ML20199H904

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Part 21 & Final Deficiency Rept DER 85-43 Re Lack of Compliance W/Bechtel Requirements for Q1E Matls.Initially Reported on 851230.Condition Not Reportable Under 10CFR50.55(e) & Part 21
ML20199H904
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 06/18/1986
From: Van Brunt E
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To: Kirsch D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
REF-PT21-86, REF-PT21-86-250-000 ANPP-36982-EEVB, DER-85-43, MDEFR-860618, PT21-86-250, PT21-86-250-000, NUDOCS 8607070386
Download: ML20199H904 (5)


Text

a ss Arizona Nuclear Power Project P.O. BOX 52034 e PHOEN X, ARIZONA 85072-2034 1230 [C 23 f,1 ll l C" June 18, 1986 a:,v..,,-

ANPP-36982-EEVB/LAS'/IYR$-97!11 U. S. Nuclear Regulatory Commission Region V 1450 Maria Iane - Suite 210 Walnut Creek, California 94596-5368 Attention:

Mr. D. F. Kirsch, Acting Director Division of Reactor Safety and Projects Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, 3 Docket Nos. 50/528, 529, 530

Subject:

Final Report - DER 85-43 A 50.55(e) and 10CFR21 Condition Relating to Lack of Compliance to Bechtel/ANPP Requirements for Q1E Materials File: 86-006-216; D.4.33.2 Referenec:

(A) Telephone Conversation between R. C. Sorenson and T. R. Bradish on December 30, 1985 (Initial Reportability - DER 85-43)

(B) ANPP-34803, dated January 24, 1986 (Interim Report - DER 85-43)

(C) ANPP-35350, dated February 28, 1986 (Interim Report - Rev. 1, DER 85-43)

(D) ANPP-36068, dated April 11, 1986 (Time Extension - DER 85-43)

(E) ANPP-36580, dated May 14, 1986 (Time Extension - DER 85-43)

Dear Sir:

Attached, is our final written report to the Deficiency under 10CFR50.55(e) referenced above. The 10CFR21 evaluation is also included.

Very truly yours, IM 1

E. E. Van Brunt, Jr.

Executive Vice President Project Director EEVBJr/DRL:kp Attachments cc: See Page Two 8607070386 860618 h

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ANPP-36982-EEVB/LAS/DRL-92.11 June 18, 1986 DER 85 Final Report Mr. D. F. Kirsch Acting Director Page Two cc:

Mr. J. M. Taylor, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.

20555 A. C. Gehr (4141)

R. P. Zimmerman (6295)

Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway - Suite 1500 Atlanta, Georgia 30339 l

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FINAL REPORT - DER 85-43 DEFICIENCY EVALUATION 50.55(e)

ARIZONA NUCLEAR POWER PROJECT (ANPP)

PVNGS UNITS 1, 2, 3 I.

Description of Deficiency Bechtel Procurement Supplier Quality Department (PSQD) Audits conducted in November,1985, at the Brown Boveri Tulsa, Oklahoma and Sanford,

-Florida facilities identified a lack of compliance to Bechtel/ANPP requirements fcr Class QIE materials. The deficiencies include:

1.

Commercial grade items for QIE applications are not controlled by drawing revisions to support previous qualification reports.

2.

Certain Brown Boveri procurement documents to vendors do not contain all of the QA program requirements imposed by the ANPP Project Specification 13-EM-017.

A reorganization of Brown Boveri occurred in 1985, subsequent to that time no material supplied or manufactured by the Tulsa facility has been provided to PVNGS. On this basis, the conditions associated with BBC/ Tulsa have been determined as non-safety-significant and eliminated from this report.

Evaluation The investigations and re-audits on April 21 and 22, 1986, at the Springhouse facility and April 29, 1986 at the Sanford facility identified the following potentially safety-significant conditions:

1.

AB40 meters manufactured by GE-Yokogawa were deleted for use in switchgear products. These meters could not be certified for use due to material and configuration changes which effect previously established environmental qualification reports. Also, objective evidence of 10CFR Part 21 evaluation, notification to NRC and BEC customers, as required by BBC Q/A procedures, could not be ascertained.

2.

BBC Springhouse organizational chart did not address Systems Engineering (Springhouse) or Component Sales (Sanford - responsible for E0 evaluation) nor were the responsibilities defined.

3.

BBC receiving procedures did not contain sufficient quantitative /

qualitative criteria to instruct QC personnel to adequately evaluate product quality.

Further investigation by BBC and subsequent verification by ANPP indicated that the conditions listed above do not affect safety for the following reasons:

1.

The AB40 meters, delivered to the project, have been quarantined to preclude installation into a 01E system and BBC Brown Boveri has verbally notified the NRC of a Reportable condition under their requirements.

r DER 85 Final Report Page Two 2.

BBC/Springhouse/Sanford procedures have been revised to define position responsibilities and delineate both Systems Engineering and Component Sales on the organization chart. The Component Sales Group has been delegated the responsibility of reviewing customer P.O.'s for equipment qualification applicability and reviewing the equipment qualification reports to ensure P.O. requirements are met.

This action will ensure the adequacy of an ongoing EQ program.

3.

BBC Sanford revised Receiving Inspection Procedure 10.17S to prescribe additional criteria necessary to assure product conformance.

BBC/Springhouse has received Certificates of Conformance from all approved vendors attesting continual compliance to environmental / seismic criteria. BEC Qualification Engineering has performed a review, evaluated any changes, and certified that they do not affect the original qualification basis. Therefore, the project has evaluated all of the conditions documented for both the BBC ;anford and BBC Springhouse facilities and has determined that these conditions are not safety-significant since, the identified problems have no impact on installed Q1E components.

Root cause analysis:

BBC was remiss in evaluating purchasing documents for correct quality requirements to be imposed on subvendors.

The BBC/Springhouse group responsible for equipment qualification did not have fully defined responsibilities with regard to QIE programmatic requirements. At that time, the Component Sales Group (Sanford, Florida) was responsible for the processing of Q1E material while the Springhouse facility had total responsibility for equipment qualification.

The condition associated with the GE-Yokogawa meters has been established as an isolated and unique case. The non-qualified meters are being sold by Yokogawa using the same part number as i

previously assigned by General Electric to the qualified meters.

II.

Analysis of Safety Implications Based on the above evaluation, this condition is evaluated for PVNGS as Not Reportable under 10CFR50.55(e) and 10CFR Part 21 since it does not represent a significant safety hazard.

III. Corrective Action The corrective actions already completed resolve the conditions identified with the root cause. ANPP Procurement Quality is currently performing the necessary activities to follow-up and verify evaluation of l

changes to Yokogawa AB40 meters (material, configuration) which is scheduled for completion by June 30, 1986.

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DER 85 Final Report Page Three References 1.

ANPP Letter (ANPP-36751-WEC/MSM-92.30), dated June 3, 1986 2.

ANPP Letter (ANPP-36539-WEC/WWM-92.30), dated May 8,1986 3.

BBC Brown Boveri Letter, dated May 14, 1986 (C. W. Rhoads to W. E. Craig) 4.

BBC Brown Boveri Letter, dated May 23, 1986 (C. W. Rhoads to W. E. Craig) 5.

ANPP Letter (ANPP-35702-WEC/WPP-92.30), dated March 26, 1986 6.

BBC Brown Boveri Letter, dated March 11, 1986 (C. W. Rhoads to W. E. Craig) 7.

ANPP Letter (ANPP-35480-WEC/WPP-92.30), dated March 10, 1986 l

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