IR 05000423/1981002
| ML20005B357 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/19/1981 |
| From: | Chaudhary S, Ebneter S, Feil R, Jernigan E, Martin T, Mattia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20005B355 | List: |
| References | |
| 50-423-81-02, 50-423-81-2, NUDOCS 8107070533 | |
| Download: ML20005B357 (52) | |
Text
-
.
.
.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-423/81-02 Occket No.
50-423 License No.
CPPR-113 Priority Category A
Licensee:
Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name:- Millstone Nuclear Power Station, Unit No. 3 Inspection at: Waterford, Connecticut and Berlin, Connecticut Inspection conducted: January 26 - February 6 and February 18, 1981 Inspectors:
$O.
NL7M/
S. K Chaudhary, Reactor Inspector date signed
,3 S. i 17E W2?f6/
f a, Chief, Plant Systems Section yh/n S. D.
bneter date signed R'. F511, Reactor Inspector dit'e sfgned Sb-
3/Z7/!f/
. Jernigan, Reactor Inspector date signe'd c.%
2/17lT/
\\l). Mattia, Senior Resident Inspector, date signed Mill tone Unit 3 Approved by:
_/ws f//9
/
Thomas T. Martin, Chief, Engineering date signed Inspection Branch Region I Form 12 (Rev. April 77)
-
8107070533 e10423 9 DR ADOCK 05000
.
.
.
-
Inspection Summary:
Inspection on January 26-February 6, 1981 and February 18, 1981 (Report Number 50-423/81-02)
Areas Inspected: Announced, team inspection conducted at the MS-3 site by regional-based inspectors of quality assurance; design controls; project management; construction activities; procurement / storage of materials and equipment related to civil / structural, welding, non-destructive examination, and electrical disciplines. A followup inspection of design controls was held at the corporate office on February 18, 1981. The inspection involved 329 inspector-hours by five regional-based inspectors.
Results: Of the five major areas inspected, no items of noncompliance were identified in one area; seven items of noncompliance were identified in four areas.
(Severity Level IV - Failure to distribute current design documents, Paragraph 3.a(1)(b); inadequate design verification, 3.a(1)(c); Severity Level V - Failure to revise design documents to incorporate changes, Paragraph 3.a(1)(a); Failure to perform QA audits, Paragraph 2.a(1)(a); Failure to control contract services, Paragraph 2.a(1)(b); Ineffective management review program, Paragraph 4.a(1)(a); Severity Level VI - Inadequate perscnnel qualif-ication program, Paragraph 5.a(1)(a)).
.
I
.
i
.
.
-__w-
-w,
,
_
_
. -, -.
__
-.,.
-
.
.
.
.
DETAILS 1.
Persons Contacted Northeast Utilities Service Company (NUSCO)
H. R. Nims, Director, Nuclear Projects
- S. R. Toth, System S';perintendent, Generation Construction
.
- S. Orefice, Superintendent, New Site Construction
- 0. G. Diedrick, Manager, Quality Assurance
- K. W. Gray, Supervisor, Construction QA E. R. Foster, Quality Assurance Project Manager L. C. Albee, Project Engineer
'
-
W. R. Rotherford, Structures Stone and Webster Engineering Corporation (S&W)
- W. Mackay, Resident Manager
- F. K. Sullivan, Senior Resident Engineer
- A. Prussi, Resident Engineer
" J. G. Kappas, Superintendent of Construction
- R. Ledoux, Supervisor, Document Control
-
- J. S. Carty, Head, Site Engineering Office (SE0)
J.'Kalb, Structural Engineer, SEO G. Anderson, Supervisor, Construction Training
- P. A. Gagel, QA Program Administrator
- G. G. Turner, Superintendent, Field Quality Control (FQC)
- W. B. Anderson, Assistant Superintendent, FQC
- M. R. Matthews, Assistant Superintendent, FQC L. Peterson, Supervisor, Non-destructive Testing G. Marsh, Senior Engineer, Welding /NDE H. J. Shippee, Chief Welding Supervisor S. Morris, Senior Engineer, Structural, FQC R. Singh, Senior Engineer, Electrical FQC K. Snyder, Supervisor, Calibration Lab J. Plant, QC Inspector, Electrical B. J. Kiley, Chief Project Structural Engineering J. P. Allen, Chief Structures Engineer
- L. D. Nace, Project Manager Northeast Ventilating Company (NEVCO)
C. Peterson, QA Supervisor T. S.trubbel, Foreman In addition, the inspectors contacted many other representatives and/or employees of the above, organizations during the inspection.
- denotes those present at exit interview.
.
,-
,
-
e f,-
~
.
.
.
.
2.
Quality Assurance The objective of this portion of the inspection was to determine if the integrated quality assurance (QA) program at Millstone 3 was in compliance with regulatory requirements and if it was effectively implemented.
a.
Findings (1)
Items of Noncompliance (a) Section 18.2.1 of the NUSCO QA Program Topical Report, requires that audits be performed of those activities where the requirements of Appendix B to 10 CFR 50 are being implemented.
The Topical Report commits NUSCO to ANSI N45.2.12 standard, which states that the applicable elements of the QA Program shall be audited at least annually, or at least once within the life of the activity, whichever is shorter. The inspector reviewed the audit schedule and several audit reports for the audits performed in 1979 and 1980 to verify compliance with the above criteria.
Contrary to the above, the following applicable elements subject to the QA program were not audited by the NUSCO Construction QA organization:
The heating, ventilating and air conditioning (HVAC)
-
subcontractor who was performing safety related work in November and December, 1980 and January, 1981.
Stone and Webster control of the HVAC subcontractor.
-
l Containment fabricators welding process during 1978
-
!
and 1980.
Stone and Webster's field procurement activities
-
i during 1979.
!
!
-
Qualifications, training and certifications of S&W l
Field QC personnel during 1979.
!
i
-
The actual welding process on the ASME piping erected
by Stone and Webster in 1979 and 1980.
,
!
l Further, the NUSCO QA Program Topical Report states that audits are scheculed on the basis of the status and safety importance of the activities being perfermed and schedules are originated and maintained by the NUSCO QA Department.
The NUSCO QA Procedure NQA-1.14 states in Paragraph 6.1.2 i
i e
y
-
-we-
-
w-
-9
w w
w
-
rte
.
.
.
1 that the scheduled audits in the approved audit schedule shall be implemented within a period of plus or minus 3 months and audits scheduled for the 12 month period must be completed no later than 3 months beyond that period or rescheduling must be approved by the QA Manager.
Contrary to the above, the following failures to meet the audit schedules for 1979 and 1980 were noted:
Audit Number A40545 (Audit of Stone and Webster)
-
scheduled to be performed on June 30, 1980 (1 3 months) has not been accomplished.
Audit Number A40552 (Audit of Storage) scheduled to
-
be performed on August 31, 1980 (1 3 months) has not been accomplished.
Audit Number A40528 (Audit of Batch Plant) scheduled
-
to be performed on March 31, 1980 (1 3 months) was accomplished on August 14, 1980, which is well beyond the 3 month tolerance.
-
Audit Number A40533 (Audit of Concrete Placement)
scheduled to be performed on April 30, 1980 (1 3 months) was accomplished on August 14, 1980, well beyond the 3 month tolerance period.
Audit Number A40511 (Audit of Rigging) scheduled to
-
be performed on October 31, 1979 (1 3 months) was accomplished on May 15, 1980, over 5 months beyond the scheduled date.
This failure to meet requirements and commitments to conduct a comprehensive audit program is a Violation of Severity Level V (423/81-02-01).
(b) The inspector found that the HVAC subcontractor had started performing safety related work in accordance with his QA program which had not been approved as required by the S&W QA program.
In addition, S&W did not verify the qualifica-tions of the subcontractor wolders as required by the QA program. This failure to effectively control the quality of purchased services is a Violation of Severity Level V (423/81-02-02).
(2) Deviations None.
.
- - -
-
,, -, -
-
-
.
.
-
(3) Significant Observations The following observations are perceived significant weaknesses in the licensee's QA organization which inay not have specific regulatory requirements but will provide the basis for subsequent performance evaluations:
(a) NUSCO MS-3 Construction QA xaff The inspector noted that the NUSCO construction QA section is heavily committed to supporting the operating plants (Millstone 1, 2 and Connecticut Yankee) with MS-3 construc-tion QA personnel.
Discussions were held with QA management to determine the impact on Millstone 3.
QA Man Hours Spent on Year Operating Plants
_
Millstone 3 1978 3508 3421 1979 2044 4001 1980 7069 3500 Note that a significant increase in QA manhours applied to operating plants occurred in 1930 and a consequent reduction in QA manhours at MS-3.
The inspector reviewed several NUSCO QA internal correspond-ences (dated November 4, 1980, November 7, 1980, January l
2, 1981 and January 19,1981) in which requests were made for additional construction OA personnel to handle the l
increased involvement with thu ;;; rt"; plants and the revitalization of the Millstone 3 construction activities.
Apparently these requests were not approved or are still being considered by upper management. The assignment of l
MS-3 QA personnel to operating plant duties is having a negative effect on the licensee's ability to meet QA I
commitments on the MS-3 project as is evidenced by the l
findings of noncompliance in Appendix A.
The problem is further compounded by the excessive turnover rate (approxi-l mately 20%) of QA personnel during 1979 and 1980.
l (423/81-02-08)
(b) NUSCO QA Organization
NUSCO QA Section Procedure NQA-1.01, Revision 0,
.
entitled, "QA Section Organization and Qualification l
of Personnel" has a brief description of duties of i
Construction QA Section, but it doesn't specifically indicate its role in operating plants (Millstone 1, 2 I
and Connecticut Yankee); a.s it is currently written l
..
--.
.
- - -
-
-
-
.
.
.
(See Attachment 8.a of Referenced Procedure), it is implied that their duties are only for Millstone 3.
The organizations, as implemented, are not in agreement with the organization functional descriptions.
'
(423/81-02-09)
Position descriptions for managerial / supervisory
.
personnel are outdated and are currently in an unapproved draft form. The inspector reviewed a current draft of a position description for the QA Construction Supervisor. The inspector did not note any provision for an Acting QA Supervisor during th oosence of the supervisor.
(423/81-02-10)
b.
Documents Reviewed (1) NUSCO (a) QA Program Topical Report, Revision 3A
-
(b) QA Section Procedures:
.
1.01 Quality A:surance Section, Organization and
-
.
Qualification of Personnel, Revisicn 0
-
1.02 Preparation, Is;uance and Control of the Northeast Utilities Quality Assurance Program Topical Report, Revision 0 1.03 Preparation, Issuance and Control of NUSCO
-
-
Quality Assurance Section Procedures, Revision 1
-
1.05 NUSCO Quality Assurance Section Indoctrination and Training Program, Revision 0 1.06 Northeast Utilities Quality Assurance Orientation
-
and Training Program, Revision 0 1.07 Training and Qualification of NQA Lead Auditors
-
and Surveyors, Revision 0 1.08 Selection, Training, Qualification and Certifica-
-
tion of NUSCO and/or NUP0C Non-NDE Inspection and Testing Personnel, Revision 0.
1.09 Selection, Training, Qualification, and Certifica-
-
tion of NUSCO and NUPOC Nondestructive Examination
_ Personnel, Revision 0 l
e
.
-
.
.
1.10 Review of NUSCO/NUP0C Quality Documents, Revision 0
-
,
1.11 Supplier Evaluations, Revision 0
-
1.12 Preparation, Issuance and Control of the NUSCO
-
Quality Assurance Category I Contractor, Supplier and Engineering Service Organization List, Revision 0 1.13 Instructions for Use of the NUSCO Quality Assurance
-
Supplier Information Computer Program, Revision 0 1.14 Conduct, Reporting and Followup of Audits,
-
Revision 0 1.15 Review and Approval of the QA Program /QA Surveys
-
of NUSCO Supplic-s, Revision 0 1.16 Audit, Survey and Inspection Computer Program,
-
Revision 0 1.17 Instructions for Use of the NUSCO Quality Assur-
-
ance Section Deficiency Surveillance Computer Program, Revision 0
-
1.18 Procedure to Stop Work, Revision 0
-
-
1.19 Preparation and Issuance of NUSCO Quality Assur-ance Section Quarterly and Annual Activity Reports, Revision 1
-
1.20 Issuance of NUSCO Quality Assurance Correspondence /
Communications, Revision 1
'
1.22 Retention and Control of Quality Records at the
-
NUSCO Quality Records Centers at Berlin and at the Nuclear Construction Site, Revision 1 1.23 Interface with Regulatory Agencies and Tracking
-
of NRC Inspection Findings and Open Items, Revision 0 1.24 Commitment Follow Program, Revision 0
-
,
2.01 Trend Analysis of Nonconformances (Draft)
-
2.02 Routing, Followup, Review and Approval of Engineer-
-
Constructor, NUSCO Contractor and Engineering Service Organization Quality Documents, Revision 0
_ _ _ __
-
-
-
- _ -, -
.-
-
.
.
.
2.03 NUSCO Quality Assurance Section Review of NUSCO
-
Procurement Documents, Revision 0 2.04 Purchase Requistion/ Purchase Order Computer
-
Program, Revision 0 2.05 Review of " Objective Evidence" Submitted by the
-
Engineer-Constructor and NUSCO Contractors, Suppliers, and Engineering Service Organizations, Revision 0 2.07 Preparation of Inspection Packages, Revision 0
-
2.08 Conduct and Reporting of NUSCO Quality Assurance
-
Inspections, Revision 0 2.09 Joint Audits, Revision 0
-
2.10 Performance, Reporting and Followup of Surveil-
-
lance Activities, Revision 0
-
3.01 Verification of Corrective Action Contained in Significant Deficiency Reports Submitted to the NRC, Revision 0 4.01 Review and Approval of Nonconformances Disposit-
-
ioned "Use-As-Is" and " Repair", Revision 1 4.02 Preparation, Issuance and Control of NUSCO
-
Construction Quality Assurance Weekly Reports, Revision 0 4.03 Preparation of NUSCO Construction Quality Assur-
-
ance Audit Checklists, Revision 0
-
4.04 In-Process Verification of Construction Activities, Revision 0 (c) Audit Schedules and Renorts QA Audit / Survey Schedule, dated December 30, 1980.
-
-
QA Schedule for Followup of Audit Findings, dated December 30, 1980.
A40495, Boston Stone and Webster Audit.
-
A40550, Concrete Records.
-
A40528, Batch Plant.
-
.
-- -.
v- - - - - -
y
.,c
,
.
..,_m.
,.
.
-
.
.
.
l A40502, Graver Weld Rod Control.
.
-
A40506, Graver NDE.
-
A40514, Subcontractor (cancelled).
-
A01400, Field Procurement (Performed by Corporate QA),
-
A40498, Welder Qualification.
-
A40487, Storage and Control of Weld Rod.
-
A40565, Weld Rod Control.
-
A40551, Pipe Welding.
-
A40492, Storage.
-
A40520, Long Term Storage.
-
A31429, Boston Stone and Webster Audit (Performed by
-
Corporate QA).
A46484, Rigging.
-
-
A40511, Rigging.
-
-
A40533, Concrete Placement.
A40546, Concrete Testing.
-
-
A40550, Concrete Records.
(d) Surveillance and In-Process Verificatior Reports
!
C-1062, Warehouse Storage.
-
C-1062A, Followup of C-1062.
-
C-1070, Reactor Pressure Vessel Lift.
-
C-1063, Reactor Pressure Vessel Lift.
-
C-1061, Re' actor Pressure Vessel Installation.
-
-
C-667, Warenouse Storage.
C-670, Cadwelding.
-
C-671, Soil Fill Operations South of Containment.
-
..
,.
,e-9 v.
-
--w--
--- ~
w---
- - - -
y y
, +,,
,-,--.w
--,
,-
m
-
- =
-
.
.
-
C-677, Rebar Installation.
-
C-678, Concrete Placement.
-
In process Verification Report V-002, Storage.
-
(e) QA Personnel QA Department Letters November 4, 1980; January 2,
-
,
1981; January 19, 1981; January 27, 1981, related to MS-3 Construction QA Staff Requirements.
>
Lead Auditor Qualification Records.
-
Construction QA NDE Certification Records.
-
(f) Stop Work Orders October 18, 1974
-
October 24, 1975
-
(2) Stone and Webster
,
(a) _0uality Assurance Directives / Standards QAD-1.7, Revision A, Quality Assurance Program Admin-
-
istrator.
-
QAD-18.1, Revision B, Program Audits.
QAD-18.2, Revision 8, Quality Audit Plan.
-
.
QAD-18.5, Revision B, Audit of Site Operations.
-
QAD-9.2, Welder / Welding Operator Qualification Inspection.
-
-
QS-8.H, Quality Standard Procedure.
(b) Audit Reports EAP Number 30, February 29, 1980.
-
EAP Number 31, May 2, 1980.
-
EAP Number 32, July 31, 1980.
-
EAP Number 33, December 8, 1980.
-
Project Nux.ber 21, January 21-25, 1980.
-
.
e e
e
+,
y +
g m
-
g y
+
w-
-
.
.
-
Project Number 22, April 14-18, 1980.
-
Project Number 23, July 14-18, 1980.
-
Project Number 24, October 6-10, 1980.
-
Program Audit 7, September 22-October 10, 1980.
-
(c) Other QA Administrator Annual Reports (1978 and 1979).
-
Inspection Activities Report for January 1 - June 30,
-
1980.
Specification 2170.430-565, Revision 2, Installation
-
of Ventilation and Air Conditioning Systems.
Purchase Order 2170.430-565-
-
(3) Subcontractors (Northeastern Ventilat.ag Company - NEVCO)
(a) Quality Assurance Northeastern Ventilating Company QA Manual.
(b) Welding Documents NEVC0 Welder Qualifications.
-
Welder Qualifications Records (I.D. S4 and S8).
-
c.
Program Implementation In addition to the noncompliances and significant observations listed above, other items considered as unresolved or inspector l
followup items were identified. These are discussed, as applicable, in the following paragraphs.
(1) NUSCO
,
l l
(a) Documents and Procedures Topical Re' port, QA Program, Revision 3A - Appendix C,
-
,
l
"QA Procedure:f Implementing the Regulatory Requirements" is not curreat and lists obsolete procedures
,
(423/81-02-11).
'
.
I l
. - -
_
--
_
_
_
.
.
_.
. -
.
-
-
~
.
.
.
NUSCO QA Procedure, NQA-2.10, Revision 0, entitled,
-
" Performance, Reporting and Followup of Surveillance Activities" stated in Section 6.1 that surveillances are performed by " qualified" NQA section personnel.
The procedure did not define, nor did it reference the qualifications of those personnel that were to perform surveillance activities. The QA Manager and
>
the Construction QA Supervisor, stated that the qualifications of QA personnel are determined by the supervisor based upon the individual's previous education, employment and/or experience.
The inspector selected several surveillances performed by two recently hired QA technicians and reviewed the NUSCO QA records to determine +6 2ir previous education, experience and NUSCO training.
One of the QA technic-ians (hired in July of 1980) possessed an electrical i
discipline background.
This QA technician performed
three surveillances (C-1070, C-1063 and C-1061) in July 1980 for the reactor pressure vessel lift and installation.
He received minimal NUSCO training to qualify him to perform surveillances of this complex construction / erection process.
During this inspection period, NUSCO QA revised the NQA-2.10 Procedure (Revision 1, issued February 3, 1981) to further define the qualifications of persons
,
performing surveillances. This item is considered resolved.
,
During a review of various NUSCO QA audits, the
-
-
inspector noted that the auditors were using various categories of findings, such as " concerns" and " comments".
,
i The NUSCO QA Audit Procedure NQA-1.14 doesn't address these types of firdings nor the appropriate management corrective action to be taken (423/81-02-12).
During a review of a draft copy of the NUSCO QA
-
Procedure NQA-2.01, entitled " Trend Analysis of Category 1 Related Problems", the inspector noted that it did not require the trending of Millstone 3 construction findings.
The inspector discussed this with the NUSCO QA Manager and he stated that Stone l
and Webster were their agents and have the responsi-
'
bility for trending.
The inspector informed the QA Manager that Stone and Webster did not trend NUSCO's (
QA findings resulting from their Audits, Surveillances i
and In-Process Verifications. This is considered i
unresolved.
(423/81-02-13)
l l
!
.
e r
p-t g-yy,me
-
7me ti---t
- -
g 3-y-
m--
-w-ir-vw+we--
e-a+
T we-v+-mW+w--e+w
-+-*wa y
e #
g w awawe-+
w,m g---r-
-e----
.
-. -
.-
_ -
--
-
._~
.
.
.
,
-
(b) QA Auditor Interviews Interviews were held with two people assigned to NUSCO Construction QA to verify knowledge and understanding of their functions, to determine how they interface with QA management, and solicit their view of management support of QA.
No negative findings were noted.
One of the QA technicians stated that he would like to broaden himself and would like to receive some training in other technical disciplines.
,
(c) QA Surveillance / Audits The inspector reviewed NUSCO's Construction QA Surveil-
-
lance Report #C-1062A and the In-Process Verification Report #V-002 which were performed to verify that Stone and Webster was complying with the imposed
storage requirements.
In response to some deficiencies identified by NUSCO QA, Stone and Webster issued
'
" unsatisfactory" reports. The NUSCO QA section accepted the S&W action, closed out the deficiencies, and did not do any followup to verify that satisfac-tory corrective action had been taken by Ston2 and Webster.
Discussions held with the construction QC supervisor indicated that this was the method being
.
used by NUSCO for all findings where Stone and Webster issued " unsatisfactory" reports.
The inspector informed the licensee that this method of inadequate followup is considered an unresolved item.
(423/81-02-14)
NUSCO Procedure NQA-1.14, Revision 0, entitled,
-
" Conduct, Reporting and Followup of Audits," Section 6.1.2, requires that the audit schedule shall be
,
implemented within a period of plus or minus three months.
This time span maybe excessive.
For example, the NUSCO QA construction section audit schedule which was issued December 30, 1980 indicates that there.are four audits (A40568-A40571) scheduled for December 31, 1980. These audits have not been accom-plished to-date, although all of these activities (Stone and Webster inspection reports, mechanical, electrical and storage) have been very active during the month of January.
(423/81-02-15)
.
(2) Stone and Webster The inspection of Stone and Webster Quality Assurance Program activities was restricted to project audits and site QA fuac-tions. The project audit inspection results are summarized in L
the paragraphs below. The inspections of Stone and Webster
site QA functions are reported in other sections of this report as appropriate.
.
,-,,r-+
--
g.-
-,
-+-++-,w w--,
--
9mm+,
m,-
y-=m,es.-ei
.g-,,y g%,-apg.-g-w, w.%
,,p+-i g%,.%---.n,---*-g,9.--w er-wwi*Nq-
+-v y-v r
+-
--+-wev----
- = _
_ _
. _ _
_
-
..
-
-..
_.-
_
-
.
.
.
I i
Quality Assurance Directive (QAD)-18.5 requires that an audit be performed at each construction site every three months with one fourth of the eighteen criteria of 10 CFR 50, Appendix 8,
,
l to be audited each quarter, such that the entire 18 criteria of Appendix B are audited annually. The referenced audits were
'
reviewed and analyzed to determine compliance with procedural commitments. The Stone and Webster audit program for 1980 encompassed all eighteen criteria.
Design and procurement related criteria were audited by Engineering Assurance and the site.and program audits were conducted by Corporate QA organiza-tions.
Some S&W a'udit findings that are related to the NRC findings on this inspection are:
Audit Report 21 reported that the MS-3 project was not
-
I adhering to the requirement that E&DCR be incorporated
'
into affected documents within the six month following the sixth E&DCR.
Audit Report 23 identified. deficiencies in the site training
-
program.
Engineering Assurance Audit Report Number 30 identified
-
unsatisfactory conditions related to data organization and verification of design calculations.
This inspection was restricted to site functions and the adequacy of S&W corrective action applied to audit findings at the corporate offici could not be verified. Succeeding S&W audit followup memoranda referenced that adequate corrective action had been verified during the subsequent audit.
The inspector noted that the S&W QA Vice President had been appointed since the submittal of the S&W QA Topical Report and
'
that this was reflected on the organization chart.
The S&W QA program administrator provided a copy of correspondence notifying the NRC of the change.
(3) Northeastern Ventilating Company (NEVCO)
NEVC0 is a contractor to S&W. NEVCO's function is to install
'
'
components of the HVAC system. The noncompliance cited for
'
inadequate control of quality of purchased services is related to this contract (Reference 2.a.(1)(b)).
NEVC0 Procedure SQAP 2.1, dated August 18, 1980, entitled,
" Training and Qualifications of Welders," requires the NEVC0 QA supervisor to review the NEVC0 welders qualification record and indicate his acceptance.
The inspector noted that the welder
!
-
.
..
. -
.
.
.
.
. -
.
.
.
_ _.
~
.
.
qualification records for two welders currently welding onsite had been reviewed by the QA supervisor, but his approval on the records occurred two months after the welders were actually welding onsite.
This item is ut. resolved pending revision of the procedure to clarify when the QA supervisor's acceptance of qualification record is required.
(423/81-02-16)
3.
Design The purpose of this part of the inspection was to determine if the site design interfaces were effective and that d* sign documentation onsite was current.
a.
Findings (1)
Items of Noncompliance (a) The S&W QA Topical Report requires that document control be accomplished... K5ich ensures timely inclusion of changes into the parent c?cument. MS-3 Procedure NEAM-38 requires that documents be revised and re-issued within six months after the sixth E&DCR has been issued against the document.
Contrary to this, S&W Speqification 279 had eight E&DCRs issued against it and the sixth one was cver 2 years old, thus violating the six and six rule.
No evidence was available that an exclusion had been gra1ted.
This area was previously identified as NRC unresolved item 80-07-01 and is upgraded to a noncompliance.
Th4 s is a Severity Level V Violation.
(423/81-02-05)
(b) Stone and Webster Engineering Assurance Procedure EAP 6.1, states that the latest issues of documents are distributed to and used by personnel who need them to prevent the use of voided, supersaded or cancelled documents.
Contrary to this, E&DCR PS-2162 was not distributed and was not available to personnel.
Consequently, Wall G-7 in the ESF Building was not constructed per design requirements of the E&DCR. This is a Severity Level IV Violation.
(423/81-02-06)
(c) Design control measures are required by the S&W SWSQAP, Section 3 and NUSCO QA Topical Report Section III.
Contrary to the requirements, S&W could not provide objec-tive evidence to show that a design input per ACI-318-71 was evaluated / verified in changing from Grade 40 rebar to
.
Grade 60 rebar in certain walls of the ESF Building.
The
.
.
s-*-:
%
-- --
gn -=
y7+y---ae--
n%
y e----
e-
=w
--
y
--e-y
--w--
'
.
.
.
licensee stopped work to prevent further concrete placements until this condition is further evaluated (See Section 3.c(1)(b). This is a Severity Level IV Violation.
(423/81-02-07)
Specific details of these noncompliances are documented in Appendix A to the letter forwarding this report.
(2) Deviations None.
(3) Significant Observations (a) The architect-engineer (S&W) is starting to do some design work in the field in relation to conduit supports for electrical raceway systems.
The design controls applicable to these supports have not been formally approved; specif-ically, the interface between the resident engineer office, the site engineering office and the corporate office have not been formally defined nor has the criteria for design verification of safety related conduit supports been
.
develop 1d.
(423/81-02-17)
b.
Documents Reviewed (1) Stone and Webster
,
(a) Procedures Engineering Assurance Procedure, EAP 6.1, Control of
-
Approved S&W Drawings.
Engineering Assurance Procedure, EAP 6.3, Preparation,
-
Review, Approval and Control of E&DCRs.
Project Manual Procedure NEAM-38, Revision 5.
-
QS-6.1, Document.
-
FM3-56.1-02A, Status Control for E&DCRs.
-
- ')
Specifications S&W Specification 999.
-
S&W Specification 279.
-
S&W Specification 350.
-
.
.
e a
y w
w a
ww y
---
m
-
.
.
.
.
(c) E&DCRs
.
F1976-F2200
-
F2401-F2550
-
F2676-F2800
-
P2062-P2165
-
P2276-P2400
-
PS-2337
-
FS-2434
-
'
FS-2744
-
PS-2162
-
E&DCRs located at field drawing stations
-
.
(d) Drawings ES-31L
-
.
-
Drawings located at field drawing station
-
(e) Structural Design Documents Structural Design Standards Manual, Volumes I and II.
-
Structural Design Guidelines, Volumes I, II, III
-
and IV.
c.
Program Implementation (1) Design Change Control The inspector reviewed a random selection of Engineering and Design Change Reports (E&DCRs) for conformance to the require-l ments of project pro'cedures, completeness, and validity of use.
The inspector also held discussions with licensee and A/E constructor personnel regarding control, distribution and implementation of such changes.
,
!
l
.
/
-..
, ~ -..,
., _. _ -.,.....,, _ _., _. _., _. _ _, -, _,
_... _ _ _ _ _, _ _..,. _ _ _.. _.. _ _
, _ _ _ _., _ _. _. _,
.
.
.
.
(a) General Observations The E&DCRs generally complied with the procedural
-
requirements in the area of format, adequate problem description and resolution, and proper approval.
The E&DCR system is also being used for documenting
-
interpretation of design requirements, and site project technical communications.
This leads to an over use of the E&DCR form and in at least one instance, an E&DCR (FS-2758) was initiated to provide disposition of'a nonconformance instead of initiating a Nonconform-ance and Disposition Report (N&D).
In several instances, E&DCRs were initiated against
-
design documents that were not issued for construction.
(b) Rebar Steel Design Change In addition to the above general observations, the inspector specifically noticed that in the month of July, 1979, E&DCR #PS-2337 was initiated by the Site Engineering Office (SEO) to permit substitution of grade 60 rebars for grade 40 rebars. The reason for the substitution was that the rebar supplier to the site, Bethlehem Steel Corporation, had stopped production of grace 40 rebars. The E&DCR resolved the question stating that the substitution had been evaluated and found 'a have no effect on the current design effort and thus grade 60 rebars may be substituted for grade 40 rebars required by the original design on a one for one basis if approved by the lead structural engineer in writing.
The inspector further noticed that the solution to the problem was provided by the same individual who had initially requested the change.
This E&DCR was approved by the project engineer on August 16,
!
l 1979. Approximately five weeks later, another E&DCR (FS-2434, dated September 24,1979) was initiated to
'
delete the requirement of the lead structural engineer's approval for substitution. This E&DCR #FS-2434 voided the
'
'
previous E&DCR #PS-2337.
However, voiding the previous
E&DCR in effect, also rescinded the approval for substitution.
l Hence, another E&DCR (FS-2744, dated December 26,1979)
was initiated to clarify the situation. This new E&DCR
!
!
was approved by project engineering on January 10, 1980.
The new E&DCR #FS-2744 voided E&DCR #FS-2434 and required i
that only a material receiving report for grade 60 rebar, i
sizes 7 to 11, need be submitted to the lead structural
engineer instead of obtaining his written approval, and referenced the voided E&DCR #PS-2337. Tha mere reference
.
-
k e-e-*-wp-
-T-q-.M.wy,ew yg--_m,gr m e
.p%-e p
_e.mm-e,,,ye,,,.,
9..
,.,wg..
,9,,,,_
,,.,,,.,,,,
,,,,,,,,,
,.,
_ _ _ _,
,_
__
_
'.
.
to a voided document does not reimpose a requirement contained in such a document and the procedures do not permit refe.ence to a voided document by reference; rather the design change should be completely restated in the new E&DCR. The intent of the E&DCR #FS-2744 was in fact to permit substitution even if it did not explicitly so state.
After the approval and applicability of substitution was estab-11shed, the inspector requested the licensee to provide data supporting the validity and technical adequacy of design for substitution of the rebars.
The inspector pointed out to the licensee his commitment to Uniform Building Code ACI-318-71 which limits the amount of rebar to 75% of the amount required for balanced ratio of concrete and steel (ACI-318, Section 10.3) in certain structural members.
The inspector stated that in view of the statement " changing to grade 60 has been evaluated and found to have no affect" (effect) in E&DCR #PS-2337, he expected to see objective evidence of such evaluation and/or an analysis documenting the casis for such a conclusion. The licensee indicated that cae evaluation referred to in the E&DCR was an engineering judgement, and was not based on any documented
,
analysis or evaluation.
The licensee, therefore, did not provide any objective evidence to the inspector to justify the design change of substitution of rebars. The regulations of 10 CFR 50, Appendix B, require that the changes to the original design be subjected to the same centrols, such as verifying and checking the adequacy of design n applied to the original design. And, because the original structural design of reinforced concrete using grade 40 rebars was not based on engineering judgement alone, the change in design permitting a different grade of rebar used one for one without a documented analysis and/or evaluation was improper.
l Based on the above observations, the inspector determined the following:
,
!
There was no objective evidence to support that the appro-
-
,
'
priate design input, i.e., ACI-318-71, was correctly translated in the busign change, nor that the impact of the change on overall design had been analysed.
There were no engineering calculations to confirm the
-
adequacy of the design change nor was there any objective
,
evidence of an independent design verification.
This is a Severity Level IV Viciation. (423/81-02-07)
\\
u
_ _ _ _
.
.
,
-
.
The licensee issued memorandum FM-MP3-2242 on February 4, 1981 which effectivel) stopped work in areas where rebar substitution was planned. This placed a hold on concrete placement in
'
Category 1 structures until the issue could be resolved.
Subsequently, a followup inspection was held February 18, 1980 at the NUSCO design office in Berlin, Connecticut to discuss the problem. As a result of this inspection, an Immediate Action Letter (IAL 81-12) was issueo by Region I confirming the commitments of the licensee.
(2) Document Control The inspector reviewed the status of several drawings, specifica-tions and design changes to assess the effectiveness of measures established for their adequacy, approval, currency of revisions, and/or posting of changes. The availability of correct design documents / instructions at the location of activities controlled by those documents was also reviewed. The major portions of document review for this audit were carried out in conjunction with the documents reviewed for the design control a.dit.
Two
'
noncompliances were identified (See Appendix A), one failure to revise Specification 279 per the six and six rule and one for
,
failure to distribute drawing change documentation.
(3) Drawing Station Control The inspector reviewed the documentation located at drawing stations at elevations 24'6" and 47'6", designated as drawing stations 33 and 12, respectively, to assure currency of drawings, completeness in relation to E&DCRs and conformance to procadural controls.
The EE series of drawings located at these stations were current, had been updated to reflect E&DCR revisions and were adequately controlled. As an example, EE-34J8-2, Cable Tray Supports, Miscellaneous Details, Sheet 2 had been updated to reflect 11 l
E&DCRs. The date of issue of each E&DCR, and its content was l
checked to assure conformance with the S&W six and six criterion l
for drawing revision as specified in the applicable Engineering Assurance Procedure. All referenced E&DCRs were available at the station.
l (4) nnsite Design by Site Engineering Office (SEO)
I The inspector held discussions with S&W personnel assigned to l
the site engineering office to determine the extent of SE0 involvement in design onsite and approval of design changes
originated in the field. The inspector also reviewed some documents maintained in SEO for controlling design and design changes.
i
!
..
.
.
-
..
.
. -.
-
-
-- _.
-
.
.
l
.
l based on the discussions with engineers of the SEO, review of docue nts and personal observations, the inspector determined that at the present time there is no significant design activity performed at site by the SEO. Therefore, there are no procedures required and/or available at site to control original design.
The design change activity is controlled by E&DCR system.
However, there were some inconsistencies in the implementation of E&DCRs such as use of E&DCR for disposition of nonconformance, successive voiding of E&DCRs, and initiation and approval of changes oy a single individual as identified
'.n previous sections of this report.
(5) Field Design The Resident Engineer has the responsibility for field design of conduit supports.
The basic design criteria for conduit supports is detailed on the EE-52 drawings, Standard Conduit Support and Guides.
Conduit installations are reviewed and the standard criteria are applied to the specific situation which is detailed on a field sketch (FSK) for the craft personnel.
After installation of the conduit supports, an as-built drawing is prepared which becomes the basis for final inspection.
Special cases which requir,e a departure from the standard design criteria of the EE-52 drawings are documented on an E&DCR and processed through the SEO.
Existing controls are informal. A field design procedure has been documented in a draft procedure but it has not been approved for use.
Consid-ering that the workload in electrical conduit installation is projected to increase rapidly in the coming months and that additional field design personnel will be assigned to the Resident Engineers Office, adequate management controls should be developed, approved, and implemented prior to the undertaking of extensive field design of conduits.
This would insure timely and uniform application of standard design criteria, assure interface identification and control and provide for design verification as required.
The absence of control over field design of conduit supports is considered a weakness in the existing program.
(423/81-02-17)
i l
1.
Project Management i
l The objective of this part of the inspection was to determine the effec-tivenest of project management in relation to management support of pr'oject requirements and comritments, responsiveness to project neeus and management involvement at the construction site.
,
l
.
.
_.
-
-
_ _
-
-
.
.
.
a.
Findings (1)
Items of Noncompliances (a)
10 CFR 50, Appendix B, Criterion II, requires that the
-
licensee's organization perform a management review of the status and adequacy of the quality assurance program.
NUSCO procedure NE0-1.06 defines the method of conducting an annual management review.
Contrary to the requirements of the implementing procedure, an annual management review was not conducted in 1978 or 1979 and adequate' followup of findings from the 1977 review was not performed.
(423/81-02-03)
Specific details of the noncompliance are documented in Appendix A to the letter forwarding this report and Section A.c(5) below.
(2) Deviations
,
None.,
(3) Significant Observations (a) Site and corporate management, both NUSCO and S&W, are actively involved in site activities.
This was evidenced by the the documented evidence of frequent attendance of management personnel at site project meetings, large attendance of upper management at NRC exit interviews, and knowledge of site operations and problems by management.
This was reinforced by the positive attitude displayed by crafts and inspection personnel during interviews and discussions with them. Thi.i is considered a strength of the MS-3 project.
(b) Training was identified as a weakness in the overall project based on the following:
-
Ni'SCO management had not performed adequate followup in response to a management review finding of a lack of training procedures in 1977 (See Paragraph 4.c(5)).
NUSCO QA personnel qualifications were not adequately
-
defined and inspection personnel were assigned to inspectic., functions outside their expertise (See paragraph 2.c.(1)(a)).
...
-
- --.
_.
. -..
-
.
.
.
.
S&W Audit 23 identified several deficiencies in
-
construction training.
Most of the deficiencies have been corrected, but this requires additional emphasis.
At least three crafts persons that were interviewed
-
stated they had not received the project indoctrination training required by project procedures (See Paragraph 4.c(6)).
(423/81-02-18)
'
(c) Regulatory reporting of potential construction deficiencies in accordance with 10 CFR-50.55(a) is considered to be weak. This is based on the chronology of events in Section 4.c.(3) below and previous NRC concerns documented in IE Inspection Reports 80-07 and 80-04.
(423/81-02-19)
b.
Documents Reviewed (1) NUSCO
,
(a) NUSCO Qu.'ity Assurance Program
'
Topical Report, Revision 3A.
-
,
(b) Nuclear Engineering and Operations Procedures
- NEO 1.01 Nuclear Engineering and Operations Group Organization, dated October 15, 1979.
- NEO 1.03 Preparation of Quality Related and Other Procedures - Format and Content, dated October 15, 1979.
- NE0 1.04 Procedure for Review of Nuclear Engineering and Operations Procedures as Required by Revisions to Northeast Utilities Quality Assurance Program Topical Report, dated October 15, 1979.
- NE0 1.05 Preparation and Processing of Proposed
l Revisions to Northeast Utilities Quality Assurance Program Topical Repcrt, dated October 15, 1979.
- NEO 1.06 Management Review of Northeast Utilities
,
.
Quality Assurance Program, dated October
'
i 15, 1979.
!
- NEO 1.08 Preparation, Issuance, and Control of NUSCO Nuclear Engineering and Operations Group j
Procedures, dated October 15, 1979.
l
..
.
- -.
,
-.,
-
.
-
,.. _.
-
-
.
.
'
- NEO 2.01 Preparation, Issuance and Control of Project Assignments, dated October 15, 1979.
- NE0 2.02 Preparation, Issuance and Control of Project Instructions, dated October 15, 1979.
.
- NE0 2.04 Rc-solution of Audit Deficiencies, dated October 15, 1979.
- NEO 2.05 Documentation of Telecons, dated October 15, 1979.
- NE0 2.06 Documentation of Meetings, dated October 15, 1979.
- NE0 2.08 Commitment Follow Program, dated October 15, 1979.
- NE0 2.10 Monitoring and Reporting of Contractor's Quality Assurance Performance, dated January 25, 1980.
(c) Quality Assurance Section Procedures 1.05 Indoctrination and Training Program.
-
1.06 Quality Assurance Orientation and Training
-
Program.
1.14 Conduct, Reporting and Followup of Audits.
-
_
1.24 Commitment Follnw Program.
-
(d) Generation Construction Procedures
-
GC0 1.06, Generation Construction Training Program, Revision 1.
-
GCD 2.08, Commitment Follow Program, NE0.
GCD 6.01, Construction Training Program Orientation.
-
(e) Other Documents
>
-
Weekly Construction Meeting Notes.
-
NUSC0/NNECO Monthly Progress Meeting Notes.
. - -, -.
..-
,,
. -.
-
'
.
.
.
.
Monthly Progress Report Generation Construction
-
Status.
Project Meeting - Notes of Conference.
-
Project Liaison Committee - Notes of Conference.
-
(2) Stone and Webster (a) Quality Standards QS-2.12, Qualification, Certification, Indoctrination
-
and Continuing cducation of Personnel, Revision 1.
QS-16.1, Problem Report System.
-
QS-16.2, Notifying Clients of Potentially Reportable
-
Deficiencies Under 10 CFR 50.55(e).
(b) Quality Assurance Directives QAD-18.1, Program Audits, Revision B.
-
QAD-18.3, Division Performance Evaluation, Revision B.
-
QAD-18.5, Audit of Site Operations, Revision B.
-
(c) Engineering Assurance Procedures EAP-16.2, Notifying Clients of Potentially Reportable
-
Deficiencies Under 10 CFR 50.55(e), CN1, Revision 2.
'
(d) Other Documents Construction Management Manual, CMM 9.2.
-
i l
-
Daily Field Office Reports.
CMS - Project Manpower Curves.
-
l c.
Program Implementation l
(1) Organization
,
(a) NUSCO The NUSCO organization structure is defined in various
-
organization charts some of which are contained in the NUSCO QA Topical Report, Revision 3A.
It was
,
noted that the organizational management assignments i
l
.
~
.
.
.
are in a transition phase (reorganization) and, therefore, the charts were not exactly current but will be revised in the near future. The actual organization structure and functional descriptions of the NUSCO organization are not implemented exactly as delineated in the Topical Report, and in supplementary charts and other manuals. This is primarily due to the interpretation placed on the term " Construction".
For example, the most recent NUSCO organization chart, dated December 1980, portrays a NUSCO Construc-tion Quality Control Unit. Generation Construction Procedure GCP-1.01, Section 3, defines the functions of the QC Unit which implies a significant role in
,
construction and only a minor role in Betterment projects.
However, in discussions with NUSCO management, it was clearly stated that this QC Unit does virtually nothing to support construction of MS-3, but is support.ing Betterment projects.
(Reference 2.a(3)(b))
A review of the position (jurisdiction) descriptions
-
for the Generation Construction Department and subse-
.quent discussions with management personnel, revealed that the approved position descriptions have been revised but have never been approved by upper management.
The organization is functioning under the revised, but unapproved descriptions.
(See also Section 2.a.(3)(b) for a related problem within the QA organiza-tion).
The position descriptions do not adequately define
-
the authority vested in specific managers for "stop work" authority (there is a NUSCO QA Procedure, NQA-1.18 which governs stop work initiated by QA, signed only by QA) and the means of resolving conflicts of opinion between construction and QA.
It should be noted that the stop work authority apparently is being effectively used by the NUSCO Superintendent,
,
Generation Construction as was evidenced by a direction
!
to place a hold on concrete placements in structures l
where 60 grade rebar had been substituted for 40 grade rebar.
However, with increased construction work and parallel activities, the stop work authority and procedure will assume greater importance and thus should be clarified. The licensee initiated action in this area during the inspection.
(423/81-02-25)
e v
.
y;yp_g e
+-
--
-,
- - * -
i-m
,y+-e.
- -. -. - -
r.-
-
.
.
.
Interfaces between licensee and contractor are control-
-
led by procedure and position descriptions. Within NUSCO and S&W, this is accomplished with the QA Topical Report, organizational directives, organization charts and procedures.
No problems were identified with organization interfaces.
In fact, crafts personnel, engineering and quality control personnel, all were positive in their statements about the functioning of the site.
(b) Stone and Webster The Stone and Webster actual organization structure and assignments were in agreement with the organization charts and descriptions.
(2) Staffing (a) NUSCO The NUSCO engineering staff appears to have very good experience and education in relation to their assigned duties and the staff is being increased to help handle the increased workload due to the increased project activity.
The duties of the engineering staff are presently being formalized into a procedure.
Previously, duties and functions were controlled by job descriptions and discuss-fons with supervision (see previous discussion about job descriptions under Organization).
The NUSCO site QA staff was discussed in Section 2 of this report.
l (b) Stone and Webster The MS-3 project activity, and thus the S&W staff, has fluctuated widely over the past few years from a low in 1978 of approximately 225 to a peak of approximately 1200 in 1979.
Project activity is again increasing and the present staff exceeds 800 with a projected peak of over 2000 expected to occur in late 1982 to mid 1983 time frame.
The inspector r'eviewed several S&W Daily Field Office Reports which are prepared per the Construction Management Manual and define the S&W site work force level by discipline and organization.
-
-
.
.
.
.
The existing percentage of field quality control staff to crafts is approximately 7.25%.
In discusssions with crafts personnel working in safety-related area, they expressed the view that QC was frequently in the area, hold points were observed and inspected and that the coverage was more than adequate. Both crafts and QC expressed the view that there was a good working relation-ship between crafts and QC.
The inspectors reviewed S&W projected manloading, as depicted on the CMS charts and discus' sed these with manage-ment.
The projected ratios of crafts workers to foreman and of S&W QC tc crafts was reviewed and it was found that the manpower curves tracked and peaked over the project lifetime.
No potential problems were identified and the planned QC staff increases were proportionate to craft staff increases.
Recruiting of crafts and other project personnel was being actively pursued.
(3) Regulatory Reporting A reportable deficiency was reviewed for cause, reportability, action, corrective action, review and followup to determine compliance with 10 CFR 50.55(e) requirements. The chronology of events was as follows:
,
-
On May 29, 1979, Nonconformance and Disposition Report (N&D) No. 0498 was prepared indicating incomplete penetra-tion of welds on the supports of the Component Cooling Water Heat Exchangers (CCWHE).
A second N&D (No. 0221) on the CCWHE supports was prepared
-
,
!
on September 17, 1979 indicating that the material used in l
the supports was not as required by the purchase specification.
l A third N&D (No. 0203) on the CCWHE supports was written
-
on October 19, 1979 stating lack of penetration.
On October 24, 1979 a Stone and Webster interoffice memo
-
from P. A. Gagel to F. Sestak, Jr., requested that a j
review and evaluation be made of the October 19 N&D in regards to the defects being reported in accordance with l
Quality Standard 16.2, Notifying Clients of Potentially
'
Reportable Deficiencies Under 10 CFR 50.55(e) or Quality
'
Standard 16.3, Identifying and Reporting Defects and l
Failures to Comply Under 10 CFR 21.
On March 4, 1980, the problem was formalized in a Report
-
of a Problem from E. McManus to J. Fletcher in accordance with QS-16.2.
I
-
.
.
.
.
On April 4, 1980, after the problem was reviewed by the
-
responsible S&W persons, it was submitted to NUSCO.
On April 15, 1980, NUSCO informed the NRC of a potential
-
deficiency regarding unsatisfactory welds in the supports of the Component Cooling Water Heat Exchangers (CCWHE).
-
A 30 day written report was submitted by NUSCO to the NRC on May 8, 1980.
The review of this reportable deficiency revealed that Stone and Webster failed to take prompt action to report the problem to NUSCO as a potential reportable item.
The problem had been identified as a possible reportable item approximately 4 1/2 months before the r,roblem report was generated to start the review process in accordance with QS 16.2.
In addition, NUSCO failed to take prompt action on reviewing the item for reporta-bility which shculd have resulted from a review of the N&D
submitted to NL'SCO. This latter aspect occurred because the NUSCO site QA section dces not take any action on N&Ds unless directed to do so by the corportte office. The lack of adequate review of N&Cs by NUSCO, and the failure of Stone and Webster to report potential deficiencies in a timely manner represents a weakness in the overall management control and reduces the effectiveness of control by NUSCO over their contractors.
(423/81-02-19)
'
!
(4) Commitment Follow Programs NUSCO utilizes the commitment follow program as defined in Procedure GCD-2.08 to control items requiring a written response and is primarily utilized by the NUSCO project engineer. A review of the computer listing of the commitment follow program revealed an inability to determine the status of an item on the list.
In addition, some items requiring a response were not included on the list.
During the inspection, the project i
engineer verified that some items were not on the list.
He stated that effort would be expended to update the list and to utilize it as a management tool as it was originally intended
,
and is considered unresolved.
(423/81-02-20)
,
(5) Management Review
'
Regulatory requirements of 10 CFR 50, Appendix B, require a managemer.t review of the adequacy and status of the goality assurance program and that the management of other organiza-tions participating in the QA program shall regularly review the status and adequacy of that part of the QA program they are
,
l executing. NUSCO Nuclear Engineering and Operations Procedure l
NE0-1.06 prescribes that the management review shall be conducted annually and details the requirements and the method of conducting
l l
I l
-
.
-
.
-
-.
-
.-
-
.
.
.
the annual review to assess the scope, status, implementation and effectiveness of NUSCO Quality Assurance Program. A manage-ment review was conducted in 1977 and in 1980.
The licensee representative stated that no management review was conducted in 1978 or 1979 because the QA program was being revised and formulated as a topical report.
In addition to the failure to perform an annual management review for two successive years, the licensee failed to utilize t.he 1977 management review findings effectively as indicated below.
,
Licensee Procedure NE0-1.06 specifies in part:
"6.4 Quality Assurance Management Review Report 6.4.1 The Northeast Utilities Quality Assurance Program Management Review Committee shall submit a written report to the NUSCO Vice President, Nuclear Engineering and Opera-tions at the conclusion of the review.
The report shall address:
6.4.1.1 For those projects and activities audited, the results of the
'
comparison between the Northeast Utilities Quality Assurance Program Topical Report and the implementing procedures.
6.4.1.2 The results of the review of audits of the past two (2) years to determine adverse trends in the implementation of the Quality i
Assurance Program.
6.4.1.3 The results of the last Review
,
Committee Audit.
!
l l
6.4.1.4 An assessment of the status and l
adequacy of the Quality Assurance
'
Program.
i 6.4.1.5 Recommendations for program i
improvements as a result of the
'
review."
Upper management followup and implementation of actions to t
correct negative findings of the management review report
!
appears to be somewhat less than effective as evidenced by the l
following items.
l
-
.
.
.
The 1977 management review report identified training as
-
an area which needed greater attention by NUSCO.
The joint utility audit of March 24-28, 1980 also identified training as a deficient area, and more recently, an audit conducted by NUSCO quality assurance on January 22, 1981 again identified training as deficient.
Employees, in addition, to any initial training received should be
-
retrained on an ongoing basis to keep current on such matters as changes in regulations, faci:1t.y modifications, problems, procedural reviews and changes within the industry.
Some technical personnel had received no training (formal or informal) in the applicable codes, standards and require-ments of their job.
The 1980 management audit was conducted on March 24-28,
-
1980. A letter dated January 7, 1981 from H. C. Mikastowicz to D. G. Diedrick identifies the status of all findings and recommendations as of January 11, 1981.
Of eight (8)
findings, four (4) were still open. Of eight (8) recommenda-tions, three (3) had not yet been acted on.
This appears to be an abnormally long time to correct adverse findings and indicates that management is lax in reviewing and correcting deficiencies found in their program.
The management review does not appear to be achieving the
-
desired result in that inf'ormation which is identified as a requirement in the procedure is not identified in the latest management review report.
The results of any comparison between NUQAP Topical Report and Implementing Procedures was not evident; and since no reviews were conducted in 1978 or 1979, no trends could be identified.
Further, no review of the results of the last committee audit were evident in the 1980 report, nor does it appear that all previously identified deficiencies, finding and recommendations are tracked to show final resolution.
<<
(423/81-02-03)
(6) Training and Qualification of personnel (a) NUSCO The NUSCO QA Topical Report, Revision 3A, Section 2.25, Indoctrination and Training, provides for the establish-ment and mainte' nance for quality assurance indoctrination and training.
It also requires the Lead of each department to be responsible for a training plan which assures that personnel performing quality related activities are trained in the principles and techniques of the activity being performed.
.
-
.
.
.
NUSCO, Procedure GCD-1.06, Revision 1, specifies that all generation construction personnel will be trained in the use of the Generation Construction Procedure manual and requires additional training within 90 days on new or revised procedures. New personnel are to be trained before assignment.
Procedure GCD-6.01, Construction Training and Orientation, also applies to new employees.
NQA Procedures 1.05 through 1.09 provide requirements for indoctrination and training of QA personnel.
The NUSCO management review of 1977, joint utility audit conducted in 1980 and NUSCO QA audit of January,1981, all identified deficiencies in NUSCO training which apparently have not been adequately corrected (see previous section on Management Review). The training of NUSCO QA site auditors was identified as a concern in Section 2.c.(1)(a)
of this report.
(b) Stone and Webster Construction
.
The Stone and Webster Quality Assurance Program for MS-3 specifies in Section 2, Paragraph 1.7 that indoctrination and education programs shall be established as appropriate for S&W personnel performing activities affecting quality.
Quality Standard QS-2.12, Revision 0, " Qualification, Certification, Indoctrination and Continuing Education of Personnel," Paragraph 4.1.2 requires the Construction Department to develop and provide appropriate training programs for indoctrination and qualification of construc-tion personnel.
Construction Management Manual Procedure CMM-9.2, provides implementing instructions.
During discussions with construction management, it was stated that not all crafts personnel had received the construction orientation and training as required.
This was verified by independent discussions with crafts personnel
!
l in the field; at least three (employed for over three months) stated they had not received the training. The primary reason for the breakdown in training was the lack of training personnel for approximately a six month period in 1980 during the slowdown of MS-3 construction.
The
deficiency had been identified by S&W QA in Audit Number
!
23 and construction management has initiated corrective action.
Review of corrective actions taken indicates that significant progress has been made; a supervisor of training was recruited, a program to ider;ify those who did not j
l receive orientation has been developed, and tachnical training for crafts has been instituted on a contract basis. However, considering that the construction force
,
j lavel is increasing at a rapid rate which increases the
.
.
k
.
.
demand for training, that further parallel technical activities will soon be instituted, that all previous commitments still have not been met, and that there is only one person (the supervisor) assigned to the training function, it appears that the construction training program requires additional attention.
(c) Stone and Webster Field Quality Control Adequate records were not available to substantitate the training and qualifications of quality control inspection personnel.
This is documented in Section 5.c(5) of this report. The documentation was subsequently developed but it indicates a lack Of management attention to the verif-ication of skills of subordinate personnel.
5.
Construction Activities This part of the inspection concentrated on construction / erection activ-ities; quality of structures, systems and components (SSCs); and inspec-tion activities.
The objective was to assess the overall quality level of as-built SSCs.
Field inspections of coupleted SSCs and in process work were conducted to vs-ify conformance with design drawiags and proced-ural controls.
Informal discussions with craft workers, foremen and
. inspectors were conducted to obtain their views of the quality of work.
a.
Findings (1)
Items of Noncompliance Qualification and certification of inspection personnel was not in compliance with 10 CFR 50, Appendix B requirements and the l
Stone and Webster implementing procedures.
The training and
'
certification records were not complete and certification dates were not consistent with training records.
This was primarily a procedure / records problem which was corrected before the l
l termination of the inspection and is therefore a non-response violation of Severity Level VI.
(423/81-02-04)
(2) Deviations None.
(3) Significant Observations A positive finding is that the overall quality of as-built SSCs appeared to be of high quality and no problems were identified in relation to the construction / erection activities. The
.
l l
e
-
.
.
responses obtained from crafts and inspection personnel during informal discussions reinforce the NRC findings, all responses were positive in relation to quality of construction and manage-ment of the project. No allegati,ons pertaining to MS-3 were received during any interview.
b.
Documents Reviewed (1) Stone and Webster (a) Specifications Stone and Webster Specification 999.
-
-
Stone and Webster Specification 279.
E-350, Specification for Electrical Insta'lation,
-
Revision 2.
Project PQM Matrix, January 27, 1981.
-
(b) Drawings
-
25212-22109, Revision 2.
-
25212-22101, Revision 3.
Drawings located at control stations in the Spreading
-
Room and Control Room areas of the Control Building.
(c) Inspection Reports S1000-2028
-
S1000-213
-
E-0000-149 (NIS, inspection and continuity test
-
report)
-
E-0050-017
-
Weld Data Sheets (d) QA/QC Procedures QS-10.51 - Electrical Equipment Installations, Change
-
Notice 1
-
QS-10.52 - Raceway and Cable Installations - Change Notice 1
_
-
.
.
.
'36
-
QS-10.53 - Cable Termination and Connections
-
QS-14.2 - Inspection Report System
-
QAD-10.18 - Raceway and Cable Installation Inspection
-
QAD-2.5 - Revision C, Qualification and Ceritification
-
of Personnel Performing QA Activities QAD-9.2 - Revision 0, September 17, 1980, Welder / Welding
-
Operation Qualification Inspection QAD-10.13 - Revision 0, November 7, 1979, Visual
-
Examination of Welds
-
QS-12.1 - Revision B, Stone and Webster Calibration Program MS-1.6 - Preparation of Measuring and Test Equipment
-
History Cards
.
-
MS-1.1 - Revision A, Measuring of Test Equipment
,
Calibration System MS-1.2 - Change Notice 3, Calibration Identification
-
Labels MS-1.3 - M&TE Recall and !,strument Status List
-
-
MS-1.7 - Revision A, Intervals of Calibration
,
QAD-9.12 - Revision 0, dated August 13, 1980, titled,
-
" Visual Examination" QAD-9.24 - Revision A, dated June 17, 1980, titled,
-
" Chemical Control of NDT Materials"
-QAD-9.31 - Revision A, dated June 17,198d, titled,
-
" Liquid Penetrant Examination, Solvent Removable, Visible Dye Technique"
-
QAD-9.41 - Revision A, dated July 23, 1980, titled,
" Radiographic Examination General Requirements"
,
-
QAD-9.12 - Rev'sion 1, dated October 14, 1976, titled,
" Radiographic Examination, Pipe Welds"
-
QAD-9.44 - Revision 1, dated October 15, 1976, titled,
" Radiographic Examination, Qualification Welds"
. -
-. -
-
.
.
c.
Program Implementation (1) Civil /Structur_al The inspectors inspected several as-ouilt structures and in process placements at the plant site to assess general conformance to work procedures and good construction practices in the areas of concrete placement and curing and structural steel erection.
The civil test lab was inspected for conformance to procedural controls and calibration of equipment.
(a) Cadweld Splices The inspector observed a cadweld splice stored in the laboratory's tensile test area apparently for tensile test. On inquiry, the inspector was informed that the splice was a production splice which had been accepted on the basis of a visual inspection, and in fact, was awaiting a tensile test.
On closer examination, the inspector observed that although the splice had been inspected and accepted, it still had an inordinate amount of asbestos
.
packing material in the end grooves which precluded a valid void determination by visual examination. The inspector questioned the validity of such a superficial visual examination.
The constructor's representative acknowledged the inability to determine voids in the splice, and the departure from the manufacturers recommenda-tions for visual examination of splices.
Inspection personnel re-examined the splice after removing the packing material and the splice was found to be acceptable. The inspector witnessed this re-examination.
The inspector followed up the cadweld splice examination procedure and examined several other splices in-situ at widely scattered
'
locations in the containment exterior wall.
Following the additional followup examination, the inspector determined that the packing material in Splice #T19571 (Sleeve #1876)
l was an isolated instance of inadequate inspection.
The constructor's FQC organization reinstructed the cadweld inspection personnel in the importance of proper inspection.
(b) Observation of Concrete Placement Activities l
The inspector reviewed project specifications for concrete
'
l placement, and the quality control inspection requirements for the project.
The inspector also held discussions with inspection personnel present at the concrete placement site for Placement Nos. C-3668, Auxilia y Building and C-3670, ESF Building. The inspector further observed some concrete repair activity for surface voids in the refueling
,
cavity wall.
i a
--
-n
.
.
-
.
.
Based on the review of documents, discussions with inspection personnel, and the direct observation of work, the inspector determined the following:
The concrete placement activities conformed to the
-
project requirements.
-
The inspection personnel at the placement were knowledge-able of w:rk requirements.
They were located in close proximity to the truck discharge an~d final placement location to observe and inspect the quality of concrete and the placement operations.
The quality requirements of concrete property was
-
verified by testing near the point of placement.
The inspector verified that the delivered concrete met the specification requirements for the placement as to mix, slump, air and temperature.
Consolidation of concrete in the forms was edequate.
-
The form work was adequate and the rebar cover was as
-
required by specification.
In one location where the rebar cover was slightly less than required, the inspector identified this discrepancy to the constructor's QC inspector who immediately took action to correct it.
The repair of concrete was properly documented in
-
inspection reports and was being carried out properly as required.
,
(c) Structural Steel Erection The inspector inspected the as-built configuration of a structural connection in the cubical space frame for one steam generator. The inspection consisted of a review of design documents and a visual check of the completed connection for conformance to the design requirements and workmanship.
The inspector determined that the completed connection met the requirements of design in configuration, material and workmanship.
The inspector also observed the erection of supplementary steel in the control building by NEVCO, the subcontractor responsible for installation of duct work.
Foremen were interviewed and qualifications of welders involved in the activity were verified.
.
-
..
.
.
(2) Electrical (a) Conduit Installations The inspector inspected the nuclear instrumentation system
'
(NIS) conduit installation in the control building at elevation 24'6" (cable spreading room) and at the next lower elevation.
The installation was in conformance with drawing 12179-EE-57A, Conduit Plan and Section, Neutron Detector, in relation to conduit size, routing, and location.
Quality of the installation appeared to meet the requirements of specification E-350 and applicable quality control documents.
Separation criteria was maintained, number and total degrees of conduit bends was within specification requirements, and pull boxes were installed per design prints.
(b) Cable Tray Installation and Supports The inspector inspected cable tray installations and supports at Elevation 24'6" and 47'6".
Cable tray supports consist primarily of unistrut sections welded to structural steel or embed plates in accordance with weld techniques W71A and W70G (AWS).
Electricians were qualified to these techniques in accordance with the Stone and Webster welder qualification program (ree paragraph 5.c(5)(b)). The inspector cross checked the qualifications and records of electricians E-15, E-17, and E-18 to verify qualification to perform welds per W71A and W70G techniques.
Unistrot-to-embed welds were inspected for conformance to the requirements of E-350, paragraphs 3.1.2.33 and 3.1.2.34 which references AWS D.1.1.
The strut and plates exhibited evidence of proper preparation ar.d removal of galvanize at least 3/16" back from weld surfaces. The welds were of acceptable quality and free of cracks, porosity, undercut and did not exhibit any lack of fusion.
The welder identi-fication number was stamped on the plate or strut as required.
The physical location and structural detail configuration of installed cable tray supports in the cable spreading room and control room were verified to be in conformance with drawings EE-34KD-2 and EE-34EZ-2.
.
(c) Electrical Installation and Inspection Procedures The Stone and Webster hierarchy of standardized documents necessitates frequent cross reference of specifications, standards, directives and procedures.
In the process of
.
_
~-
_
.
-
.
-
.
i.
.
b projectizing documents, S&W may delete the applicability of a referenced document to MS-3 if the deletion is properly documented.
For example,.,5-10.52, Raceway and Cable
'
Installation, references C/A-9.2, CMP-9.3, and CMP-9.4.
These have been determined to be not applicable to MS-3 because the requirements are adequately addressed in E-350 and other specifications. After considerable effort, the licensee provided documentation of project approval for deletion of the referenced CMPs (Memorandum dated June 3,
.
1977 received by MS-3 FQC February 4,1981).
Specification E-350, Paragraph 3.1.1.2, contained a permiss-ive requirement that " cable pulling may be started without final sign off of the raceway tickets." This was in direct conflict with QAD 7.1.2 which stated that "when all applicable inspection attributes are satisfactory, FQC will sign and date the Raceway Ticket and forward the appropriate copy to construction as notification that the raceway is released for the cable pull." The permissive wording of E-350 could have resulted in future excessive partial cable pulls and allowed installation of cables in
.
nonconforming raceways.
The FQC and project staff, during
-
i the inspection, revised the E-350 paragraph to assure compatability with the QAD by issuance of E&DCR PS-E-979 dated February 3,1981. This is preventive in nature ar.d will eliminate a potential problem.
No cable has been l
pulled yet and therefore, no further corrective action is
'
required.
(d) Electrical Crafts and FQC Staffing The electrical crafts manpower strength is at approximately 115 electricians (including foremen).
Projected manloading in this area is for a rapid increase in c'
.tricians over the next twelve months to a level almost triple the existing level. The FQC electrical inspector staff is presently at three inspectors and is scheduled to increase to six by the latter part of 1981 to track the level of electricians assigned to safety related work. The FQC supervisor stated that Stone and Webster is actively interviewing candidates for the ap; roved electrical inspector positions.
(e) Craft and Inspector Interviews
,
During the field inspections of electrical installations, the views of three foremen, three electricians and two inspectors were informally solicited. The MS-3 experience of those interviewed varied from 2 weeks to several years.
.
yP
-p-7*
"T+
<g.
77,..7 g-,7 g%,._y,9,_.
7.9.,,,
,_
,,,,,, _,,,,., _ _,
_,
'.
.
.
'
All responses to NRC questions related to the quality of work of electrical equipment installations were positive and descriptions such as "very good", "too good," and
" excellent" were used.
No allegations of poor workmanship, defective / improper materials, or any other complaints were received.
The crafts personnel overwhelmingly stated that there was a very high level of QC inspection activity in the work areas.
Two foremen felt additional inspectors would be beneficial to speed up inspections at hold points. All electricians interviewed had knowledge of specific hold points and there were no reported instances of work proceed-ing beyond hold points either by the electricians or QC inspectors.
All interviewees reported good cooperation between crafts and QC and no reports of intimidation or threats to inspec-tors were received.
All persons interviewed rated both Stone and Webster and NUSCO management involvement and support as very good.
Most, with the exception of those recently hired, knew the NUSCO site manager, Stone and Webster managers and stated they ar e frequently seen in the field. There were no reported problem areas. One person felt that previous slowdowns in construction had been a " problem" in terms of job security and turnover.
Two of the crafts personnel stated they had not received the Stone and Webster construction orientation training.
Their hire-in dates corresponded to the time period when there was no Stone and Webster construction training supervisor and was in consonance with the comments of Stone and Webster management that some crafts had not received the orientation training.
(3) Nondestructive Examinations (NDE)
(a) Procedure Review This review included, but was not limited to NDE procedural attributes delineated in the appropriate article of Section V of the ASME, B&PV Code.
'
.
-
.
.
.
With the following exceptions, the procedures appeared to meet applicable code requirements. During this review, the inspector found that QAD-9.24 contained a listing of
)
penetrant materials that may be used in conjunction with
)
QAD-9.32. A further review discloseo that the latter procedure had been validated usin, only one of the listed matr -i al s. Although all listed materials were of the sob ;nt removable type, they were from different manufac-turers.
However, the procedure validations are performed at the Stone and Webster corporate office.
There was no documentary evidence, at the site, to demcnstrate that the materials being used (Sherwin Williams) had been validated in accordance with procedural requirements.
This item is considered to be unresolved pending an NRC review of adequate validation documents.
(423/81-02-21)
The radiographic procedure, QAD-9.41, requires that radio-graphic film be processed in accordance with an established procedure defining processing parameters consistent with Section V of the ASME, B&PB Code. An examination of the dark room and related activities indicated that film was being hand procassed. Although a formal procedure had not been developed to control all aspects of dark room activities, no rejectable films were identified.
However, film processing, both manual and automatic are considered to be special processes.
The contractor (Stone and Webster) committed to develop the necessary procedures / controls to assure that acceptable and archival quality radiographs are produced.
This item is considered to be unresolved pending an NRC review of formal dark room procedures / controls.
(423/81-02-22)
(b) Radiograph Film Review The inspector audited radiographs of production welds including Feedwater Penetration No. 5 and RCS-15 Weld No.
29 "C" Cold Leg Valve to Pipe.
Also, included in the review were several intermediate radiographs of Penetration Nos. 1, 2, 3, 4, 91 and 92.
Radiographic quality and weld quality appeared to be acceptable. One faint indication was observed in Weld No. 29.
This was being further evaluated for disposition by ti.e contractor at the termine-tion of the insoection.
.
V
.
.
.
.
.
(4) Safety Related Welding (a) Welding Inspection The inspector examined work activities associated with the repair of safety related penetration sleeve welds.
This review was performed to ascertain compliance with applicable procedure and code requirements. The repair involved cutting the penetration sleeve just outboard of the flued head-to-sleeve weld thus establishing the location for the new weld.
However, it was necessary to remove th'e backing ring which was an integral part of the existing weld.
Subsequent to its removal and examination, the necessary veld repair and buildup was performed.
The inspector monitored welding activities of the Main Steam Penetration Nos. 1, 2, 3 and 4.
This included applying weld buildup to the insida of the flued head to re-establish dimensional tolerances.
The information on the weld data sheet and associated repair documentation was verified by the inspector as being factual and correct.
(b) Welding PQM Matrix The applicable welding specification / techniques related to the above welding processes were also checked for compliance with the appropriate code requirements and the Contractor's Project PQM Matrix. This latter document is developed by the Materials Engineering Department and is periodically revised per spec fication, METG-14-1, and issued for site i
use.
This specification requires that the Matrix be
.
revised when any of the following occurs:
1) A Project l
Welding Technique Sheet is prepared or revised; 2) A Project PQM is prepared or revised; and, 3) A new addenda to the code goes into effect. A cursory review of the Matrix indicated that the latest revision date to be January 27, 1981.
This document also indicated that all listed documents met the Summer 1980 Addenda to Section IX of the ASME, B&PV Code. The unavailability of appropriate l
documents and personnel precluded verification of compliance
with the stated code requirement:.
This item is considered
!
to be unresolved pending an NRC review during a subsequent inspection.
(423/81-01.-23)
.
l l
l l
l l
l
.-
-
.
-
.
-
.
(c) Welding /NDE Personnel Interviews The inspector interviewed eight contractor personnel including, welders, quality control inspectors and craftsmen.
Each individual indicated that he received adequate management support and direction.
Each further stated that he felt that the quality of work to be excellent. All persons interviewed indicated they had no knowledge of anyone being intimidated or instructed to disregard procedures.
Two of those interviewed said they had left other jobs (not nuclear) because of production pressures and lack of management support.
(5) Personnel Qualifications (a) QC Inspector Qualification / Certification The inspector reviewed the records and held discussions with licensee and constructor personnel regarding the qualification and certification J quality control inspection personnel. The inspector reviewed the following documents:
Training and Certification records of over eight (8)
-
QC personnel from civil / structural, electrical and NDE disciplines.
-
ANSI N45.2.6-73, " Qualification of Inspection, Examina-
-
tion and Testing Personnel for the Construction of Nuclear Power Plants."
Stone a d Webster QAD-2.5, Revision C, " Qualification
-
,
i and Certification of Personnel Performing QA Activities."
l Memoranda:
l
-
I R. A. Plant to G. G. Turner
-
j G. G. Turner to R. A. Plant, dated January 5, 1981
-
l G. G. Turner to R. A. Plant, dated January 22, 1981
-
l l
The certifications of the inspection personnel were issued l
by the Boston office of Stone and Webster Engineering Corporation and were required by procedure to be based on i
experience, examinations and proficiency tests. They were issued by a Level III examiner designated by Stone and l
Webster Engineering Corporation QA Department.
i
-
l l
-
,
-
--
-
-
..
- - - - - - -
-
-
.
.
.
.
In all cases the documented date of certification was the hire-in date of the individual and in many cases, the certification was issued prior to the examinations and proficiency testing conducted by the FQC. As an example, one inspector was certified on September 22, 1980 but he did not complete the examinations and proficiency tests until October 20, 1980. Another inspector was certified in December 1980, but he was not recommended for certifi-cation in a memorandum from Turner to Plant until January 22, 1981. The qualifications records for one electrical inspector were deficient in that the date of certification was incorrect and there was no objective evidence (proficiency exam) of qualifications of the inspector to perform inspection of welds. Thus, the basis for certification of these personnel was incorrect and the certificates did not
-
assure that suitable proficiency was achieved before granting certift:ation. This was identified as a noncom-pliance to Criteria II of Appendix B, 10 CFR 50.
The Stone and Webster organization took corrective action during the inspection to correct.the paper work problems related to certification and to assure future certifications are granted after proficiency has been demonstrated and documented. The inspector verified by discussions with the inspectors that their knowledge was adequate to perform the level of inspections assigned to them.
It was determinad by the NRC inspector that the corrective action was adequate and that no written response to the item of noncompliance is required.
(423/81-02-4)
(b) Welder / Welding Ooerator Qualification Program The applicable refererced documents were ra"tewed by the inspector to determine basic scope, completeness, and consistency with referenced codes, standards and regulatory guices. The aforet.entioned documents were used for refer-ence during the inspection of quality related activities and documentation.
Based on this review, observations, and discussions with cognizant personnel the inspector determined that welders /
welder operators training was consistent with program requirements. Additionally, the inspector monitored six welders and one welder operator during preparation of
'
specimens for qualification tests. The inspector also visually. examined several welded samples that had been accepted for testing. All were considered to be acceptable to established criteria.
Several radiographs of welded
_
-
.
.
.
.
specimens were randomly selected for review to determine weld and radiographic quality.
No weld defects were discernible on these radiographs. Quality of radiographs appeared to be acceptable using the image quality indicator as required by the code.
(6) Calibration Program The calibration program for measuring and test equipment (M&TE)
is delineated by QS-12 1, Revision B, dated December 2, 1980 which refe~ences the Stone and Webster Calibration Manual. The inspactor verified the calibration of torque wrenches M&TE
- 04894 and M&TE #04763 1 sed by the electrical crafts at elevation 24'6" for torquing bolts on electrical installations.
Both torque wrenches were properly identified and labelled in accord-ance with Procedure MS-1.2.
Calibration status was traceable to the calibration laboratory and the M&TE History Cards were accurately prepared in accordance with Procedure MS-1.6.
Records for each tool reflected calibration date, procedure, recall date, and calibration data from five (5) equally spaced calibration points as required per CP-4-N-001.
The test equipment in the civil / structural test lab was inspected fcr conformance to calibration program requirements.
Tensile test and compression test machines were in acceptable operating cenditions, calibrated and properly certified.
The environment of the moist curing room in the laboratory was controlled in accordance with ASTM standards and instrumentation for monitoring humidity and temperature was calibrated and traceable to secondary standards.
The storage facility (issue station) for weld rods was inspected to verify calibration of storage oven thermometers and compliance with calibration program requirements. All rod storage ovens were found to be operable, valid calibrations and within required temperature range.
6.
Procurement / Storage of Materials and Equipment The purpose of this part of the inspection was to assess the effective-ness of site activities in relation to procurement, receiving inspections and storage of materials and equipment.
al Findings (1)
Items of Noncompliance None
.
"
-
-- - - -
-
- - - ---
.
.
.
.
(2) Deviations None (3) Significant Observations None b.
Documents Reviewed (1) Quality Assurance Documents QS-13.11, CN1, Material / Equipment Storage
-
QA-13.12, Material / Equipment Maintenance
-
-
QAD-10.9, Storage and Work Area Cleanliness
-
QS-15.3, Risk Release of Unsat/ Nonconforming Material /
-
Equipment FCP-121, Equipment Storage History Cards
-
,
FM3-S13.12-01B, Preventive Maintenance
-
QS-13.31, Work Area Cleanliness
-
QS-7.10, Control of Purchased Material / Equipment and
-
Services (2) Construction Methods Procedures
,
CMP-6.4, Welding Material Control
-
i CMP-1.3, Material / Equipment Storage
-
CMP-1.4, Housekeeping
-
l (3) Other Documents
!
Material Receiving Report 80-094 for Electrical Switchgear
-
Stone and Webster Purchase Orders 10161, 10275, 10425,
-
10621 and 10634
,
l Certificates of Conformance - Stone and Webster Procurement l
-
Quality Assurance (PQA) for Switchgear
.
Certificates of Conformance - For Unistrut Material
-
i
!
-
!
.
.
.
.
Mill Certification - Rebar and Weld Rod
-
Random sampling of 1980 and 1981 FQC inspection reports
-
for storage and maintenance
,
Preventative Maintenance Records for Rockwell Hydrogen
-
Recombiner (3-HCS-RBNR-1B), Conax Electrical Penetrations (1A-13, IA-14), Safety Injection Pump (3-SIH-P-IB)
Vendor Storage Requirements Manuals, Rockwell Hydrogen
-
Recombiner and Conax Penetrations c.
Program Implementation (1)
In-place Storage (a) Stone and Webster Inspection Schedules The inspector verified that FQC had developed a scr.edule of inspections for stored in place equipment and that scheduled inspections had been performed.
(b) Electrical The inspector verified that electrical equipments installed or set in place were adequately protected to prevent degradation from environmental and work place stresses.
As examples, the inspector inspected set-in place switchgear located in th control building and limitorque valve operators in the containment building.
The switchgear was located in a moderate temperature environment and was being prepared for installation. The equipment was adequately protected from constructica dust and water by protective covers.
No degradation or damage to the switchgear was detected.
Field quality control had performed in place inspections of the switchgear on an area basis and recorded these inspections in accordance with procedural controls.
The inspector noted that the switchgear was to be welded to embedded channels to assure seismic mounting. However, only three channels had been embedded in the concrete, whereas four were required to span the width of the switch-gear.
In discussing this with electricians and Stone and Webster inspectors, it was pointed out by them that the discrepancy had been identified and was documented on E&DCR PS-3199 which prescribed a fix. The inspector verified that the E&DCR was available at the applicable
_
location.
.
f
"
--m-y
-
r-
.
r
.
.
.
i. -
Limitcrque valve operator 3RHS-MV-8702-C-I located in
>
cubicle D of the containment was adequately protected by
covers, cushioning material and electrical heaters were energized to prevent condensation inside the motor casing.
(c) Mechanical The inspector observed the in place storage and protection provided the Reactor Coolant System Pumps, valves and two Accumulator Tank Nos. 3-SIL-TK-1B and IC.
The inspector l
found that the protection provided these components was
!
consistent with the requirements of the applicable specif-ications and procedures, with the exception of the tanks.
The inspector noted that the internal nitrogen atmosphere had been removed to permit the installation of connecting piping. Discussions with contractor personnel disclosed that the removal of the internal purge had been approved by the cognizant engineer and was so documented.
The inspector also observed safety related stainless steel pipe spools stored inside and adjacent to and outside the auxtlary building. An examination of the material stored inside the building at about the 25 foot elevation revealed that no protective covering was provided and that the spools had been contaminated by globules of paint adhering to the outside surface of the uppermost spools. The contractor's QC personnel took immediate corrective action in what appeared to be an isolated instance.
<>ipe spools outside the building were stored without protective coverings under erected scaffolding. Overhead concreting activities were scheduled to sti.rt above the l
pipe spools in the near future. These two conditions l
prompted the inspector to review the implementing proced-(
ures to determine how interfacing between the onsite l
organizations is accomplished with respect to providing
!
adequate protection for equipment temporarily stored i
in place from planned / adjacent on going construction
!
activities. The procedures lack specificity in that there l
is no formal requirement, nor assignment of responsibility, to initiate protective measures or to assure their contin-
'
uation. This is considered unresolved (423/81-02-24).
(d) Audit Accompanime3
.
The inspector accompanied the S&W field QC inspector on her daily routine inspection of the safety related equipment that is installed in place in the various Millstone 3 Buildings.
~
_
_
.
. -
.
.
.
(2) Warehouse Storage The inspector observed the physical :torage of several rafety related equipments stored in the warehouse to verify compliance with the above referenced documents.
The inspector also reviewed
'
the inspection and maintenance reco.ds for the referenced items to verify compliance with the requirements in the applicable documents.
(3) Weld Rod Storage The inspector audited storage facilities for we' ding materials.
This audit included a review of the contractors " General Welding Procedure for Pipirg Systems," W-lu0, Revision 7, and attachments which establishes requirements for the storage, handling and issuance of welding materials. The inspector audited weld rod issue slips of weld rods issued between January 28, 1981 and February 4, 1981. The information on the issue slips was consistent with procedural requirements and indicated that weld rods issued were as specified by the appropriate welding procedure.
The inspector verified that welding material in the issue
'
station was being stored in heated rod ovens with calibrated thermometers and were set at the appropriate temperature for the applicable welding rods.
The inspector observed that some rod shipping / storage containe-
.iad sustai ed damage. These damaged containers were unopened and were as-rsceived by the issue station. A container, with representative damage was opened to determine content integrity.
The coating on the 7018 electrode
was inspected for visible damage. No observable damage was identified.
An inspection was pt'eformed of warehouse electrode storage.
The inspector observed several shipping containers with varying
,
degrees of damage. However, none appeared to have the hermetic l
seal broken. An audit was performed of the warehouse surveillance
'
reports. A resiew of inspection attributes delineated on these reports excluded container damage.
Discussions with cognizant personnel indicated that no attempt is made, during receipt and storage, to evaluate content (rod) integrity. Howaver, if the l
container is punctured, all electrodes contained therein are reje cted.
'
(4) Procurement
,
The refe enced purchase orcers, certificates of conformance and associated records were reviewed for compliance with program
!
and procedural requirements.
!
!
!
'
,
,y
- -
.
,y-
-. -,
. _ -. _ _ _ _. -
_
_ _,. -
.
-
. - - - -
-
.
.
(5)
Independent Verification The inspector selected a sample of reinforcing steel and weld rod from the field stock for independent analysis.
The materials were independently analyzed by an NRC contractor laboratory and the results of the independent analysis was compared to the material purchase order and supplier certificates of compliance /
mill certifications.
(a) Reinforcing Steel The rebar was purchased per P.O. 2199-310-279 from Bethlehem Steel.
The #18 rebar steel was purchased as ASTM A615-72, Supplement 51 as modified to meet chemical and physical requirements of "Special Grade" 50 KSI yield and ACI 318-77. The mill certification was available for review.
The rebar was analyzed for chemical composition per ASTM specification A615-72, Part 4, the physical characteristics were tested to A615-72, Part 7, and a bend test was performed per Part 8.
The independent laboratory concluded that the steel conformed to the ASTM A615-72 requirements.
(b) Weld Rod The weld rod was purchased from ARCOS Corp. under purchase
'
order 12179-35065 and specifications as follows:
E308-16, ASME SFA 5.4, Class E308-16
-
ASME Section TI, Part C S&W Spec. ME-103C ERNI-CU7, ASME SFA S.14
-
AWS AS.14-69 ASME Section II, Part C S&W Spec ME-108C The quality assurance records for these rods contained Certification of Tests.
l The independent laboratory tested the rods for composition i
to ASME SFA 5.4 (Class E-308-16) and ASME SFA 5.14-69 (ERNI-CU7). The results were compared to typical analyses
of these materials and the values reported on the suppliers certif1 cation.
The comparisons were favorable.
'
.
i l
.
_
_
. _ _. __._ _ -
_ _._. ____ -
- 1(..'
7.
Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Sections 2, 4, 5 and 6 of this report.
8.
Exit Interview The inspectors met with the licensee representatives (denoted in Section 1) at the conclusion of the inspection on February 6, 1981 at the MS-3 construction site. The inspector summarized the scope of the inspection and discussed the inspection findings.
-
e i
l t
'
_
,
-
. - - -
-
- - -..
- - - _
,. _
-