided 12683.19538, 21654, 79442 and 21554.ges sampled were MRA heat treat certifications. The packa
._m_
i The inspector examined the duties and responsibilities of the source
'inseitetor and the interrelated duties and responsibilities of receiving inspector through review of Bechtel Procedure " Procurement Supplier Quality Manual" Sixth Edition and " Surveillance Inspection Plan for Nuclear Service Pipe & Fittings, 2" and Smaller". Rev. O.
The requirements of ANSI M45.2.2 for item inspection were implemented in those procedures.
l d.
Weld Procedure Deview The inspector examined a weld procedure specification, P1 AT Lh CVN i
Rev. 4 of April 18, 1979 for compliance to the detailed ASME B&PV Code requirements. Also examined were the procedure qualification records and the supporting tast data in conjunction with the specification. '
The procedure qualification records supported the procedure specification i
i for position, thickness range, preheat rod sizes and postwald heat treatment range. The inspector afso verified that tensile tast, impact test and guided bend test results met code requirements.
A discrepancy between the welding procedure specification (WPS) and the procedure qualification records (PQR) for an essential variable was identified. The WP5 provided a heat treatment temperature range. The PQR's did not provide information on interpass temperature.
This discrepancy was identified after the inspection; therefore, a licensee representative was notified by telephone.
Discussion with the licensee indicated the discreoancy was acceptable on the basis that the PQa was performed in 1968 and the code at that tins did not include intenass temperature as an essential variable.
The preantle to the ende Section IX states it is not the intent of revisions to the code to require requalification of processes' qualified to earlier versions of the code. The inspector had no i
further questions.
The inspector examined the general welding specifications and detamined the fitup and final weld configuration were not specified for full penetration piping branch connection corner welds such as would be used for socko ets, threadolets, and weldolets. The inspector did not identify any case where a safety related branch connection using that type of fitting had been made during site fabrication.
The inspector did observe Q class sockolet fittings in the site warehouse. At the exit interview licensee personnel connitted to issue fitus and weld configuration instructions for full penetration corner welds in accordance with the applicable requirements of the ASME S&PV code and to deter 1rine more completely whether any such safety related joints had been previously performed and to perfom reinspection as required. Therefore, this item will be inspected i
further on a future inspection.
(! tem 50-528/81-02/03) l i
16-e.
Field Welding i
The inspector examined the welding of two field fabricated piping weld joints; 24" carbon steel weld W 018 SG 005 DLBB on Orawing 13 P-SGF 119(8) welded to procedure PIAT Lh CVN(4) in mid layer welding and 4" stainless steel weld WC04 PCE 073 HCBA on Drawing 13P PCF 201(5) during fitup inspection and root welding.
j Through observation of field work and subsequent records review the inspector veHfied certain specific activities were in compliance with applicable codes and standards. For both welds the inspector veHfied the requirements of the weld procedure were included on the weld traveler form regarding preheat, inter 9 ass tamperature, and filler metal. The inspector veHfied the welders and QC engineers wem qualified, that required nondestructive examination was specified, and that inspections applicable at the time of observation had/were being performed and properly signed off on the traveler. The accuracy of the rod withdrawal slips was verified.
l For the carbon steel weld, the 1nspector observed that post weld heat treatment was not required and that the weld preheat had been properly increased to exercise that option in accordance with code j
requirements. The inspector's observation of work and the visual l
weld quality did not disclose any items of noncospliance or deviations.
I The inspector examined a completed 12" stainless steel field weld, W004 SI 220 CCSA. The visual appearance of the weld was satisfactory.
1 l
f.
Rod Room i
l The inspector examined Rod Room 13 Unit 3 and vedfied even settings j
were in accordance with FSAR committments. The inspector observed proper material segregation and current oven calibration stickers.
i l
The inspector selected three lots of metadal in the rod room and later verified, by records review, that the detail requirements of the code and reference 1 standards were properly documented on the steHal certifications. The details verified were the chemical and physical test results including igact test results for P-1 3
l weld anteHal and delta ferHta measurments for P-8 material.
j The weld rod lots examined were E 309-16 Lot 10564-3 MRR 85479, E 308L-16 Lot 50 923 M04 MRR 57618 and E 7018 Lot 2F018T01 MRR j
92247. No itans of noncompliance or deviations were identified.
g.
Audits
(
The inspector examined the two most recent audits of the welding l
area by the Bechtel QA. Welding audits are performed by the MQ&S Division. The audits examined were perfomed in 1980. The scope and depth of the audits appeared satisfactory. The inspector examined the corrective action on two of the audit findings in detail (CAR
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.005 and 013 of November 21,1980) dealing with radiographic examination j
and socket welds respectively. The cornctive action appeared to be sufficient to prevent recurrence.
In regards to the CAR 013, the problem identified by the MQ&S auditor was that of a welder perfoming a socket weld without having first ribed the pipe with a reference line to ensure the pipe was properly positioned in the socket fitting, i.e.1/16 inch from bottoming i
out. The weld had not been inspected by the QCE at that point and would have been identified as not in confonance when inspected.
The inspector interviewed involved personnel including the welder, 1
QCE. FWE, the Unit Assistant Lead Field Weld Engineer, and the Unit Superintendent. The problem had occurred because the welder had been teamed with a new pipe fitter. The welder's previous fitter had been perfoming the scribing during fitup for the welder.
The new fittar was unaware of the requirement and the problem was not noted by the welder prior to welding. Through the interviews the inspector detemined that the general problem with absence of scribe lines on socket weld fitups had been previously identified and reported on a nonconformance report and a CAR 5-40-80 of 7/23/80.
Both the CAR's were given to the Unit Assistant Lead Field Weld Engineer for disposition by the Unit Superintendent. At the exit interview the inspector indicated that since CAR's are generally written for significant items, repeat CAR's are indicative of a possible need to escalate the level of management involved in the resolution. Licensen management agreed to consider this point.
The inspector had no further questions.
h.
Personnel Interviews l
The inspector interviewed a num6er of sita personnel regarding l
the QA/QC program as it related to welding activities. The inspector interviewed the Project Quality Control Engineer, two quality control j
engineers, a unit assistant lead field weld engineer, a field weld j
engineer, two welders and two fittars.
l There was a consistant attitude throughout the site organization that quality was second in importance only to personne' safety and was being achieved. The quality control engineers felt that they were satisfactorily controlling quality and had the support of their supervision, the field engineers and the superintendents.
The only potential administrative weakness identified in the course of the interviews was that the QC personnel have no documentation i
vehicle to request action or clarifications from engineering.
The vehicles used are speed memos and interoffice menos. However none of the personnel interviewed felt that this lack of a fonal i
vehicle had resulted in a lack of action. This item was discussed l
at the exit interview. Licensee management agreed to consider l
the need for a forwal vehicle. The inspector had no further questions.
5
_, - ~, _.-
'r 6.
Review of Inscection. Sterace and Paintenance of Pemanent Plant Materists In conjunction with a review of reccrds and observation of work in the area of electrical ccaponents and systems, the licensee's system of receipt inspection, storage, and maintenance of permanent plant iters was audited for compliance to industry standards and licensing conedtments.
The following areas of weakness were noted by the inspector in the licensee's program.
a.
Personnel Oua11fication (1) The 1tcensee's system for training and indoctrination of inspection persone.el was reviewed. This system appeared to conform generally to the requirements of Regulatory Guide 1.58, and ANSI N 45.2.6
" Qualifications of Inspection Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants." The inspector noted however, that the licensee's procedure QCI 8.0, " Qualification, Certification, and Training of QC Personnel",
did not expressly state the education and experience requirements defined in. ANSI N45.2.6, section 3.1, " Levels of Capability."
The licensee's instruction stated "Each candidate...shall have sufficient education and experience to assure understanding of the principles of QC...". The licensee stated that other factors were sometimes used to provide assurance that inspectors met minimum capability requirements as allowed by the ANSI standard. These factors were not forsally documented or detailed as required by Revision 1, September 1980, of Regulatory Guide 1.58. This revision to the Regulatory Guide states that "Since only one set of reconsnandations is provided for the education and experience of personnel, a coeudtzent to comply (with ANSI N45.2.6 and Regulatory Guide 1.58) in lieu of providing an alternative to the reconnendations of the standard means that the specific education ar.d experience reconuendations of the standard will be followed."
The licensee stated that a change to QCI 8.0, " Qualification.
Certification and Training of QC Personnel", paragraph 6.0,
" certification requirements" would be made to clearly state the criteria used to establish the capability requirements for Level I and Level !! inspectors when the education and experience reouirements of ANSI N45.2.6 are not met. Moreover, the licensee stated that each instance would be documented in the inspectors training file with a notation by the Level III examiner as to how capability requirements were determined. Level !!! inspectors would meet AN5! N45.2.6 requirements as specifically stated.
The inspector noted that only 3 to 5 QC inspectors out of 75 to 80 did not fully meet the ANSI N45.2.6 requirements
<l
- for expeHence and education of Level II inspectors. The training program for insoectors as implemented did aopear to provide adequate capabilities to qualify these personnel to perform quality control functions as Level II inspec+ars.
(2) The receiving. inspectors interviewed appeared weak in their knowledge of the requirements of ANSI N45.2.2, " Packaging, Shipping, Receiving. Storage and Handling of Itses for Nuclear Power Plants." Son.e confusion was noted among receiving inspection personnel between ANSI N45.2.2 storage level A, B and C areas and Palo Verde warehouses A. B and C (all designated ANSI storage level B). The storage of statien htteMas (non class IE items which were erroneously listed as quality class Q items on receiving inspection doceentation) was exacined. The batteries were found to have been designated on the receiving inspection plan (RIP) as ANSI storage level C and placed in warehouse C.
ANSI
.N45.2.2 classifies batteries as storage level B items.
It was noted that the wMtten tests receiving inspectors take, as part of their certification, contained no questions directed at the specific requirements of ANSI N45.2.2, even though this standard provides specific instructions for receiving inspection and storage. The written test was directed at insuMng proper document control and had many questions of this nature.
b.
perfornance of Receiving Insnection (1) The inspector noted that receiving inspection (QC) personnel tend to rely on procurement supplied documentation such as the Material Receipt Record (MRR) rather than performing an independent check or verification of the procurement department functions. The station batteMes (noted previously) had been erroneously designated as ANSI M45.2.2 storage level C items by procurement on a handwritten list of purchase specification storage requirements which was in use as an aid to istR preparation (i.e. Specification 13-EM-050, Station BatteHes, required ANSI M45.2.2 storage level B). Procurement personnel had therefore erroneously indicated storage level C on the MRR. It appeared that the receiving inspector noted the storage level designation s
s on the MRR and indicated " storage classification C" on the Receiving Inspection Plan (RIP). As previously noted, the Linspector appeared to associate storage level C with storage
~ in warshouse C, an ANSI M45.2.2 level B area, and did not
~ question this designation.' 'The receiving inspector did not appear to have verified the storage designation with either j
' specification requirements or' ANSI N45.2.2 guidelines. A similar
. problem had been subject of a previous item of noncompliance concerning unit I emergency generators (Inspection Report 50-528n9-02 e
s
/
^
r j
e
. (2) There appeared to be a lack of positive control of special handling or inspection requirements. The receiving inspection personnel (QC) and procurement personnel get special handling information from the discipline field engineer after the field engineer receives the MRR from procurement signifying site arrival.
If no special instructions are forthcoming from the discipline field engineer, the receiving inspection (and procurement) personnel assume that none are required. The station batteries noted previously had no special handling, storage, or receiving inspection instructions. The requirements of WPP 28.0, " Maintenance of Materials and Equipment", paragraph 8.10. " Station Batteries"; and specific vendor instructions were not relayed to procurement or receiving inspection (QC) personnel. No action was taken to meet special receiving and storage requirunents. Furthermore, these items had not been properly included in the pemanent plant equipment maintenance system so that when observed by the NRC inspector on January 28, 1981, no check of the batteries fluid level or state of charge had been made since arrival on site in April 1980. The last accurately documented charging of these batteries was by the vendor on Sunday, March 16, 1980.
The station batteries are not safety related, consequently no enforcement action was taken, however the personnel and procedures involved will apply directly to safety related batteries when received on site, c.
Storace and Maintenance (1) It was noted that the storage level B warehouses did not have provisions to provide heating or cooling. The temperature and humidity in these areas was continuously monitored by strip chart recordingJnstrumenp. Due to the mild environment, temperatures in the 40"F to 140 F range required by ANSI M45.2.2 for storage level 8 equipment was maintained. The licensee did not however seem to have provisions to control temperatures for equipmenJ whose maximum storage condition might be less than the 140"F maximum such as storage batteries.
(2) The maintenance of penanent plant itams is performed under the direction of. discipline field engineers, but the adequacy of quality control or quality assurance surveillance of some activities appeared questionable. Previous NRC. inspections have identified permanent plant items not included in the licensee's maintenance program (Inspection Report 50-528/80-17).
This inspection disclosed station batteries which had not had checks on fluid levels or staa of charge, and had not been given periodic freshening charges as required, although maintenance action cards indicated that these cctivities had been perfomed.
(As these batteries were found to be non-safety related items no followup of this item was performed by the inspector).
These events do however bring questions to light as to the adequacy of the licensea's saintenance program.-
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, t The licensee was aware of these problems and is performing a review of persanent plant items to insure proper inclusion l
in the maintenance program. The licensee has scheduled quality assurance audits of this area for early 1981.
This area will be reviewed by NRC inspectors as a followup item during a future inspection. Specific items to be reviewed include (1) the licensee's method of assuring that all permanent plant items are included in the maintenance program and (2) the licensee's methods of assuring that specific maintenance requirements are properly performed and doctmented for these permanent plant items.
(50-528/81-02/04) 7.
Review of Electrical Components and Svstems The inspector observed work performance, and completed work associated with the four safety related DC busses, load centers, inverters, and vital AC instrument power panels in unit 1.
Areas reviewed included equipment maintenance, construction inspection and qualification of inspection (QC) personnel, documentation relative to nonconforming components, and missile protection and separation requirements. The following areas of weakness were noted by the inspector in the licensee's program, a.
Incemolete 10 CFR 50.55(e) Submittal On November 5,1980 the licensee submitted a final report on a reportable deficiency related to a mechanical interlock device on battery charger 1-E-PKA-H15. This interlock could be defeated, allowing simultaneous the closure of breakers supplying redundant DC busses thereby placing these busses in parallel. The final report stated that "this condition is isolated to the above identified battery charger". An improved design was provided for Units 2 and 3.
On January 29, 1981 the inspector noted an identical fault in the mechanical interlock on redundant battery charger 1-E-PKB-H16 in Unit 1.
This condition was apparently not identified by the licensee.
The inspector noted that, in addition, the mechanical interlocks i
were not labeled to alert operating personnel of the possibility i
of electrically connecting two redundant DC busses if the interlock j
was defeated. ~Moreover, the breakers themselves were not labeled or color coded in a manner that would indicate them to be part of redundant trains.
The inspector was concerned that a full evaluation of the deficiency had not been made prior to the submittal of the final report.
The licensee stated that this item would be re-reviewed and an amended final report submitted. This will be a followup item during-a future inspection.
(50-528/81-02/05)
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, t b.
.Ircrecer Identification of Class IE Cenduit and Cable The facility design as detailed in the FSAR incorporates a standby or third-of-a-kind safety related load. This load is the third charging pump. The FSAR states that conduit from the power source transfer switch to this standby or third-of-a-kind charging pump i
is to be marked with red and green stripes indicating power from either safety related division A or safety related division B.
The licensee s one line schematic of this circuit shows that the conduit is to be labeled with red and green striped identification tags per the FSAR. The drawing however gives an "N" series number to the circuit which by the licensee's standards indicates non-safety related.
(Safety related circuits and conduits have "A 8
C or 0" series numbers). Additionally the cable was specified on the circuit one-line schematic drawing as black cable.
(The licensee utilizes red, green, yellow or blue colored cable in safety related circuits).
The conduit installation drawings showed only the conduit numbers, frem which safety classification could be detemined. As this l
conduit nuder was an "N" series number the conduit was labeled in the field as non-safety related and the conduit did not provide I
the cable with separation frem other non-class IE circuits associated j
with monitoring pug performance.
-IEEE 384 requires that both raceway (conduit) and cable should be identified so as to readily distinguish between redundant class IE systems and non-class IE divisions. The system of identification is required by Regulatory Guide 1.75 to be " simple and should preclude the need to consult any reference material."
The use of "N' series cable and conduit numers and the use of black colored cable seems to defeat the licensee's othemise simple system.
The licensee stated that this matter would be reviewed and appropriate FSAR and design changes iglemented. This area will be a followup item during a future inspection.
(50-528/81-02/06) c.
Ouestionable Breakout of Cable from Raceway to Conduit The inspector noted a routing of safety class IE cable from horizontal raceway to vertical conduit that did not appear consistant with normal industry practica. In unit one, division A cable (safety related) was observed to be routed out of horizontal tray IEZJIAATKAC to vertical conduit IEZJ1AARK22 by rising approximately 6 inches to clear the tray edge (edge protector provided), running approximately 15 inches horizontally (unsupported) and then dropping approximately l
4 20 inches (unsupported) to enter the conduit vertically. This type mf breakout was noted in several other instances for cables of divisions A, B and 0 of unit one.
Normal industry practice, and the practice in use at unit 2 has the cable rising from the tray to enter conduit hoMzontally near l
the tray edge with the transition to vertical conduit accomplished by means of a 90 degree elbow in the conduit. An alternate industry l
practice would utilize a tray end dropout to support the cable during this direction change and provide tray edge protection. The licensee installation, as observed in unit one, appears to provide questionable support to the cable at the loop fomed by the direction changes.
The licensee's drawings specify the maximum unsupported distance 4
for cable in free air shall be 18 inches hoMzontal and 24 inches vertically. These cMteHa may not however be sufficient in this situation where an unsupported " loop" of cable is formed due to a major direction change. The licensee stated that this situation would be brought to the attention of design engineeMng for review.
d.
Use of Flexible conduit as a Means of Providino Separation of Rtdundant Cacies The FSAR states in paragraph 8.3.1.4.1.1.C.8 that, when " isolation between separation groups...is less than...(3 feet hoMzontal and 5 feet vertical)..., all but one of the separation groups (is) routed in ricid steel conduit or wireway maintaining a one inch separation between conduits...." In the F5AR section 8.3.1.4.1.2 when the 6 inch minimum physical separation within control boards and other panels is not maintained the separation groups shall be installed in an " enclosed raceway (ricid steel conduit. EMT. or enclosed metalic cutter)."
- i In practice the licensee is using a flexible spiral wound metalic conduit as a cable support in areas where certain flexibility is required in the cable system. The licensee also considers this flexible metalic conduit equivalent to Mgid steel conduit as a barrier for meeting separation requirements. The inspector questioned this application of flexible conduit. The licensee stated that this area would be reviswed for compliance to industry standards and regulatory guidelines. This item will be examined further pending review with NRR of specific separation requirements and the use of flexible conduit.
(50-528/81-02/07)
Note: Emphasis added.
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Secaration of Redundant Circuits by Means of Conduit or Enclosed M aceways IEEE 384 in paragraphs 5.1.3 and 5.1.4 state that "Where plant arrangements preclude raintaining the minimum separation distance, the redundant circuits shall be run in enclosed raceways that qualify as barriers...." Figure 3 of IEEE 384 shows two redundant divisions, I
both enclosed in solid barriers with 1 inch spacing between the barriers.
The licensee in the FSAR states that the requirements of Regulatory l
Guide 1.75 and IEEE 384-1974 are met.
In sectian 8.3.1.4.1 of the FSAR " separation criteria" it states in paragraphs 8.3.1.4.1.C.7 and 8.3.1.4.1.C.8 that "all but one of the separation groups" shall be run in enclosed racewaye The addition of the words "all but one of" dilute the requirements of IEEE 384 to have each separation group in enclosed raceway where minimun separation distances are not maintained.
In practice the licensee has considered separation to be adequate, in situaticns where minimum separation distances are not met between two redundant divisions, by routing one of the two groups in conduit and leaving the other in exposed raceway. (IEEE 384 requires both groups to be routad in conduit with a 1" minimum separation between conduits.)
This apparent exception to industry standards was discussed with the licensee. This item will be examined further pending review with NRR of the specific separation requirements and the use of enclosed raceways to achieve separation.
(50-528/80-02/08) 8.
Review of Structural Concrete Activities The inspector observed work perforinance, and completed work associated with concrete placement activities. Areas examined included post-placement activities associated with unit one refueling water storage tank (first-lift), and condensate storage tank (5th lift). Additionally, Cadweld activities on unit three containment were observed. The inspac*ar identified no areas of weakness or concern.
9.
Prefect Management Control The project anagement portion of the inspection was directed towards verification that management has been exercising control in a manner that should assure a quality product. The inspection included (1) interviews with selected field and office engineers, clerks and ranagement personnel
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, l up thrtugh the level of the APS Vice President, Nuclear Project Management, and the Bechtel Field Construction Manager, and (2) examination of selected procedures, various types of reports, logs, minutes of staff meetings, trending analysis, personnel records and analysis of equipment and systems.
Attachment A is a listing of most of the documents and procedures examined during this portion of the inspection. Principal areas of review included:
(1) Procram - Organization, Comunication, and Change Control; (2) Imolementation Planning. Activity Review, and Inspection; and (3) Manacement Involvement -
Reports, Management Review, Other Informaticn Channels, anc Management Image. Results of the inspection are as follows:
a.
Procram (1) Oreanization Organization charts for the licensee and contractor were current.
Lines of authority and comunications between APS and Bechtel (A/E - Construction Manager / Contractor) have been clearly defined and were understood by parties interviewed.
Written and approved detailed position descriptions had been prepared for engineers and managers and were found to be consistent 4
with the current organizational structure and program description.
Individuals interviewed had a good understanding of interface controls relating to changes, notifications, reports, approvals and step work authority.
l (2) Comunications The APS and Bechtel program procedures clearly define channels cf communications and responsibilities for comunications in IP-2.1, MS-1, MS-2, MS-3 and NS-4.
The types of reports i
in use have been identified in procedures IP-3.2, QAD 10.1 and QAD 2.4.
They include progress reports, trending analysis, studies, surveillaned reports, and periodic reports. A management 1
Review Meeting is scheduled and has been held annually to discuss the Annual QA Report ~with the President, Chief Executive Officer and other members of APS management.
(3) Chance Control The p(rogram incorporates controls to effect changes in response to:
- 1) NRC Circulars, Bulletins and Infomation Notices; (2) design changas, field generated specifications, and field change requests; (3) corrective action resulting frca audit i
findings; and (4) regulatory requirements. The document control logs in the several departments require a close out of these type of items.
In addition, the licenses receives and evaluates 4
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26-l l
l for action industry experience reports, Bechtel i
NRC items of nonconcliance reviews (agency wide)Q,A Bulletins, all of which j
are routed through the Vice President, Nuclear Project Management, I
to OA for followup action as appropriate.
(See section on i
QA program for additional information in this area.)
t b.
Imolementation 3
J 1
(1) Planning QAD 2.4 identifies the type of reports to be submitted to management to assure that management is apprised of conditions found during -
l the reporting period that could be adverse to quality. Examination of these reports and minutes of management meetings disclosed that ennagement has been responsive to adverse trends to assure the controls have been initiated when trouble spots appeared, i
such as for apparent excessive rework on hangers and supports, i
Discussionswithmanagement(APSandBechtel)andthelicansee's engineers in QA, engineering, and construction indicated that i
interfaces between the various licensee organizations and contractors were clearly understood.
The several managers interviewed appeared comfortable with the size of their staff for the current work load. All felt they had managenent backing and could obtain additional resources when necessary. Severti cases were cited to demonstrate this support. Staff members generally felt that, while kept busy, their work load was not excessive to preclude the review of various reports and to detect trouble spots.
The review of staff qualifications disclosed thoss examined to be consistent with position description requirements.
Personnel interviewed had a good understanding of their responsibilities and authorities.
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(2) Activity Review Several recent activities performed by the engineering, construction and QA staffs were examined, including several jobs in progress.
Areas considered included censtruction deficiency reports, activity planning, record accessibility, sanpower, interfaces, engineering coverage, and identification of regulatory requirements.
No weaknesses in the licensee's activities were identified.
(3) Insoection The frequency of and quality of field inspection / surveillance and performance reviews, conducted by department heads, discipline engineers and other management staff who impact on contractor 9
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, perfomance were examined. Personnel job descriptions specify
-individual responsibilities with respect to the surveillance of construction activities. APS personnel, other than QA, do not perform insoections per se, but rather perform a surveillance type function. QAD 10.1 provides guidelines for reporting surveillance activities at the site by licensee project personnel.
Project staff normally complete a surveillance report "...after each site visit involving noteworthy activities or observations...."
The site construction engineers maintain log books of their daily activities and only prepare site surveillance reports when significant observations are ade. Their log books are examined at least once per month by the Field Engineering Supervisor. The site construction engineers interviewed did not work to a surveillance plan, but did follow the activities in progress in their respective disciplines. The engineers from the engineering department habitually prepara site surveillance reports for each visit. They attempt to get to the site several i
times a month and work with their APS and Bechtel counterparts.
The Surveillance Report Log was examined, as were several surveillance l
reports, to assure that reports were properly distributed, that persons were assigned to take appmpriate corrective actions and that items were tracked through correction. It appeared that i
item were being appropriately reviewed and an effort made to improve performance.
c.
Manacement involvement (1) Reoorts i
Management's utilization of various operatienal reports was i
examined in detail with principal managers and supervisors,
including the APS Vice President, Nuclear Project Management.
Utilization of reports by the Company President and Executive Vice President was also ascertained. Issues examined included staffing, construction deficiency reports, trends and rework.
All conscientiously reviewed the analysis of trending reports, and did not believe rework to be a problem at this time.
Where pmblem dreas were identified, management attention was being given to correct the situatior such as that cited earlier with respect to hangers and supports.
The managers interviewed felt their staffs were adequate for i
the current work load, even though it was " heavy", and all felt they had management backing to obtain additional personnel
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once the need was justified. Education and experience of i
the staff appeared to be consensurate with the job descriptions i
examined.
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. Deficiency Evaluation Reports (DERs) are prepared by Bechtel for significant matters and evaluated for Part 21/50.55(e) recortability. APS OA is responsible for tracking and auditing CERs to their ultimate conclusions and to report to the Comission as appropriata.
It appeared that actions taken - upward and downward - to resolve issues were adequata, tinaly, and connunications were completa.
(2) Manacement Review j
Management conducts annual reviews of department performanca, including a compensation review and perfornance by objectives review. Each supervisor is required to conduct a similar review of his department and staff. The Equiprent Utilizat1on Department does field audits and work sampling on adequacy of equipment.
The various managers interviewed demonstrated knowledge of QA findings and field engineeMng reports. All were familiar with the systems used to follow up on and verify corrective action.
It is the practice of the Vice President, Nuclear Projects Management to attend all NRC-IE exit interviews unless he has an unavoidable conflict. Likewise QA, Construction, and Engineering management and their counterparts in the Bechtel organization usually attend exit meetings. All negative findings are personally reviewed by the Vice President, Nuclear Projects Management. An action item list is used to track open items and assure a timely response to findings. Bechtel determines the corrective action. They are audited by APS QA tJ assure answers are meaningful and reflect timely corrective action..
The NRC Regional Office has not expeHanced any problems in this regard with the licensee.
(3) Other Infomation Channels Licensee management does not have a wMtten program for handling allegations, nor has management guaranteed protection to workers in wMting who bring in such complaints. However, it has
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been the policy and practice that allegations be handled by the QA Manager. All workers and staff members interviewed by the team ausbers believed that management had an "open door" policy and believed that their concerns would be attended to satisfactorily. They did not have any adverse coements in this regard. Management stated, and the staff concurred, that this unwritten policy and adherence to quality standards has been continually stressed to the staff. When allegations t
have been received, the record supports that they have been handled promptly and the alleger notified of the resolution.
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b i From the discussions, it was found that the Executive Vice President has personally talked to QA/QC type inspectors to assure that they are not being intimidated by management with respect to identified deficiencies. Allegations received by Bechtel are directed to the Construction Manager who directs the investigation and keeps abreast of findings.
The licensee has an effective suggestion-award system for improving quality and/or performance. The staff was aware of the system and it appeared that it was easy to submit suggestions.
1 The licensee does not have a grievance system since there are no union members under APS Nuclear Project Management.
(4) Management Imace The methods used by management to maintain contact with site construction and the people performing the work were examined.
i The examination included employees' perception of management's interest in employees, interest in the job, dedication to quality, ledge of what is going on.
availability to employees, and general know The Vice President. Nuclear Projects Management holds a staff meeting with the managers at least once a senth. Periodically
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i he meets with them and the employees. Approximately once a month he meets with the site construction and QA staff. Personnel interviewed confirmed his attendance at their staff meetings and the holding of general staff meetings. Department staff meetings are held at least monthly, while supervisory staff meetings are usually held weekly at the construction site.
The licensee has initiated programs to improve connunications within the APS and the contractor / craft organizations. Nuclear c
Projects has a communications consultant who periodically l
holds seminars with the staff on a volunteer basis. Through Arizona State University APS also sponsors an annuai one-and-a-half day Communications Seminar for APS and Bechtel staffs down to the craft general forenan level. At the and of the session, the craft foremen are given ample opportunity to discuss their problems with construction management. All participants are invited to rate the program and identify concerns anonymously. The program has been in effect for three years.
A total of about 360 will attend one of the six seminars to be held this year. The several monasers and engineers interviewed thought the program to be very beneficial. This feeling prevailed in the course evaluation sheets reviewed by the inspector.
.g.
.r 30-It was found that all levels of management periodically tour
' work areas from several times a week to at least once a month.
The Nuclear Projects Vice President formally tours the site once a month with the Bechtel Project l'anager and Construction Manager. Since 1977, the APS Board of Directors have annually held a meeting at the construction site that includes a site tour and a status / progress report. Personnel interviend confirmed managements visibility on site, at staff restings and general meetings. They cerceived management to be dedicated i
to quality, genuinely interested and supportive of emolayees.
available to employees through open door policy at all levels i
of management, and that management had a good understanding of the job. All felt that substandard work would not be accepted or " engineered away."
- 10. Exit Interview At the conclusion of the inspection the. scope and findings of the construction assessment teams inspection were discussed with the licensee representatives identified in paragraph 1 of this report. The licensee's representatives agreed to examine the identified items of concern.
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