ML20205E794

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Forwards Insp Repts 50-529/86-33 & 50-530/86-27 on 861201-12 & Notice of Violation.Two Programmatic Weaknesses Identified in QA Program & Improvements Needed Re Sys Engineer Program Listed.Response Re Improper Storage of Equipment Requested
ML20205E794
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 03/13/1987
From: Kirsch D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Van Brunt E
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
Shared Package
ML20205E799 List:
References
NUDOCS 8703310016
Download: ML20205E794 (4)


See also: IR 05000529/1986033

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MAR 131987

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Docket No. 50-529, 50-530

-Arizona Nuclear Power Project

.P. O. Box 52034

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. Phoenix, Arizona 85702-2034

Attention:

.Mr. E. E. Van Brunt, Jr.

Executive Vice President-

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Subject: NRC Inspection of Palo Verde Nuclear Generating Station

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Units No. 2/3

Gentlemen:

This refers to the special team inspection of December 1-12, 1986, conducted

by Mr. R. C. Barr and other members of our staff, of activities authorized by

'NRC License No. NPF-51 and Construction Permit CPPR-143 and to the discussion-

of our findings held by Mr. Barr with Messrs. Van Brunt, Haynes, Bynum and

other members of your staff at the conclusion of the inspection. Also

included in this report are the results of a meeting held on February 3,1987

and a telephone conference held on February 6, 1987 to follow-up on several

items identified during the inspection.

Areas examined during this inspection are described in the enclosed inspection

report. 'Within these areas, the inspection consisted of selected examinations

of procedures, records and personnel interviews.

Based on the results of this inspection, it appears that certain of your

activities were not conducted in full compliance with NRC requirements, as set

forth in 'the Notice of Violation, enclosed herewith as Appendix A. Your

response to this Notice is to be submitted in accordance with the provisions

of 10 CFR 2.201.

.The inspection objectives were to evaluate whether appropriate corrective

actions were being implemented on a timely basis in response to operating and

maintenance experience at Units 1 and 2 and being translated into preventive

measures at Unit 3.

The inspection focused on design changes initiated by the

electrical discipline. 'All facets of the design change process from problem

, identification', through design efforts, to design change implementation.and

design change package closecut, were examined.

A summary of the areas inspacted is included in Appendix 8.

Overall Conclusion

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The team determined that several aspects of your system engineer program need

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improvement as evidenced by the following:

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MAR 131987

The' cognizant system's engineer dispositioning of Engineering Evaluation

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Requests-(EER), designated as "information only", lacked clear assignment

of responsibility.

Several' instances were identified where the documented scope of the

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review of an EER by a system engineer was narrow.

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iSystem engineers did not regularly evaluate trends or review

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-surveillances and corrective maintenance on systems under their

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cognizance; therefore, overall system performance evaluations were not

being performed. This practice minimizes the opportunity for predicting

and improving system perfomance.

We recognize that your system engineer program has been in the formative

stages since licensing of Unit-1 and some general improvements have been made.

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We~also are aware of the actions you are taking to define the program, as

discussed during management meetings subsequent to this inspection.

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Nonetheless, in. recognition of the importance of trending and evaluating

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integrated system performance, we would have expected this program to be more

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aggressively implemented by this stage in your facility operation;

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Furthermore, we-are concerned that senior project management appeared unaware

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of the significant weaknesses in this program, indicating that your oversight

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of this activity has not been sufficient.

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'The team. identified an inadequate design in the utilization of thermolag for

cable tray fire barriers due to not having an independently tested

configuration; 'and instances of technical specification ~surveillances having

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been performed with outdated procedures because appropriate administrative

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controls had not been implemented to assure procedures were changed

subsequent to a design change. Each of these areas need additional management

attention to prevent reoccurance of these deficiencies.

Our review of the Quality Assurance Program identified two programmatic

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weaknesses. The scope of the QA review for design changes appears to be poorly

defined. Further, where deficiencies and departures from procedures had been

identified and corrected during the quality review, they had not been-

evaluated for adverse impact on plant operation. Strengthening the QA program

should also have a high management priority.

The team also identified the need for increased attentiveness by plant

personnel, including supervision, during plant rounds and tours to ensure

' adverse conditions are identified and corrected at the earliest opportunity.

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Specifically, attention to the improper storage of large transient equipment

needs improvement. Several items of improperly stored equipment were

identified during the inspection of December 1-12, 1986 and again during the

followup visit on February 3, 1987.

In your response to the attached Notice

of Violation, please provide a discussion of the apparent ineffectiveness of

your initial corrective actions for this violation.

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MAR 131987

Our review of the Design Change Program concluded, for those areas examined,

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appropriate corrective actions had been implemented on a timely basis in

response to operating and maintenance experience at Units 1 and 2 and had been

or were planned to be incorporated into preventive measures at Unit 3. Except

for the programatic weaknesses in the system engineer program and the scope of

QA. review of design changes, the programs to implement design changes at your

facility appear to be functioning in an acceptable manner.

We understand that several actions discussed during the exit meeting will be

taken in response to concerns raised by the team. A listing of these actions

is provided in paragraph 9 of the attached report. Please include the status'

of these actions in addition to your response to the enclosed Notice of

Violation.

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In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures

will be placed in the NRC Public Document Room.

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The response directed by this letter and the accompanying Notice are not

subject to the clearance procedure of the Office of Management and Budget as

required by the Paperwork Reduction Act of 1980,.PL 96-511.

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Should you have any questions concerning this inspection, we will be pleased

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to discuss them with you.

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Dennis F. Kirsch, Director

Division of Reactor Safety and

Projects

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Enclosures:

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A.

Appendix A - Notice of Violation

B.

Sumary of Inspection Findings

C.

Inspection Report 50-529/86-33,50-530/86-27

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cc w/ enclosures A and B:

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J. G. Haynes, Vice President, Nuclear Production

J. R. Bynum, PVNGS Plant Manager

W. F. Quinn, Manager, Licensing

T. D. Shriver, Manager, Compliance

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W. E. Ide, Director, Corporate QA/QC

C. N. Russo, Manager, Quality Audits / Monitoring

Ms. Jill Morrison, PVIF

Lynne Bernabei, GAP.

Duke Railsback, ACC

A. C. Gehr, Esq.

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Resident Inspector

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B. Faulkenberry

J. Martin

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