ML20076E142: Difference between revisions
StriderTol (talk | contribs) (StriderTol Bot insert) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
| (One intermediate revision by the same user not shown) | |||
| Line 2: | Line 2: | ||
| number = ML20076E142 | | number = ML20076E142 | ||
| issue date = 04/04/1983 | | issue date = 04/04/1983 | ||
| title = Responds to NRC | | title = Responds to NRC Re Violations Noted in IE Insp on 830104-07 & 17-21.Corrective actions:6-inches of Pipe & Weld Replaced.Listed Supports Installed on 830323 Per Design Change Package 1-SS-RD-013 | ||
| author name = Van Brunt E | | author name = Van Brunt E | ||
| author affiliation = ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR | | author affiliation = ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR | ||
| Line 11: | Line 11: | ||
| contact person = | | contact person = | ||
| document report number = ANPP-23414-BSK, NUDOCS 8305260321 | | document report number = ANPP-23414-BSK, NUDOCS 8305260321 | ||
| title reference date = 03-02-1983 | |||
| package number = ML20076E136 | | package number = ML20076E136 | ||
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC | ||
| Line 17: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:\\ | ||
fr. | |||
fr. | ,<. y, Arizona Public Service Companyy P O 00X 21666 | ||
* PHOENIX. ARiZON A 85036 | * PHOENIX. ARiZON A 85036 | ||
,/,. | |||
' '? | |||
April 4,L1983 ANPP-23414-BSK/ JAR U. S. Nuclear Regulatory Commission Region V Creekside Oaks Office Park 1450 Maria Lane - Suite 210 Walnut Creek, California 94596-5368 Attention: | April 4,L1983 ANPP-23414-BSK/ JAR U. S. Nuclear Regulatory Commission Region V Creekside Oaks Office Park 1450 Maria Lane - Suite 210 Walnut Creek, California 94596-5368 Attention: | ||
Mr. D. M. Sternberg, Chief Reactor Projects Branch No. 1 | |||
==Subject:== | ==Subject:== | ||
| Line 30: | Line 31: | ||
==Dear Sir:== | ==Dear Sir:== | ||
This letter refers to the special Inspection conducted by Mr. P. P. Narbut on January 4-7 and 17-21, 1983, as documented in your letter of March 2, 1983, of activities authorized by the Nuclear Regulatory Commission (NRC) | This letter refers to the special Inspection conducted by Mr. P. P. Narbut on January 4-7 and 17-21, 1983, as documented in your letter of March 2, 1983, of activities authorized by the Nuclear Regulatory Commission (NRC) | ||
Construction Permit No. CPPR-141. | Construction Permit No. CPPR-141. | ||
During this Inspection, two (2) items of noncompliance were identified. | During this Inspection, two (2) items of noncompliance were identified. | ||
Our response to these items of noncompliance (Severity Level V-Supplement II) is presented in the enclosed Attachment A. | Our response to these items of noncompliance (Severity Level V-Supplement II) is presented in the enclosed Attachment A. | ||
Very truly y | Very truly y rs, CLLL rRLL N | ||
8305260321 830503 | E. E. Van Brunt, Jr. | ||
G. C. Andognini J. R. Bynum D. B. Fasnacht A. C. Rogers W. E. Ide C. N. Russo G. E. Pankonin A. C. Gehr l | 8305260321 830503 gDRADOCK 05000528 APS Vice President PDR Nuclear Projects ANPP Project Director EEVBJr/BSK:ske Enclosure cc: | ||
T. G. Woods, Jr. | |||
G. C. Andognini J. R. Bynum D. B. Fasnacht A. C. Rogers W. E. Ide C. N. Russo G. E. Pankonin A. C. Gehr l | |||
W. II. Wilson l | |||
R. L. Patterson R. M. Grant l | |||
D. R. Hawkinson l | |||
t | t | ||
a | a o | ||
t STATE OF ARIZONA | |||
) | |||
COUNTY OF MARICOPA ) | ) ss. | ||
I, | COUNTY OF MARICOPA ) | ||
J | I, E. E. Van Brunt, Jr. | ||
m b | , represent that I am Vice President, Nuclea.- Projects of Arizona Public Service Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority so to do, that I have read such document and know its contents, and that to the best of my knowledge and belief, the statements made therein are true, s | ||
J | |||
~ | |||
4 | m b | ||
(_., | |||
dLb b | |||
b rA Sworn to before me this V day of Orii i | |||
i 19 kb. | |||
4 Ne. | |||
ZW Notary Public My Commission Expires: | |||
1 g | 1 g | ||
/ | |||
i | i | ||
~ | |||
''s ATTACHMENT A | |||
-NOTICE OF VIOLATION Docket No. 50-528 Construction Permit No. CPPR-141 As a result of the Inspection _ conducted on January 4-7 and'17-21, 1983, and in accordance with the NRC Enforcement Policy 10CFR Part 2, Appendix C, 47FR9987 (March 9,1982), the following Violations were identified: | |||
A. 10CFR50, Appendix B, Criterion V, as addressed in Section 17 of the PSAR, states,.in part: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the-cir-cumstances and shall be accomplished in accordance with these instructions, procedures, or drawings...." | A. | ||
10CFR50, Appendix B, Criterion V, as addressed in Section 17 of the PSAR, states,.in part: | |||
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the-cir-cumstances and shall be accomplished in accordance with these instructions, procedures, or drawings...." | |||
Bechtel Welding Standard WD-1, Revision 1, dated February 17, 1981, Paragraph 1.3, states: | Bechtel Welding Standard WD-1, Revision 1, dated February 17, 1981, Paragraph 1.3, states: | ||
"This procedure includes checklists and other forms to be used for documenting satisfactory accomplish-ment of the fabrication and examination processes. | |||
The use of these checklists and forms provides assurance that welding is performed and examined in accordance with specified procedures, that welding procedures and welders and/or welding operators are qualified in accordance with the ASME Code, Section IX, and that specified and certified materials are used for fabrication. Provisions are made for wit-nessing or inspecting by the Authorized Nuclear Inspector (ANI) ." | The use of these checklists and forms provides assurance that welding is performed and examined in accordance with specified procedures, that welding procedures and welders and/or welding operators are qualified in accordance with the ASME Code, Section IX, and that specified and certified materials are used for fabrication. Provisions are made for wit-nessing or inspecting by the Authorized Nuclear Inspector (ANI)." | ||
Contrary to the above, on or about February 12, 1982, an unauthorized, undocumented weld was made in Line RDB-012-XCCA-4'l one inch (1") North of Field Weld FW-302 shown on MCN-1-10441P dated January 9,1982. The weld was subse-quently ground even with the pipe on the outside and inside diameter to make visual detection of the weld difficult. | Contrary to the above, on or about February 12, 1982, an unauthorized, undocumented weld was made in Line RDB-012-XCCA-4'l one inch (1") North of Field Weld FW-302 shown on MCN-1-10441P dated January 9,1982. The weld was subse-quently ground even with the pipe on the outside and inside diameter to make visual detection of the weld difficult. | ||
This is a Severity Level V Violation (Supplement III), | This is a Severity Level V Violation (Supplement III), | ||
| Line 67: | Line 79: | ||
L | L | ||
o | ' o Attachment A Notice of Violation Page 2 Response to Item A 1. | ||
Attachment A Notice of Violation Page 2 Response to Item A | Corrective Steps Taken and Results Achieved Nonconformance Report No. WA-673 was prepared describing the presence of the undocumented weld. | ||
The disposition required replacing a six-inch (6") | The disposition required replacing a six-inch (6") | ||
length of pipe that included the weld in question, as well as the sockolet and two (2) welds, FW-332 and FW-303. | length of pipe that included the weld in question, as well as the sockolet and two (2) welds, FW-332 and FW-303. | ||
2. | |||
Corrective Steps That Have Been Taken to Avoid Further Noncompliances The alleger claims he made the weld in question. | |||
He did not claim to have knowledge of any others. | He did not claim to have knowledge of any others. | ||
This is considered an isolated incident. However, the implications of this incident, and the serious nature of the Violation, will be discussed with all welder foremen to reemphasize the absolute necessity to comply with all jobsite procedures controlling welding operations. | This is considered an isolated incident. However, the implications of this incident, and the serious nature of the Violation, will be discussed with all welder foremen to reemphasize the absolute necessity to comply with all jobsite procedures controlling welding operations. | ||
3. | |||
Date When Full Compliance Will Be Achieved Full compliance was achieved on March 15, 1983, with the completion of the work described on Nonconformance Report No. WA-673. The work was performed, inspected and documented in accordance with approved Project procedures. | |||
Discussions with all welder foremen will be accomplished by April 15, 1983. | Discussions with all welder foremen will be accomplished by April 15, 1983. | ||
( | ( | ||
B. | |||
10CFR50, Appendix A, Criterion 1, states, in part: | |||
" Structures, systems and components important to safety shall be designed, fabricated, erected and tested to quality standards commensurate with the importance of the safety functions to be performed. | |||
Where generally recognized codes and standards are used, they shall be identified....to assure a quality product in keeping with the required safety function. | Where generally recognized codes and standards are used, they shall be identified....to assure a quality product in keeping with the required safety function. | ||
l l | l l | ||
| Line 84: | Line 99: | ||
Attachment A Notice of Violation Page 3 The Arizona Nuclear Power Project Design Criteria Manual, Part III, Revision 3, dated October 5, 1979, for the " Radioactive Waste Drains System", Paragraph 1.2.b, identifies "American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section III" as the applicable Code for " Piping and Valves Auxiliary Building Engineered Safety Features (ESF) Room Drainage". | Attachment A Notice of Violation Page 3 The Arizona Nuclear Power Project Design Criteria Manual, Part III, Revision 3, dated October 5, 1979, for the " Radioactive Waste Drains System", Paragraph 1.2.b, identifies "American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section III" as the applicable Code for " Piping and Valves Auxiliary Building Engineered Safety Features (ESF) Room Drainage". | ||
The ASME Boiler and Pressure Vessel Code, Section III, Subsection ND, 1974 Edition, including the Winter 1975 Addenda, Paragraph ND 3676.9, states: | The ASME Boiler and Pressure Vessel Code, Section III, Subsection ND, 1974 Edition, including the Winter 1975 Addenda, Paragraph ND 3676.9, states: | ||
Contrary to the above, pipe supports were not engineered or provided for the Radioactive Waste Drain System Piping added to Drawing No. 13-P-ZAE-200, Revision 6, by Drawing Change Notices (DCN's) No. 7 and No. 8. The piping was installed without pipe supports as authorized by Modification Change Notice No. 1-10441P, dated January 9, 1982, which was verified-complete by the Quality Control Inspector on March 4, 1982. | " Supports shall be furnished as specified in Subsection NF to protect piping against detrimental sagging, external mechanical injury, abuse and exposure to unusual service conditions." | ||
Contrary to the above, pipe supports were not engineered or provided for the Radioactive Waste Drain System Piping added to Drawing No. 13-P-ZAE-200, Revision 6, by Drawing Change Notices (DCN's) No. 7 and No. 8. | |||
The piping was installed without pipe supports as authorized by Modification Change Notice No. 1-10441P, dated January 9, 1982, which was verified-complete by the Quality Control Inspector on March 4, 1982. | |||
This is a Severity Level V Violation (Supplement II), applicable to Unit #1. | This is a Severity Level V Violation (Supplement II), applicable to Unit #1. | ||
Response to Item B | Response to Item B 1. | ||
Corrective Steps Taken and Results Achieved The cause is attributed to oversight. The original design did not require supports; however, the design change which added drain pipes should have also required the installation of pipe supports. Engineering has analyzed the subject lines shown on Drawing No. 13-P-ZAE-200 and the following supports were designed Janu-ary 27, 1983 and were installed in Unit #1 by March 23, 1983, as per Design Change Package (DCP) No. 1-SS-RD-013: | |||
Pipe Support No. | Pipe Support No. | ||
13-RD-006-H-00A | Line No. | ||
13-RD-006-H-00A RD-A-006-XCCA-1" 13-RD-006-H-001 RD-A-006-XCCA-4" 13-RD-012-H-00A RD-B-012-XCCA-1" 13-RD-012-H-001 RD-B-012-XCCA-4" 13-RD-151-H-001 RD-A-151-XCCA-4" 13-RD-153-H-001 RD-B-153-XCCA-4" | |||
Attachment A Notice of Violation Page 4 These pipe supports were,added.to the IE Bulletin No. 79-14 program and have been verified as having been installed in accordance with the design draw-ings. The supports for Units #2 and #3 will be. | Attachment A Notice of Violation Page 4 These pipe supports were,added.to the IE Bulletin No. 79-14 program and have been verified as having been installed in accordance with the design draw-ings. The supports for Units #2 and #3 will be. | ||
installed in accordance with DCP's No. 2-CS-RD-013 and No. 3-CS-RD-013, respectively. | installed in accordance with DCP's No. 2-CS-RD-013 and No. 3-CS-RD-013, respectively. | ||
: 2. - Corrective Steps That Have Been Taken To Avoid Further Noncompliances To prevent a similar occurrence in the future, all piping design changes, as documented by Field Change Requests and Drawing Change Notices,.are being sup-plied to the Pipe Stress and Support group. These are evaluated for the necessity of new or revised pipe support designs. The corrective action for this item of noncompliance is considered complete and no further_ action is required. | : 2. - Corrective Steps That Have Been Taken To Avoid Further Noncompliances To prevent a similar occurrence in the future, all piping design changes, as documented by Field Change Requests and Drawing Change Notices,.are being sup-plied to the Pipe Stress and Support group. These are evaluated for the necessity of new or revised pipe support designs. The corrective action for this item of noncompliance is considered complete and no further_ action is required. | ||
3. | |||
Date When Full Compliance Will Be Achieved Full compliance for Unit #1 was achieved by March 23, 1983. The supports for Units #2 and #3 will be installed in accordance with the Design Change Packages referenced above.}} | |||
Latest revision as of 02:51, 15 December 2024
| ML20076E142 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde |
| Issue date: | 04/04/1983 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Sternberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20076E136 | List: |
| References | |
| ANPP-23414-BSK, NUDOCS 8305260321 | |
| Download: ML20076E142 (6) | |
Text
\\
fr.
,<. y, Arizona Public Service Companyy P O 00X 21666
- PHOENIX. ARiZON A 85036
,/,.
' '?
April 4,L1983 ANPP-23414-BSK/ JAR U. S. Nuclear Regulatory Commission Region V Creekside Oaks Office Park 1450 Maria Lane - Suite 210 Walnut Creek, California 94596-5368 Attention:
Mr. D. M. Sternberg, Chief Reactor Projects Branch No. 1
Subject:
hTC I6E Inspection of January 4-7, 17-21, 1983 File: 83-019-026 D.4.33.2
Dear Sir:
This letter refers to the special Inspection conducted by Mr. P. P. Narbut on January 4-7 and 17-21, 1983, as documented in your letter of March 2, 1983, of activities authorized by the Nuclear Regulatory Commission (NRC)
Construction Permit No. CPPR-141.
During this Inspection, two (2) items of noncompliance were identified.
Our response to these items of noncompliance (Severity Level V-Supplement II) is presented in the enclosed Attachment A.
Very truly y rs, CLLL rRLL N
E. E. Van Brunt, Jr.
8305260321 830503 gDRADOCK 05000528 APS Vice President PDR Nuclear Projects ANPP Project Director EEVBJr/BSK:ske Enclosure cc:
T. G. Woods, Jr.
G. C. Andognini J. R. Bynum D. B. Fasnacht A. C. Rogers W. E. Ide C. N. Russo G. E. Pankonin A. C. Gehr l
W. II. Wilson l
R. L. Patterson R. M. Grant l
D. R. Hawkinson l
t
a o
t STATE OF ARIZONA
)
) ss.
COUNTY OF MARICOPA )
I, E. E. Van Brunt, Jr.
, represent that I am Vice President, Nuclea.- Projects of Arizona Public Service Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority so to do, that I have read such document and know its contents, and that to the best of my knowledge and belief, the statements made therein are true, s
J
~
m b
(_.,
dLb b
b rA Sworn to before me this V day of Orii i
i 19 kb.
4 Ne.
ZW Notary Public My Commission Expires:
1 g
/
i
~
s ATTACHMENT A
-NOTICE OF VIOLATION Docket No. 50-528 Construction Permit No. CPPR-141 As a result of the Inspection _ conducted on January 4-7 and'17-21, 1983, and in accordance with the NRC Enforcement Policy 10CFR Part 2, Appendix C, 47FR9987 (March 9,1982), the following Violations were identified:
A.
10CFR50, Appendix B, Criterion V, as addressed in Section 17 of the PSAR, states,.in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the-cir-cumstances and shall be accomplished in accordance with these instructions, procedures, or drawings...."
Bechtel Welding Standard WD-1, Revision 1, dated February 17, 1981, Paragraph 1.3, states:
"This procedure includes checklists and other forms to be used for documenting satisfactory accomplish-ment of the fabrication and examination processes.
The use of these checklists and forms provides assurance that welding is performed and examined in accordance with specified procedures, that welding procedures and welders and/or welding operators are qualified in accordance with the ASME Code,Section IX, and that specified and certified materials are used for fabrication. Provisions are made for wit-nessing or inspecting by the Authorized Nuclear Inspector (ANI)."
Contrary to the above, on or about February 12, 1982, an unauthorized, undocumented weld was made in Line RDB-012-XCCA-4'l one inch (1") North of Field Weld FW-302 shown on MCN-1-10441P dated January 9,1982. The weld was subse-quently ground even with the pipe on the outside and inside diameter to make visual detection of the weld difficult.
This is a Severity Level V Violation (Supplement III),
applicable to Unit #1.
L
' o Attachment A Notice of Violation Page 2 Response to Item A 1.
Corrective Steps Taken and Results Achieved Nonconformance Report No. WA-673 was prepared describing the presence of the undocumented weld.
The disposition required replacing a six-inch (6")
length of pipe that included the weld in question, as well as the sockolet and two (2) welds, FW-332 and FW-303.
2.
Corrective Steps That Have Been Taken to Avoid Further Noncompliances The alleger claims he made the weld in question.
He did not claim to have knowledge of any others.
This is considered an isolated incident. However, the implications of this incident, and the serious nature of the Violation, will be discussed with all welder foremen to reemphasize the absolute necessity to comply with all jobsite procedures controlling welding operations.
3.
Date When Full Compliance Will Be Achieved Full compliance was achieved on March 15, 1983, with the completion of the work described on Nonconformance Report No. WA-673. The work was performed, inspected and documented in accordance with approved Project procedures.
Discussions with all welder foremen will be accomplished by April 15, 1983.
(
B.
10CFR50, Appendix A, Criterion 1, states, in part:
" Structures, systems and components important to safety shall be designed, fabricated, erected and tested to quality standards commensurate with the importance of the safety functions to be performed.
Where generally recognized codes and standards are used, they shall be identified....to assure a quality product in keeping with the required safety function.
l l
l L
Attachment A Notice of Violation Page 3 The Arizona Nuclear Power Project Design Criteria Manual, Part III, Revision 3, dated October 5, 1979, for the " Radioactive Waste Drains System", Paragraph 1.2.b, identifies "American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III" as the applicable Code for " Piping and Valves Auxiliary Building Engineered Safety Features (ESF) Room Drainage".
The ASME Boiler and Pressure Vessel Code,Section III, Subsection ND, 1974 Edition, including the Winter 1975 Addenda, Paragraph ND 3676.9, states:
" Supports shall be furnished as specified in Subsection NF to protect piping against detrimental sagging, external mechanical injury, abuse and exposure to unusual service conditions."
Contrary to the above, pipe supports were not engineered or provided for the Radioactive Waste Drain System Piping added to Drawing No. 13-P-ZAE-200, Revision 6, by Drawing Change Notices (DCN's) No. 7 and No. 8.
The piping was installed without pipe supports as authorized by Modification Change Notice No. 1-10441P, dated January 9, 1982, which was verified-complete by the Quality Control Inspector on March 4, 1982.
This is a Severity Level V Violation (Supplement II), applicable to Unit #1.
Response to Item B 1.
Corrective Steps Taken and Results Achieved The cause is attributed to oversight. The original design did not require supports; however, the design change which added drain pipes should have also required the installation of pipe supports. Engineering has analyzed the subject lines shown on Drawing No. 13-P-ZAE-200 and the following supports were designed Janu-ary 27, 1983 and were installed in Unit #1 by March 23, 1983, as per Design Change Package (DCP) No. 1-SS-RD-013:
Pipe Support No.
Line No.
13-RD-006-H-00A RD-A-006-XCCA-1" 13-RD-006-H-001 RD-A-006-XCCA-4" 13-RD-012-H-00A RD-B-012-XCCA-1" 13-RD-012-H-001 RD-B-012-XCCA-4" 13-RD-151-H-001 RD-A-151-XCCA-4" 13-RD-153-H-001 RD-B-153-XCCA-4"
Attachment A Notice of Violation Page 4 These pipe supports were,added.to the IE Bulletin No. 79-14 program and have been verified as having been installed in accordance with the design draw-ings. The supports for Units #2 and #3 will be.
installed in accordance with DCP's No. 2-CS-RD-013 and No. 3-CS-RD-013, respectively.
- 2. - Corrective Steps That Have Been Taken To Avoid Further Noncompliances To prevent a similar occurrence in the future, all piping design changes, as documented by Field Change Requests and Drawing Change Notices,.are being sup-plied to the Pipe Stress and Support group. These are evaluated for the necessity of new or revised pipe support designs. The corrective action for this item of noncompliance is considered complete and no further_ action is required.
3.
Date When Full Compliance Will Be Achieved Full compliance for Unit #1 was achieved by March 23, 1983. The supports for Units #2 and #3 will be installed in accordance with the Design Change Packages referenced above.