IR 05000458/1984023
| ML20151K987 | |
| Person / Time | |
|---|---|
| Site: | 05000000, River Bend |
| Issue date: | 06/21/1985 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20151J031 | List: |
| References | |
| FOIA-87-866 NUDOCS 8506280211 | |
| Download: ML20151K987 (13) | |
Text
_ _ _ _ _ _
,. i
_
e June II, 1945 M(MORANDUM FOR:
R. P. Denise Olrector Olvision of deactor Safety and Projects, Region IV FRON:
J. G. Partlow, Ofrector Olvision of Inspection Programs office of Inspection and inforcement SUBJ[CI:
AS$t$5 MENT 0F IWI.tl(NTAfl0N 0F THE NRC INSPECTION PROGRAM BY Rt010W IV AT RIVER SEND STAfl0N The Office of Inspection and Enfortetent desCrlbed to the C0amilslon in SECY 82 150A the assessment of the laplementation of the NRC Inspection program in conjunction with Construction Appraisal Team (CAT) inspections. Accord-Ingly, we have examined Region IV's laplementation of the constraction inspec-tion progran based on the July August 1984 CAT inspection at River Send.
The results of the inspection were documented in InspeCtlon Report 50 458/84 23, dated October 19 1984.
The enclosure to this seeorandus docu-ments the results of our assess, ment of the construction Inspection progran laplementation.
Ortstaalslaned W 8 Junee 6. Pentet J. G. Partlow Ofrector Olvision of Inspection Programs Of fice of Inspection and Enforcement Enclosure:
Assessment cc:
J. Taylor, it g.y,J{.lyp.is nl M/r M. llei shm.in
)
.l. Konklin H. l'eranleh 11. Wons A!5 ( /6 W
i J/JA f
N
,
RCPB:01:It RCPs:01:1E RCPB:01:!!
RCPB 1:1E DIR:
IE INong/v j JKonkiln I MPeranich RHetIiman JPar 1 p 7/8 06/g /85 j W06/h/85 06/
/85 06/,/85
_
--
x porg. r7-r4
9!o62oo@ r#k
- /f tv
=
_
_ - _ _.
____
_ _ _ _ _ _ _ - _ _ _ - _ _ _ _
___.
__ _ _
__
-
,.
,
.
,
REGIONAL CONSTRUCTION "NSPECTION PROGRAM
A55[55 MENT = RIV lR 5[NQ (RIV)
l 1.
SCOPE TheConstructionAppraisalTeam(CAT)oftheOlvisionofInspection Progrees conducted an announced construction innection at the River Bend Station of the Gulf States Utilities Cospany during the period of July 30th * August 10th and August 20th * August allt, 1984. While the pre *
dominant ef fort of the inspection tsaa was devoted to hardware inspecticn, the team also evaluated the control of design changes and corrective actions.
Inaddition,adetailedexaminationwasmadeofprojectcon-struction controls.
The purpose of this assessment is to evaluate the laplementation by Region IV of the Construction Inspection Program. A further purpose of the assessment is to make recossendations, if necessaryf the licensee'sto improve inspection prograa so that a comprehensive review o construction activities is covered by the Construction Inspection Program.
,
!!u A55t55 MENT ACTly! Tit $
A review was made of RIV's inspection and SALP reports of the River Bend Station to identify those deficiencies that were previously identified by RIV inspectors.
The inspection reports of 1979 1984, the 1982 and 1983 SALP reports, open iteal and violations wre reviewd.
The Executive Summary and Potential Enforcement Actions of the River Bend CAT inspection report is provided as Appendix A and Appendix 8.
The inspection reports for 1983 and the 766 inspection data wre analyzed and it was determined that approximately 1850 man hours of direct inspec-tion effort wre performed by Region IV at River Bend in 1983.
The analysis of the reports and coeputer data indicated that the construction inspection program was approximately 85 percent complete at the start of the CAT inspection.
The total man hours and percent completion is com-parable to other construction sites and Regional totals for the construc-tion status of the River Bend construction effort.
!!!. !N5P(Cil0N FI,NQ]]Q A.
(lectrical and I,n,,,strumentation Construction 1.
CAT Findinot
A number of cable and raceway separation deficiencies w re identified.
'
The CAT inspectors found that a number of cable tray supports did not meet the drawing configurations that were used for determining support loading.
l
,
--..
,.__,
,-.._._.._.._.-____.._,____--,_.-__.,_..,_,.,_,,_.,,,,_,,_._._m_,_,_-_,__,,__....,-.___,_____-,.,,,,,_..,.,m,.,,,_-m..,.-mmm,_
-. _,
__- _-
.
.
'
2.
Assessment
'
The cable raceway separation deficiencies were previously identified by the Regional inspectors in Inspection Report 83 21 and was being carried as an open item.
Further, the Region had endeavored to have an electrical construction consultant review the separation probles prior to the CAT l
'
inspection.
'
Inspection Procedure 37051, As Built Verification has not as yet been implemented by the Region and it is possible that the cable tray support problem may have seen identified.
3.
Recomendation The existing Construction Inspection Procedures if properly implemented are adequate to have identified existing problems.
8.
M CHANICAL COV,,TRUCTION
,
1.
CAT Findinos
._
Several instances were identified where engineering dis-positions of H & Os and E&DCRs were not as thorough or extensive as necessary to address generic considerations of identified hardware deficiencies.
- Problems were identified with pipe support / restraint lock mechanisms, taproper protection and misuse of pipe supports.
2.
Assessment
The Region in the past has identified an inadequacy of the licensee's handling generic considerations of N & Os and E&OCRs. The specific problem with the incompatibility of ASME snubbers was the subject of a NRC Information Bulletin but for different manufacturers.
- The problems identified with pipe supports / restraint lock mechanisms, improper protection and misuse of pipe supports is common to most sites in the latter stages of construction and require more frequent surveillance and follow up by the Itcensee.
3.
Recomendation The Construction Inspection Procedures for this area are evaluated to be adequate to have identified the cristing problems.
g.
.
.
,-.
-
>+r
.=.
w
-
-y w---
--- - - - - -
m.-
-ew-ww,--
p.w-,e--N---er*
W-y-e*v+w- - -
-*"-e'eT-*" '
=**r*T'""""
-'"'-"8-"-"*---F#'*""'***
- """"'""C
- " '"
'*
-.
___
_-
-_
__
__
___
_ - _ _ _
_ _ _ _ _ _ _ _
-
,,,
,
.
.
.
C.
WELOING NDE 1.
CAT Findings
Several discrepancies were identified concerning film supplied by a pipe vendor.
- Discrepancies were also identified during the inspection of the vendor equipment and review of vendor film.
2.
Assessment
The piping vendor film discrepancies were reported to the NRCandtheRegioniscarryingthedeficiencyasanopen item and is currently reviewing the licensee s corrective action.
- The deficiencies identified concerning vendor film and equipment has been a recurring problem at many of the nucleal construction sites and the current reorganization
and redirection of the Vendor Inspection Program should result in addressing these vendor deficierr:tes.
,_
3.
Recomendation The Construction Inspection Procedures for this area are determined to be adequate if the program is properly imple-mented.
The identified problems with vendor film and equipment will be brought to the attention of the Vendor Inspection Program Branch for their evaluation.
D.
CIVIL AND STRUCTURAt CONSTRUCTION 1.
CAT Findinas
Identification of two cracks in concrete, and Roto Foam, debrisandconcreteinplantisolationjoints.
'
A significant numb 6r of high strength bolts in the Reactor Building structural steel connections were found to be below minimum torque values.
2.
A,$lelsment
The current IE Inspection Procedures do not specifically call for the inspection of foreign material in isolation joints.
However good inspection practice and a review of the licensee's construction and inspection procedures should have indicated the need for this inspection to be performed by the Regional Inspectors.
.
. - _ _ _ _ _ _ _
-- -
.
. -
.--..--.--=:..
.
,
n.
,
.
.
'
'
The current inspection Procedure for Structural Steel and Supports does not specifically require a recheck of structural steel bolt torquing after initial inspec-tion. The relaxation of bolt torquing has been identified at previous sites and the Reactor Construction Programs Branch will evaluate including this recheck in existing procedures.
3.
Recommendations Other than the evaluation fer retorquing of high strength bolts the Inspection Program Procedures are evaluated to be adequate for this area.
E.
MATERIAL TRACEABILITY 1.
CAT Findinos
The temperature control of weld filler material storage ovens was deficient.
,
.
'
Workorreworkofsomeflangejointswasbeingaccomplished
,_
without QC or engineering concurrence.
2.
Assessment
The regional inspectors have made frequent inspections of the licensee's control of weld filler metal and have l
not found temperature control deficiencies. These inspec-tions are outlined in Re and others. gional Inspection Reports 81 8, 825,832, The identified deficiency is apparently a result of r change in the licensee's monitoring procedures and is being reviewed for possible corrective action by the licensee.
- The identification of undocumented rework performed on a pips flange is apparently an isolated case and was not identified in other discipline areas.
3.
Recommendations The Construction Inspection Procedures for this area are evaluated to be adequate for the area of material traceability.
F.
QlilGNCHANGECONTROLSANDCORRECTIVEACTION$YSTEMS 1.
CAT Findtnas
Incorrect mounting of diesel generator silencers.
- Installation of ASME Class 3 orifice plates in ASME Class 2 lines.
.
_
w----
+--
---r
,
,-y%
_w--.-
-,,, - - - - - -,,. - - -
-.r---g-
.,.g
-%
,,_.-,,,..,9-9g-,,-,,.,p,-.,,9,,,eg-y-
-,,,,w,y
-
y7-g y,,yww-w
-- - -, -.-im
-
cg-'
=g*w e-yw..w-yv,-
'..
'
t
<
'
'
Inadequate corrective action being taken to preclude
repetition of non conformances or to properly disposition existing nonconformances.
'
2.
Assessment
'
The mounting of the diesel generator silencers was in accordance with the manafacturer's installation direction.
However, the design was found to be deficient.
This problem
,
has been identified by the CAT at other facilities.
- The improper installation of Class 3 orifices in a Class 2 line was a result of an engineering specification error and it is possible the licenses would have identified the error during its ASME document review.
- The necessity to continuously review the licensee's adequacy for corrective action is comon to many construction sites.
3.
Recommendation
,
The regional inspectors should review previous CAT construction
.-
appraisal reports to better assist them in identifying deficiencies.
G.
PROJECT CONSTRUCTION CONTR0t$
1.
CAT Findinos
The GSU quality assurance audit section needs to periodically review its audit program.
- GSU needs to develop and implement a quality concern program.
2.
Assessment
The overall audit program for River Bend was adequate and failure to detect some missing audit criteria is not unexpected.
The failure of GSU to audit the engineering activities at Stone and Webster - Toronto will be addressed by the Vender Program Branch.
- The lack of a GSU quality concern program at River Bend has been the subject of prior conversations between GSU and the Region IV Regional Administrator.
3.
Recomendation The Construction Inspection Procedures for these areas are evaluated
.
to be adequate for their intended scope.
.$.
__
_ - _
.. _ _
.
. -..
.1
_ _
_ _. _ _
_ _ _ _ __
_
.
. _ _. _ _.
___
__ __
.
.'
-
.
^
IV.
OVERAll ASSESSMENT CONCLUSIONS The implementation of the Construction Program Inspection Procedures at the River Bend Station was satisfactory.
The majority of the CAT findings or related findings were identified by the Region.
Those CAT findings not specifically identified by the Region will be the subject of evaluation by the Reactor Construction Programs Branch for possible specific inclusion in the current inspection procedures.
Those CAT findings that relate to the Vendor Program Branch will be trans-mitted for their evaluation and possible inclusion in their activities.
It is recommended that the previous CAT reports be made available to the Resident inspectors for their review for possible applicability of the findings to their specific construction site.
.
mee 6-
_
.-
-- --._.
._.
..
.
. - -.
.
.
...
. -..
.
-. - -. - -.
..
.
.... -.
-
l
.
.
,'
,
.
.
APPENDIX A EXECUTIVE SUMMARY An announced Construction Appraisal Team (CAT) inspection was conducted at the River Bend Station during the period July 30' August 10 and August 20-31, 1984 Overall Conclusions It is the conclusion of the Construction Appraisal Team that the hardware, docu-mentation for construction activities, 'and project constructicn controls were generally in accordance with requirements, commitments and principles of prudent management. However*, the team did identify a number of construction program weaknesses that require management attention. These are:
1.
The inspection program, in the area of cable and raceway separation deficiency identification, requires improvement. A number of cable and
.
raceway separation deficiencies were identified by the hRC CAT in raceway and cable which had been previously inspected by site field Quality Control.
2.
Ilueerous cable tray supports did not eeet the drawing configurations that were utilized for determining support loading.
3.
The applicant failed to consider the generic implications of identified ceficiencies. An identified problem with incompatability of non-ASME snubber assemblies was not investigated to determine application to ASi1E snubbers, and a specification change requiring the installation of a fire barrier seal for fire dampers was not specified as applicable to previously installed and accepted hardsare.
Imp.lementation of FSAR and procedural engir.eering requirements were not consistently met in the areas of cable tray fill, cable spacing and
-
.
cor, trol of hydrogen producing materials.
- In sumry, the identified weaknesses require increased attention by management I
to assure that completed installations meet design requirements, gAsINSrECTEDAfi0RESULTS
-
Electrical and Instrumentation Construction The majority of the electrical and instrumentation samples were found to meet the appropriate design and construction requirements. However, deficiencies were identified in several areas including items which will require additional tiRC review and analysis.
Although not extensive, a number of cable and raceway separation deficiencies were identified, and it was determined that the applicant's inspection program in this area was not fully ef fective. Additional information is also rt. quired A-1
-
.-
--
-
.
..
m;
.
.
s\\
D
.
regarding qualification and NRC approval of fire barrier raaterials used in cable wrap applications.
Implementation of FSAR and procedural engineering requirements were not consistently performed in the electrical area. Examples include failure to implement requirements limiting the use of hydrogen generating materials inside the. containment drywell and failure to properly,1ncorporate FSAR requirements for items such as tray fill and cable spacing into quality control procedures.
A number of cable tray supports did not rneet the drawing configurations that were used for determining support loading.
Several discrepancies were found in ' equipment environmental qualification reports indicating that review of reports of this type requires improvement.
The Class 1E 125 volt batteries had been charged and turned over to the startup organizatien even though the battery room ventilation systems were still under construction and not in operation.
This indicates that additional management attention is required for the control and maintenance of completed equipment turned over to startup.
.
,
,
f7chanical Construction The mechanical equipment and HVAC supports / restraints were found to be constructed in accordance with applicable requirements. Although discrepancies were noted on piping, pipe supports and restraints, concrete expansion anchors and HVAC ducting and accessories, no serious technical deficiencies were observed.
Several instances were observed where engineering dispositions on Nonconfomance and Disposition Reports and Engineering.and Design Coordination Reports were not as thorough or extensive as necessary to address generic considerations of identified hardware deficiencies. Lack of thoroughness by engineers and QA reviewers in this area could allow potentially significant safety issues to be overlooked or inadequately resolved. Lack of attention to detail and poor construction practices with regard to installed and accepted baroware was evident.
Problems were identified by the NRC CAT with pipe support / restraint fastener
-
.
locking mechanisms, improper protection and misuse of pipe supports and the
'
number of interdisciplinary clearance problems that had not been pre-authori:ed by engineering, weldina and Nondestructive Examination welding and nondestructive examination activities were generally found to be in accordance with applicable codes and specifications. However, several discrepancies were identified concerning film supplied by a piping vendor.
The applicant had previously reported similar problems (o the NRC and the NRC CAT believes that the applicant should review additional radiographic packages in order to assure that discrepancies identified by both the applicant and the NRC constitute isolated cases, in addition, some discrepancies were also identified during the inspection of vendor equipment and review of vendor film. The applicant has connitted to reviewing these discrepancies and the NRC will assess the results of this review.
A-2
--
__
. _ _ _ _ _ _ _ _ _ - _ _ _ _ _. -____________________ -
F
-
?.
.
.
.
.
Civil and Structural Construction Concrete quality, Cadwelding and Concrete Material Certificatien were, in general, found to be acceptable. Rebar appeared to be placed in accordance with the However, deficiencies identified by NRC CAT inspectors, namely i
cesign drawings.
two cracks in the concrete, and Roto Foam, debris and concrete in the plant i
isolation joints (rattle spaces) are indicative of a need for improvement in the inspection activities.
..
Structural steel member size, configuration and connections were generally
,
fcund to be acceptable. Two steel connections were found not to be in accordance with the design drawings and are being evaluated by S&W. These are also indications of a need for improvement in the construction inspection
-
program.
'
A significant number of high' strength bolts in the Reactor Building structural steel connections were found to be below minimum torque values. This indicates
'
i that these bolts do not have the bolt preload required by AISC specifications,
_Haterial Traceability and Controls
,
-
Egeneral, the project traceability and controls program was found to be acceptable. A few deficiencies were fcund by the NRC CAT in the material
'
traceability and control of some safety-related f asteners, piping flange components and environmental control of weld filler material storage ovens.
Work or rework of some flange joints was being accomplished without QC or engineering concurrence or knowledge which also resulted in a loss of material control.
Design Chance Control
.
Design change control, including control of changes to design documents, was determinea to be generally in conformance with applicable requirements. A number of isolated (non-generic) discrepancies were identified, of which the most significar.t were incorrect ecunting of diesel generator silencers and instalfation of ASME Class 3 orifica plates in an AStiE Class 2 line. Three
,
deficiencies were identified which could be generic; two of these deficiencies
.
concerned failure to check and independently review design calculations prior
'
e to release of design information to Construction. The third was the use of E&DCRs to identify nonconformances.
'*
Corrective Action Systems
,-
i In general, the corrective action program utilizing Noncenformance and Otsposition Reports to identify, evaluate and correct nonconforming conditions was found to be acceptable except that in certain instances inadequate corrective action was being taken to preclude repet. tion of nonconformances or to properly dispose of existing nonconformances, project Construction Controls The overall project construction controls were found to be adequate to assure that construction and test activities will meet quality requirements. Specific A-3
.._
'
..
..,
.,
,
',,,g:
'
-
.
..
\\
areas were identified that require additional managenent attention.
Project management review of important quality control reports needs to be improved.
.
e,;.s The GSU quality assurance audit section needs to periodically review its audit program to make sure that all scheduled audit areas have actually been addressed.
':^
An improved and more comprehensive quality concern program needs to be developed.
proceduralized, and implemented.
-
..
?
e
.
e
,
emme
.
M
-
,
.
'
I r
.
A4
--.
_
a.
.a
.
_
. _ _ _ _ _ _ _ _ _ _ _
.
I
- *
.
t.,
,.
.
L ',
APPENDIX B POTENTIAL ENFORCEMENT ACTIONS
..
As a result uf the NRC CAT inspecticn of July 30 to August 10 and August 20 to August 31, 1984, the following items have bee Potential Enforcement Actions (section reference.n referred to Region IV as s"are to the detailed portion of the inspection report):
1, Contrary to 10 CFR 50, Appendix B, Criterion !!, and GSU Nuclear Quality Assurance Manual (NQAM) Quality Assurance Procedure QAP-2, the applicant failca to regularly review the sta,tus and adequacy of the Quality Assurance Program in that certain quality trending documents did not receive adequate rnanagement review.
(Section IX.B.2)
2.
Centrary to 10 CFR 50, Appendix B, Criterion !!!, and GSU NQAM QAP-3,
'
design cor, trol has not been inaintained as the applicant has:
' Failed to verify adequacy of design. Lead calculations for' Reactor
-
a.
Cuilding cable tray supports were based on design informatien wMeh
,
'
-
does not represent as-built configurations.
(Section!!.B.1)
6.
Failed to properly translate FSAR recuirements for items such as cable tray fill, cable spacing and cot trol of aluminum permanent plant materials inside of the containment drywell, into specifica-tions, drawings, procedures and instructions.
(Sections!!.B.1 and !!.8.2)
J Contrary to 10 CFR 50, Appendix B[ Criterion VI, and GSU NQAM QAP-6, 3.
reasures failed to assure that procedures and drawings, including changes, were used at the location where the prescribed activity is performed in
,
that nine of the 37 inspection reports on anchor and high strength bolting had the incorrect revision of either the drawing or the procedure identificd on.them.
(Sections Ill.B.3 and V.B.2)
.
Centrary to 10 CTR 50. Appendix B Criterien X, and GSU NQAM QAP-10, appli-
'
cant failed to provide an adequate inspection program in that:
inspection of sorno raceways for physical separation had not becn a.
accor.iplished in accordance with the criteria established in the applicable procedures.
(Sectiori !!'.B.1)
b.
Safety-related ASME class pipe support / restraints have not been constructed and inspected in accordance with design requirements.
(Section!!!.B.2)
5.
Contrary to 10 CFR 50, Appendix B, Criterion XVI, and GSU NQAM QAP-16,
,
the applicant's program nas faileo to assure that conditions adverse to quality have been prortptly identified ano corrected in that:
B1
_
_
.
-
,:
- q,
- . :.
.
,
,.;
bJ
.--
g.
-;...
-
,.-
i..
.
,,
.
"
...
An identified problem with non ASME snubber assemblies was not a.
investigated sufficiently to reveal the same problem on ASME snubber r
assembifes supplied by the same vendors.
(Section!!!.8.2)
.
.
b.
A new specification requirenent for the use of fire barrier sealant
-
around fire damper to wall joints was not clearly identified to be backfitted to previously installed ano accepted hardware.
(Section III.B5)
Inadequate corrective action is being taken to preclude repetition
!
c.
of nonconformances.
(Section Vill.B.1)
'
,
- ..
.
O f
.
a-
!
l
-
l
.
,
!
!
.
.
t
.
,
'
.
i
.
e
.
l
!
l Ba2
_
._
-me,
- - - -
--.-,-m-,,,,4 y,---g
- - - - - -, - - -, - - -
,,-,.-m
.
y __
- - -
--
g-m.--m-,,-m~-
e
_