ML20154N377

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-528/85-31

ML20154N377
Person / Time
Site:	Palo Verde
Issue date:	03/11/1986
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
NUDOCS 8603170306
Download: ML20154N377 (1)

See also: IR 05000528/1985031

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MAR 111986 .

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' Docket No. 50-528

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Arizona Nuclear Power Project

P. O. Box 52034

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Phoenix, Arizona 85072-2034

Attention: Mr. E. E.' Van ' Brunt,' Jr.

Executive Vice President

Gentlemen:

Thank you for your letter dated January 17, 1986, informing us of the steps-

you have taken to correct the items which we brought to your attention in our ,

' letter dated December 19, 1986. Your corrective actions will be verified

during a future inspection.

Your cooperation with us is appreciated.

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Sincerely, ,

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Orfgfnci signelt tiy .

D.h.IYUEEbh, Director .

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Division of Reactor Safety and

n: Proj ects '

bec w/ copy of letter dated 1/17/86:

. G. Cook, RV'

B. Faulkenberry, RV

J. Hartin, RV

Resident' Inspector

Project Inspector

RSB/ Document Control Desk (RIDS)

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, P O Box $2034 e PHOENIX. ARIZONA 85072-2014

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O i January 17,8EGif/T$P/98.05

ANPP-34681-

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U. S. Nuclear Regulatory Commission

Region V

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1450 Maria Lane, Suite 210

Walnut Creek, CA 94596-5368

Attention: Mr. D. F. Kirsch, Deputy Director

Division of Reactor Safety and Projects

Subject: Palo Verde Nuclear Generating Station (PVNGS)

Unit 1

Docket No. STN 50-528 (License NPF-41)

Response to Notice of Violations: 50-528/85-31-09, 50-528/85-31-06;

and Response to Notice of Deviation: 50-528/65-31-04.

File: 86-070-026; D.4.33.2

Reference: NRC Inspection Report 50-528/85-31, letter from D. F. Kirsch to

E. E. Van Brunt, dated 12/19/85

Dear Sir:

This letter is provided in response to the inspection conducted by

Mr. S. Richards and other members of the NRC staff on October 28 through

November 8, 1985 of activities authorized by NRC, License No. NPF-41. Based

on the results of the inspection, two violations of NRC requirements

(administration of temporary modifications) and one deviation (design

verification) were identified. The two violations were discussed in Items A

and B in Appendix A of the referenced letter. The deviation was discussed in

Appendix B of the referenced letter. The Arizona Nuclear Power Project (ANPP)

responses to these items are submitted herewith in Attachments A and B to this

letter.

With respect to the general areas of perceived weakness identified by the NRC

in the referenced Inspection Report, ANPP will address these areas and include

its responses to these areas along with the transmittal of the final response

to Item B which is discussed in Attachment A to this letter.

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Mr. D. F. Kirsch

PVNGS L' nit 1 Notice of Violations and Deviation

50-528/85-31-09, 50-528/85-31-06 and 50-528/85-31-04

Page 2

ANPP- 34681

Should there be any further concerns, ANPP will be pleased to discuss them

with you.

Very truly yours,

E G Vs>< 0 w N n g

E. E. Van Brunt , Jr.

Executive Vice President

Project Mrector

EEVB/ TAP /dla

Attachments

cc A. C. Gehr

R. P. Zimmerman

E. A Licitra

L. F. Miller

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. ATTACHMENT A

NOTICE OF VIOLATION

o-- Arizona Public Service Company Docket No. 50-528

P. O. Box 21666 License No. NPF-41

Phoenix, Arizona 85036 ,

As a result of the inspection conducted during the period of October 28

through November 8,1985, two violations of NRC requirements were identified.

The violations involved failure to follow the procedure controlling temporary

modifications and failure to properly evaluate a change to a plant system. In

accordance with the NRC Enforcement Policy,10 CFR Part 2, Appendiz C, the

following violations are listed below:

A. 10 CFR 50 Appendix B, Criterion V, as addressed in Section 17 of the

Final Safety Analysis Report (FSAR), requires that activities affecting

quality be prescribed by and accomplished in accordance with documented

procedures. g

s Station Manual Procedure Number 73AC-92205, " Temporary Nodification

Control," Section 371.13, requires that independent verification of

quality related temporary modifications be performed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of

the time the temporary modification is implemented.

Contrary to the above, temporary modifications 1-85-CH-320, which

altered the capacity of various anubbers on quality related systems and

was installed on July 27, 1985 but not verified until October 25, 1985

and temporary modification.1-65-RC-181, which altered a pipe support for

the pressuriser spray line was installed but not independently verified

(at the time of the inspection) to be properly implemented within 8

hours of their implementationA

This is a Severity Invel IV Violation (Supplement I).

B. 10 CFR 50.59, parasraph (b) requires in part that changes to the

facility as described in the Safety Analysis Beport include a written

safety evaluation which provides the basis for the determination that

the chanse does not involve an unreviewed safety question.

Contrary to the above, on October 31, 1985,,the independent air receiver

tanks of the "A" emergency diesel generator air start system were cross

connected by a temporary jumper host without a written safety evaluation

/ being performed.

This is a Severity Level V Violation (Supplement I).

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RESPONSE TO NOTICE OF VI0IATION (50-528/85-31-09)

- ITEM A

I. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

As a result of this violation, a review of Temporary Modifications (TMs)

1-85-RC-181 and 1-85-CH-320 was performed which revealed:

1) Only one TM was required to be installed to Revision 3 of

73AC-92205, and

2) On the date of each TMs installation, there were at least three

verifications of each modification.

Temporary Modification 1-85-RC-181 was installed to Revision 2 of

73AC-92205 per contractor Work Order (CWO) 86071 on 5/15/85. Since

Revision 3 of this procedure did not become effective until 6/20/85,

Revision 2 was required to be used for this modification. Revision 2 of

73AC-92205 Paragraph 5.3.3 required the installer to have an independent

verifier designated. This paragraph required verification of

installation by signing page 4 of Appendir A of the Temporary

Modification Request, but not within the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time restriction

presently in Revision 3 of 73AC-9ZZ05. The revision of the procedure in

effect at the time of the modification (Revision 2) did not require the

8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit. Additionally, the Temporary Modification was

installed per CWO 86071 which required the Bechtel Area Field Engineer

(AFE) and Quality Control Engineer (QCE) to verify the work performed.

We work was verified upon completion by the Bechtel AFE and QCE in the

CWO and by ANFP Ops Engineering in Block 34 of the Temporary

Modification Request all signed on 5/15/85. ANPP, therefore, believes

the Notice of Violation cited for t g temporary _ modification is

1. [ inappropriate.

Temporary Modification 1-85-CH-320 was installed to Revision 3 of

73AC-92205 per CWO 98018 on 7/27/85. We CWO required a verification

and signature for the installation by the Bechtel Area Field Engineer

and Quality control Engineer. Wese steps were signed upon completion

of the installation on 7/27/85. The ANPP Ops Engineer signed on Block

34 of the IMR also on 7/27/85. A discussion with the ANPP Outage

Management Engineer (OME) revealed he did not realise the requirement of

Paragraph 5.1.10 of 73AC-92205 Rev. 3 at the time of installation. his

paragraph states that an ANPP Outage Management Group (ONG) member is

responsible for compliance to the Procedure for Temporary Modifications

installed or removed by use of CWO's. We ONE erred in not ensuring

Block 35 was signed within the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit because the procedure

had been recently revised from Revision 2 to Revision 3 prior to the

work. This temporary modification was ultimately independently verified

by an ANPP Ops Engineer on 11/25/85. (Note: The Notice of Violation

states 10/25/85).

The information presented above indicates that no proepdure violation

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occurred during installation of 1-85-RC-181, however,(a minor procedural

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violationdidoccurduringtheinstallationof1-85-CH-320.b

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, he conditions stated in this violation have been addressed and the

following corrective steps have been taken.

1. ONG will review all Temporary Modifications installed or restored

using a Contractor Work Order to ensure compliance with 73AC-92ZO5

Rev. 3. This review will include all Temporary Modifications

installed / restored since 6/20/85.

II. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITDIS OF

NONCOMPLIANCE

1. ANPP Memo ANPM-00449/ PIA-94.05 has been issued to require retraining

to 73AC-9ZZ05 Rev. 3 by all Outage Management Personnel.

2. A Procedural Change Notice (PCN) is being initiated to 73AC-9ZZ05 to

further clarify the Outage Management Department responsibility with

respect to this issue.

III. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

1. The review of Temporary Modifications installed as 6/20/85 is

espected to be completed by 2/15/86.

2. Retraining of Outage Management Mrsonnel to 73AC-9ZZ05 will be

completed by 1/31/86.

3. The PCN issued to clarify 73AC-92205 is expected to be completed by

2/1/86

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RESPONSE TO NOTICE OF VIDIATION (50-528/85-31-06)

ITEM B .

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I. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

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ANPP is currently investigating the implications of this violation with

respect to the approach in the performance of written safety ' evaluation

, as required by 10CFR50.59 and with respect to operational activities.

- As discussed in a telephone conversation between Mr. L. F. Miller

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/' (Region V) and Mr. T. A. Petersen (ANPP) on January 14, 1986, Mr. Miller

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to transmit a final response to

g/g explained 4 hat ittowould

this. violation beatacceptable

the NRD a later date provided a justification and a

proposed schedule for resolution be provided in the initial 30 day

response letter required. The preceding information provides the ANPP

j j justification for a subsequent final responsel the final response is -

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fW scheduled to be submitted as provided below.

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II. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF

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NONCOMPLIANCE

This ites will be fully addressed in the ANPP final response to this

violation.

III. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

The ANPP final response to this violation is scheduled to be submitted

by February 5, 1986.

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, ATTACHMENT B

NOTICE OF DEVIATION

Arizona Public Service Company Docket No. 50-528

P. O. Box 21666 License No. NPF-41

Phoenix, Arizona 85036

As a result of the inspection conducted October 28 through November 8,1985, a

deviation involving inadequate control of the design process was identified. .

In accordance with the NRC Enforcement Policy,10 CFR Part 2, Appendiz C, 47

FR 9887 (March 9, 1982) the deviation is described below:

Section 1.8 of the Palo Verde Nuclear Generating Station FSAR endorses

Regulatory Guide 1.64 (Revision 2) for operations phase activities with

the following exception to position C.2 of the regulatory guide ,

" Supervisory personnel may perform design verification under exceptional

circumstances as documented and approved by the next level of

supervision, if the justification...is individually documented and

approved in advance."

Contrary to the above commitment, the Bechtel engineering organisation

has used their supervisors to perfora design verification reviews l

without documented individual justification being approved in advance

for each and every design change package since commencement of thit 1

operations activities (i.e., January 1985).

This is a deviation.

Please submit to this office within thirty days of the date of this

notice a written statement or explanation regarding the above ites,

describing corrective steps taken, the results achieved (or corrective

steps that are planned), and the date when corrective actions will be

completed.

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• RESPONSE TO NOTICE OF DEVIATION (50-528/85-31-04)

I. CORRECTIVE STEPS TAKEN

PSAR Section 1.8 taposes the requirements of Regulatory Guide 1.64,

Revision 2 af ter the issuance of an Operating License. It also allows

(as discussed in the Notice of Deviation) the exception to position C.2

of the regulatory guide. For activities to be performed prior to the

issuance of an operating license, the Bechtel program complies with ANSI

N45.2.11-1974, Section 6.1, which allows design verification to be

performed by the originator's supervisor without prior accumented

approval. Regulatory Guide 1.64, Revision 2, effectively takes

exception to ANSI N45.2.11, Section 6.1, by not allowing the

originator's supervisor to perfora design verification. Sinca Bechtel

Engineering was neither fully aware of the programatic lapact of

Regulatory Guide 1.64, Revision 2, ou operations phase activities nor

that portion of the ANPP Operational QA Program which endorses

Regulatory Guide 1.64 Revision 2 and complies with the FSAR, the

requirement of ANSI N45.2.11-1974, Section 6.1, which had been used for

construction phase activities continued to be used since commencement of

Unit 1 operations activities. The regularly scheduled audit, by ANFP

QA, of techtel's on site design activities in January, 1985 did not

identify this inconsistency since Bechtel had not yet performed safety

related design activities under the newly issued operating license for

Unit.1. The audit scoping matriz for ANPP requires that the Design

Qiange Backages (DCPs) looked at during the on-site audit of Bechtel be

used for the ANPP QA audit of Bechtel's design office (NORWALK). Since

no safety related DCPs had been generated, as stated above, this area

was not esamined during the design office audit, therefore, ANPP QA did

not discover this inconsistency. Because of this inconsistency between

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the design review requirements for operations phase activities and the

design review requirements that were actually being performed , the

following corrective steps were taken:

1. ANPP QA initiated CAR No. CA85-0252 on 11/12/85 that required

Bechtel to address the issue of supervisors performing design

verifications. 7-

2. A complete review of FSAR Section 1 has been completed by Bechtel

Quality Assurance for other impacts to the ANPP Operational QA

Program.

3. Bechtel has completed a review of all their project procedures

which involve design verification in accordance with Regulatory

Guide 1.64, Revision 2 and ANSI N45.2.11. Only the following

procedures were found to be in need of revision or clarification to

demonstrate complisace with the Operational QA Program with respect

to supervisors performing design verifications:

IP-4.12, " Project Engineering Drawings and Drawing Change Notices"

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e ' RESPONSE TO NOTICE OP DEVIATION (50-528/85-31-04) cont'd

I. CORRECTIVE ST DS TAKEN (Cont'd)

IP-4.14, " Specification Change Notice"; and

IP-5.15, " Supplier Deviation Disposition Requests".

4. Bechtel issued to responsible personnel an Inter-office Memorandum,

dated 12/9/85 which described interia changes to their Internal

Procedures necessary to ensure documented independent design

verification and to preclude the immediate supervisor from this

activity.

II. REJULTS ACHIEVED OR CORRECTIVE STEPS PIANNED

Essed on the corrective steps taken, the following results have been

achieved:

1. The review of PSAR Section 1.8 by Bechtel Quality Assurance

concluded that no other conditions similar to the design

verification problem were found to exist.

2. Bechtel has initiated changes to procedures IP-4.12, IP-4.14, and

IP-5.15, as discussed in Item I.2, above, to provide independent

design verification separate from the immediate supervisor to

comply with Regulatory Guide 1.64, Revision 2, requirements.

3. The interia changes described in Bechtel's Inter-office Memorandum,

dated 12/9/85, brought the Internal Procedures into compliance with

the ANFP Operational QA Program.

4. ANPP QA/QC have reviewed and accepted Bechtel's response to CAR No.

CA85-0252. This response concluded that the deficiency was purely

programatic, and had no 1spect on the design work performed by

Bechtel since issuance of the Unit 1 Operating License. ANEP is

currently verifying the response.

5. ANPP QA will perform a review of major design contractor programs

and procedures to ensure applicable design control regulatory

requirements are adequately addressed.

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.' RESPONSE TO NOTICE OF DEVIATION (50-528/85-31-04) cont'd

III. DATE WHEN CORRECTIVE ACTIONS WILL BE COMPLETED

Corrective actions that remain to be completed are scheduled to be

completed as follows:

1. The changes to Bechtel Internal Procedures IP-4.12, IP-4.14, and

IP-5.15 were approved for use by Bechtel on January 8,1986.

2. The verification of the conclusion that there was no impact on the

design work performed by Bechtel since the issuance of the Uhit 1

Operating License is scheduled to be completed by the end of first

quarter 1986.

3. The review of major contractor design programs and procedures is

scheduled to be completed by the end of second quarter 1986.

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