ML20209G083

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Responds to NRC Re Violations Noted in Insp on 770509-12.Corrective Actions:Rev 5 to Spec 13-cm-101 Issued & Work Plans Procedures/Qc Instruction 56 Revised to Clarify Operator Duties
ML20209G083
Person / Time
Site: 05000000, Palo Verde
Issue date: 07/22/1977
From: Van Brunt E
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To: Spencer G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML17198A269 List: ... further results
References
FOIA-84-293 ANPP-9031, NUDOCS 8508150584
Download: ML20209G083 (10)
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Text

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    • .o cmin. 4mzona e s os e July 22, 1977 ANPP-9031

,-;. P-U. S. Nuclear Regulatory Consnission g[f h,.. ".. ' ?

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Office of Inspection and Enforcement Region V

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Walnut Creek Plaza - Suite 202 2900 North California Boulevard

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Attention: Mr. C. S. Spencer, Cl.ief Reactor Construction and Engineering Support Branch

Subject:

Docket Nos. $0-528, 50-529 and 50-530 Tile:

77-058-026 Dear Sir This refers to the inspection conducted by Messrs. R. J. Pate and T. W. Bishop en May 9-12, 1977 as documented in your letter dated June 14, 1977 of activities autherized by the Nuclear Regulatory Cossaission (NRC) Construction Permit Nos. CPPR-141, 142 and 143.

As a result of this inspection, a Notice of Violation was written identifying two apparent violations.

Our response to this notice is recorded on Attachment A.

You also requesteid in your letter that we describe those actions taken to improve the implementation of construction procedures.

l Our response to the request appears in Attachment B.

Arizona Public Service Company recognizes its responsibility in assuring the implementation of censtruction procedures. We have initiated considerable effort in this regard and will continue this ef fort until the procedures are strictly followed, Very trul

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E. 7, My youeh fg'gul00504OD0703 E. E. Van Brunt, Jr.

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APS Vice President J

llR Construction Projects ANPP Project Director EEVBJr/JARieke Attachments ces R. !..

Robb B. S. Kaplan W. 11. Wilson W. M. Petro J. M. Allen J. E. Bashore R. L. Hand A. C. Cahr C. Betzhold

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ATTACitMENT A t

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Socket No. 50-528 f

\\Construction Permit No. CPPR-141

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NOTICE OF VIOLATION

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A.

Criterion V requires that instructions, procedures or drawings

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include quantitative or qualitative acceptance criteria for determining whether or not an activity has been satisfactorily accomplished.

Contrary to the above requirement, Change Notice No. 212 to Specification 13-CM-101, Revision 3, was issued March 7, 1977 l

specifying that strict compliance to the requirements of eight concrete aggregate tests was not mandatory. Although the tests were still performed, there were no acceptance criteria.

Con-sequently, for one of these tests (ASTM C235, Soft Fragments),

records establish that aggregate containing nearly three times the previously specified maximum smount of soft fragments has been found acceptable by quality control engineers (Engineers Test Laboratory, Lab / Invoice No. 224-4342-1, dated March 24, 1977). Two other instances of acceptance of questionable aggregate were reported on Lab / Invoice Nos. 224-0261-1 and 224-0261-2 (both dated February 23, 1977) which reference Change Notice No. 212 as the basis for acceptance.

It is noted that five of the eight tests not requiring strict compliance to previous acceptance c-iteria are mandatory in-process tests as specified in ANSI N45.2.5-1974.

The PSAR (Section 3.8) commits to the ANSI standard.

This is an infraction.

RESPONSE

A.

Specification Change Notice (SCN) No. 212 did, in f act, leave the impression that there was no mandatory acceptance criteria for these concrete aggregates.

This situation has been corrected in that Specification 13-CM-101, Revision 5, has been issued to modify and explain that any deviation from tha source acceptance and specification require-i ments will cause a Nonconformance Report (NCR) to be issued.

The disposition of 'the NCR will be based on the field engineer's l

judgement of the effect of the deviation on concrete quality.

Revision 5 to 13-CM-T01 was issued June 20, 1977.

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f Pcg2 2 Variations in the results of these ASTM tests usually indicate changes in production methods and unforeseen variations of the e

pit material.

These changes may result in loss of slump con-trol and require careful consideration as to their acceptability.

Bechtel Engineering has reviewed the variaties in question and has found them acceptable.

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Additionally, Arizona Public Service Company (APS) has instructed l

Bechtel PVNGS Project Management to use the established noncon-formance system for all deviations and to take appropriate steps to assure that these procedures are followed.

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B.

Criterion IX requires special processes, including reinforcing l

bar splicing, to be performed by qualified personnel.

I Contrary to the above requirement, on May 11, 1977 an NRC inspector observed an unqualified worker installing cadweld fixtures on reinforcing steel in the reactor containment base mat area.

It was noted that unqualified personnel were also used for cadweld cartridge loading, reinforcing steel end prep-aration and file reference marking, with no subsequent check of l

these operations by qualified individuals.

This is an infraction.

i

RESPONSE

B.

Contrary to the Bechtel Work Plans Procedures / Quality Control Instructions (WPP/QCI) 56.0, an unqualified worker installed a cadweld fixture and performed cartridge loading. The WPP/QCI l

56.0 was intended to define what steps in the preparation and installation of cadwelds can be done by an unqualified member of the team and which activities must be performed by a qualified operator.

A review of this proccdure and the events of May 11, 1977, indicated that the procedures regulating these activities were not definitive and resulted in this nonconcpliance.

WPP/QCI 56.0 has been revised to clarify (1) the duties of qualified operators and (2) which operations may be accom-plished by unqualified personnel working within the cadweld team.

This procedure now requires that the qualified operator check the work done by the unqualified team member and that quality control inspectors accomplish in-process surveillance of pre-weld operations and that this surveillance be documented.

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f Attachment A Notice of Violation Page 3 f

All of the cadwelds in question were found to be acceptable during the 100% final inspection by quality control. None of the cadweld test samples taken for the containment mat area 1

failed the tensile acceptance criteria.

The procedures change was achieved July 15, 1977.

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ATTACID!ENT B f

1 Arizona Public Service Company (APS) continues to recognize that strict compliance with construction specifications is absolutely necessary.

k'e are also concerned that these con-struction specifications have not been strictly implemented in all cases.

As directed by APS, Bechtel Engineering is in the process of reviewing construction specifications and work procedures to assure that these procedures and specifications adequately express the acceptance and rejection criteria in order to im-prove the understanding and implementation of specification requirements. This will be completed by August 15, 1977.

As stated in our letter ANPP-8766, dated June 21,1977, APS has continued to instruct Bechtel management and has conducted training sessions to improve their implementation of the con-struction specifications.

Bechtel construction has initiated training sessions for superintendents, foremen, quality control and field engineers explaining and clarifying specification requirements and emphasizing that the work procedures must be strictly followed. The Bechtel training sessions began in June, 1977 and will continue until APS is assured that the construction specifications are being implemented.

The rereview of construction specifications by APS, as described in our letter of June 21, 1977, will be completed by July 29, 1977. This rereview is to ensure APS that these specifications do, in fact, reflect the requirements of the PSAR and to pro-vide ready information to audit the implementation of construc-tion procedures.

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p. o. s o x zie s e - awocNix. Anizon A asose July 22, 1977 ANPP-9031 o f.t. N -

U. S. Nuclear Regulatory Coc: mission h

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Office of Inspection and Enforcement

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1 Walnut Creek Plaza - Suite 202

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2900 North California Boulevard Walnut Creek, California 94596 i

U*i'0 Attention:

Mr. G. S. Spencer, Chief Reactor Construction and Engineering Support Branch

Subject:

Docket Nos. 50-528, 50-529 and 50-530 File: 77-058-026

Dear Sir:

This refers to the inspection conducted by Messrs. R. J. Pate and T. W. Bishop on May 9-12, 1977 as documented in your letter dated June 14, 1977 of activities authorized by the Nuclear Regulatory Cor: mission (NRC) Construction Permit Nos. CPPR-141,142 and 143.

As a result of this inspection, a Notice of Violation was written identifying two apparent violations. Our response to this notice is recorded on Attachment A.

You also requested in your letter that we describe those actions taken to improve the implementation of construction procedures.

Our response to the request appears in Attachment B.

Arizona Public Service Company recognizes its responsibility in assuring the implementation of construction procedures. We have initiated considerable effort in this regard and will continue this effort until the procedures are strictly followed.

Very truly your k

E.T.\\ d, i E. E. Van Brunt, Jr.

APS Vice President Construction Projects ANPP Project Director EEVBJr/ JAR:ske Attachments cc:

R. L. Robb B. S. Kaplan W. H. Wilson W. M. Petro J. M. Allen J. E. Bashore R. L. Hand A. C. Gehr C. Betzhold

ATTACILMENT A Docket No. 50-528 Construction Permit No. CPPR-141 NOTICE OF VIOLATION A.

Criterion V requires that instructions, procedures or drawings include ' quantitative or qualitative acceptance criteria for determining whether or not an activity has been satisfactorily accomplished.

Contrary to the above requirement, Change Notice No. 212 to Specification 13-CM-101, Revision 3, was issued March 7, 1977 specifying that strict compliance to the requirements of eight concrete aggregate tests was not mandatory. Although the tests were still performed, there were no acceptance criteria.

Con-sequently, for one of these tests (ASTM C235, Soft Fragments),

records establish that aggregate containing nearly three times the previously specified maximum smount of sof t fragments has been found acceptable by quality control engineers (Engineers Test Laboratory, Lab / Invoice No. 224-4342-1, dated March 24, 1977). Two other instances of acceptance of questionable aggregate were reported on Lab / Invoice Nos. 224-0261-1 and 224-0261-2 (both dated February 23, 1977) which reference Change Notice No. 212 as the basis for acceptance.

It is noted that five of the eight tests not requiring strict compliance to

(

previous acceptance criteria are mandatory in-process tests as specified in ANSI N45.2.5-1974.

The PSAR (Section 3.8) commits to the ANSI standard.

i This is an infraction.

l l

RESPONSE

i

'A.

Specification Change Notice (SCN) No. 212 did, in f act, leave the impression that there was no mandatory acceptance criteria i

for these concrete aggregates.

This situation has been corrected in that Specification 13-CM-101, Revision 5, has been issued to modify and explain that any deviation from the source acceptance and specification require-ments will cause a Nonconformance Report (NCR) to be issued.

The disposition of the NCR will be based on the field engineer's l

judgement of the effect of the deviation on concrete quality.

Revision 5 to 13-CM-101 was issued June 20, 1977.

L

o rage.

Variations in the results of these ASTM tests usually indicate changes in product *oc methods and unforeseen variations of the pit material.

Tht. su changes =ay result in loss of slump con-trol and require tareful consideration as to their acceptability.

Bechtel Engineerin3 has reviewed the variaties in question and has found them acceptable.

l

' Additionally, Arizona Public Service Company (APS) has instructed Bechtel PVNGS Project Management to use the established noncon-formance system for all deviations and to take appropriate steps to assure that these procedures are followed.

B.

Criterion IX requires special processes, including reinforcing bar splicing, to be performed by qualified personnel.

Contrary to the above requirement, on May 11, 1977 an NRC inspector observed an unqualified worker installing cadweld fixtures on reinforcing steel in the reactor containment base mat area. It was noted that unqualified personnel were also used for cadweld cartridge loading, reinforcing steel end prep-aration and file reference marking, with no subsequent check of these operations by qualified individuals.

'This is an infraction.

RESPONSE

B.

Contrary to the Bechtel Work Plans Procedures / Quality Control Instructions (WPP/QCI) 56.0, an unqualified worker installed a cadweld fixture and performed cartridge loading. The WPP/QCI 56.0 was intended to define what steps in the preparation and installation of cadwelds can be done by an unqualified member of the team and unich activities must be performed by a qualified operator. A review of this procedure and the events of May 11, 1977,inaicated that the procedures regulating these activities were not definitive and resulted in this nonconspliance.

WPP/QCI 56.0 has been revised to clarify (1) the duties of qualified operators and (2) which operations may be accom-plished by unqualified personnel working within the cadweld team. This procedure now requires that the qualified operator check the work done by the unqualified team member and that quality control inspectors accomplish in-process surveillance of pre-weld operations and that this surveillance be documented.

S

Attechment a Notiice of Violation Page 3 All of the cadwelds in questfon were found to be acceptable during the 1007. final inspection by quality control. None of the cadweld test samples taken f or the containment mat area failed the tensile acceptance criteria.

The procedures change was achieved July 15, 1977.

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ATTACILStENT 3 Arizona Public Service Company (APS) continues to recognize that strict compliance with construction specifications is absolutely necessary. We are also concerned that these con-struction specifications have not been strictly implemented in all cases.

As directed by APS, Bechtel Engineering is in the process of reviewing construction specifications and work procedures to assure that these procedures and specifications adequately express the acceptance and rejection criteria in order to im-prove the understanding and implementation of specification requirements. This will be completed by August 15, 1977.

As stated in our letter ANPP-8766, dated June 21,1977, APS has continued to instruct Bechtel management and has conducted training sessions to improve their implementation of the con-struction specifications.

Bechtel construction has initiated training sessions-f or superintendents, foremen, quality control and field engineers explaining and clarifying specification requirements and emphasizing that the work procedures must be strictly followed. The Bechtel training sessions began in June, 1977 and will continue until APS is assured that the construction specifications are being implemented.

The rereview of construction specifications by APS, as described in our letter of June 21, 1977, will be completed by July 29, 1977. This rereview is to ensure APS that these specifications do, in fact, reflect the requirements of the PSAR and to pro-vide ready information to audit the implementation of construc-tion procedures.

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