ML20207S834

Final Part 21 & Deficiency Rept RER-GSE 86-41 Re Control of Design Change Packages (Dcp).Initially Reported on 861205. Review & Correction of DCPs Will Be Completed by 870101. Conditions Not Reportable Per 10CFR50.55 & Part 21

ML20207S834
Person / Time
Site:	Palo Verde
Issue date:	03/06/1987
From:	Haynes J ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
REF-PT21-87, REF-PT21-87-052-000 023-02106-JGH-D, 23-2106-JGH-D, PT21-87-052-000, PT21-87-52, RER-QSE-86-41, NUDOCS 8703200313
Download: ML20207S834 (5)

Text

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j;p Arizona Nuclear Power Project /g P.o. BOX 52034

• PHOENIX. ARIZONA 85072-2034 h' March 6, 1987 0,

023-02106-JGH/DRL Up U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane - Suite 210 Walnut Creek, California 94596-5368 Attention: Mr. D. F. Kirsch, Director Division of Reactor Safety & Projects Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, 3 Docket No. 50/528, 529, 530

Subject:

Final Report - RER-QSE 86-41 A 50.55(e) and 10CFR21 Evaluation Relating to Control of DCP's File: 87-006-216

Reference:

(A) Telephone conversation between Jo Bianchi for R. C. Sorenson and D. R. Larkin on December 5, 1986. (Initial Notification -

RER-QSE 86-41)

(B) ANPP-39577, dated January 2, 1987 (Interim Report - RER-QSE 86-41)

Dear Sir:

The NRC was notified of a potentially reportable deficiency in reference (A) and an interim report by reference (B). Attached, is our final written report of the deficiency under the requirements of 10CFR50.55(e) and 10CFR21.

Very truly yours, Af*f J. G. Haynes Vice President Nuclear Production JGH/DRL/lks cc: See Page Two Vf S

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..1 j RER-QSE 86-41

' Mr. D. F. Kirsch Director March 6, 1987 023-02106-JGH/DRL Page Two cci 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 Atlanca, Georgia 30339 l

l

FINAL REPORT - RER-QSE 86-41 DEFICIENCY EVALUATION 50.55(e)

ARIZONA NUCLEAR POWER PROJECT (ANPP)

PVNGS UNITS 1, 2, 3 I. Description of Deficiency Quality Assurance identified three cases where it appeared that Limitorque Operators had been withdrawn from the warehouse without required design changes. Additionally, six Limitorque Operators still in the warehouse did not appear to have required design changes.

This deficiency was documented on Corrective Action Report CP86-0194.

Evaluation The evaluation of this deficiency included a review of the Limitorque Operators apparently installed without the required design change as well as the six Limitorque Operators remaining in the warehouse.

Additionally, a review was conducted of a sample of other DCP's to determine if warehouse material impacts were properly addressed.

Finally, the applicable procedures were reviewed to determine if controls adequately established who was responsible for implementing DCP's into warehouse stock and how the warehouse material would be controlled during the process.

The review of the Limitorque Operators apparently installed without incorporation of the design change indicated that in one case the design change had actually been incorporated. In the other cases the evaluation revealed that the design change was not required to be installed for the particular non quality related application in which the Limitorque Operator was utilized.

Six (6) Limitorque Operators located in the warehouse were identified as being affected by design change. All six (6) of these operators have been put into Quality Control (QC) Quarantine with Non Conformance (NCR) tags. These operators will be inspected and DCP's incorporated, if required, prior to these operators being released from hold.

At the present time, approximately 10,900 DCP's have been issued.

l Of these, 3,700 (1/3 of the total DCP's) were reviewed to determine if there was a potential material impact. The results indicated that there were 243 DCP's with potential warehouse material impact. Of the 243, a random sample of 111 DCP's were studied in detail. Twelve (12) of these did have potential impacts, seven (7) impacted only material still in the warehouse, and five (5) had the potential to have affected equipment installed at PVNGS. An evaluation of the five (5) cases which could have affected installed equipment indicated, because of other inspections, engineering evaluations or work activities, no installed equipment had been affected, i

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y- .

-A review of the procedures in place to ensure incorporation of DCP's into warehouse equipment / material and updating of the appropriate data bases was performed.. The review indicated two deficiencies:

A. The . Design Change Package Instruction did not clearly define a requirement to address, within the DCP, the impact on SIMS, MMIS, warehouse stock and procurement documents.

B. Station Manual Procedure 73AC-0ZZ15' failed to reflect responsibility changes due to changing department scope and to clearly define-requirements and responsibilities for departments to review and implement DCP's/PCP's.

Transportability The sampic review of DCP's indicated that in a small number of cases implementation of DCP's did have material impacts for warehouse material /

equipment and associated data bases which were not properly implemented.

The review also determined that currently installed equipment is not affected.

Root Cause The root cause has been determined to be inadequate or unclear pro-cedures for handling material impacts of DCP's (other than the direct impact on installed equipment). An additional cause was an organizational change which did not fully consider reassignment of responsibilities.

Safety _ Significant Assessment In the case of both the initially identified deficiencies as well as those resulting from the sample review of DCP's, the deficiencies do not affect installed equipment. Therefore, the deficiency has not adversely affected the safety of operation.

II. Analysis of Safety Implications Based on the above, these conditions were evaluated as Not Reportable under the requirements of 10CFR50.55(e) and 10CFR21 since no safety-significant concerns were identified and therefore they would not constitute a safety-significant condition.

III. Corrective Action A. A review of the balance of DCP's will be completed by July 1, 1987.

Any identified deficiency will be corrected. If a safety-significant condition-is identified, the NRC will be notified.

B. Interim controls to ensure proper control of safety-related spare parts affected by DCP's issued after March 15, 1987, have been developed and will be in place by March 13, 1987.

9. . . . . .,,

r C. ' Permanent programmatic control will be developed in procedures and department instructions by April 15, 1987.

'D. 'A procedure has been approved to ensure that responsibilities are reviewed / reassigned as necessary when organization changes are made.

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