IR 05000460/1981010
| ML20039E984 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 12/21/1981 |
| From: | Dangelo A, Dodds R, Haist D, Hernandez G, Narbut P, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20039E976 | List: |
| References | |
| 50-460-81-10, 50-563-81-10, NUDOCS 8201110688 | |
| Download: ML20039E984 (39) | |
Text
_
__
_ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
r
-
V. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report Nos. 50-460/81-10, 50-513/81-10 Docket Nos. 50-460, 50-513 License Nos. CPPR-134, 174 Licensee: Washington Public Power Supply System P. O. Box 968 Richland, Washington 99352 Facility Name: Washington Nuclear Projects Nos. 1 & 4 (WNP-1/4)
Inspection at: WNP-1/4 Site, Benton County, Washington Inspection conducted:
November 16-20, 1981 I2f2Ih>I Inspectors:
C P. P. Narbut, Team Leader Date Signed fYh/
l2l2ll[ j R. T. Dodds, Chief, Reactor Project Sec. 2 Date Signed Reactor Construction Projects Branch M/
Yh
/1[2/
/
A. D. Toth, Residerit Reactor Inspector Date' Signed W
/?fhf9f D. Haist, Reactor Inspector Datd S/gned l k)c t
[pn
/2/2l[6l G. Hernandez, Reactor Inspector Date Signed ff)crlI f
t.,
(E ll I fu l A. D'Angelo, Reactor Inspector Date Signed
/ 2/2 </f/
W
'N Approved by v
R. T. Dodds, Chief, Reactor Project Sec. 2 Date Signed Reactor Construction Projects Branch Summary:
Inspection during the period of November 16-20; 1981 Areas inspected: Special construction assessment team inspecticn of quality assurance, design controls, procurement controls, construction controls, and project management of construction at the WNP-1/4 site. The inspection involved 228 inspection hours on-site by six NRC inspector a.
Results:
Of the five major areas inspected, no items of noncompliance were identified.
8201110688 811222 PDR ADOCK 05000460 PDR G
._
-
.
.
.
r.
,
REPORT INDEX
Subjec_t Page t
1.
Persons Contacted I
2.
Background
,,
3.
Management Summary and Conclusions
4.
Project Management
',
,
a.
Organization.
b.
Management-Information
c.
Staffing.
5 d.
QA Staff Involvement
'
e.
Engineering Overview f.
Reportability to NRC
g.
Positive Management Actions
7 h.
Effectiveness
1.
Summary
5.
Quality Assurance
a.
Program
b.
Adequacy
c.
Implementation
d.
Summary
6.
On Site Design
a.
Design Verification
b.
Concrete Anchor Bolt Installation
c.
Drawing Control
7.
Procurement Controls
a.
Program Implementation
b.
Owner Procured Components
c.
Contractor Procurement
8.
Construction Controls - AWSH
a.
Scope
b.
Status
,
i c.
Manpower Resources
!
d.
Personnel Qualifications
!.
e.
Employee Morale / Personnel Interviews
!
f.
Audits Surveillances
g.
Document Control
h.
Material Handling and Storage
'
!
1.
Reinforcing Steel' Bending
[
J.
Concrete Placement
k.
Interfaces
l
,.-
-
_
. - -, - -,, _ _.. _
, _ -, - -. - - _ - - _ _,, - -,, - -
...
.
t.
,
REPORT INDEX Subject Page 9.
Construction Controls - J. A. Jones
a..
Management Involvement
b.
QA/QV Facilities
c.
QA/QV Manpower
I d.
QA/QV Qualifications
e.
Craft Qualifications
f.
Enployee Morale
g.
Document Control
h.
Audits and Surveillance
1.
Hold Point System
i j.
Stop Work System
k.
Nonconformance Control
1.
Construction Controls
m.
Quality Records
.
n.
Material Conditional Releases
10. Unresolved Item -Definition 36 '
l 11.
Exit Interview
_
e
'
!
,
i k
.
!
!
,
.,.
- - -,. -
.,
-
,.,.. -. - - -.,
.-
,
.,-
...
-
--
.. - -. -
.
_.
-
-
.
-
-
__
=
.
.
i i
,
DETAILS 1.
Persons Contacted
,
,
a.
Washington Public Power Supply System (WPPSS)
- D. W. Mazur, Program Director, WNP-1/4
- C. R. Edwards, Project QA Manager
- R. W. Root Jr., Assistant Program Director, Construction
- M. E. Rodin, Senior QA Engineer
- M. H. Deter, Senior QA Engineer
- J. M. Steidle, Senior QA Engineer
- M. J. Farrell, QA Engineer
- R. C. DeBattista, QA' Engineer
- R. E. Brown Jr., QA Engineer J. A. O'Donnell, Business Manager N. J. Irwin, Senior QA Engineer C. B. Organ, Assistant Program Director, Engineering T. E. Douay, Senior Engineer Mechanical R. H. Rockwood, Senior Construction Engineer Construction D. G. Parthee, Safety Supervisor A. Hosler, Project Licensing Manager b.
Bechtel Power Corporation (Bechtel)
- E. W. Edwards, Project Manager
- G. A. Hierzer, Field Construction Manager
- L. C. McKillip, Manager of Projects
- D. R. Johnson, Manager of Quality
- T. F. Fallon, Project Construction QC Engineer L. Bradley, Material Specialist B. Raymond, Lead Receiving Quality _ Control Engineer
' *J. B. Gatewood, Project QA Engineer c.
United Engineers and Constructors (UE&C)
- V. Mani, Project Mariager-
- H. G. Kreider, V.P., Power Engineering
- R. H. Leonard, Assistant Deoartment Manager, Project Quality
-
- E. C. Haren, Project QA Manager I
- G. L. Faust, Field Superinter. dent-Quality Assurance
'
.it H..Eryans~, Construction Support Manager
.. J. Taylor, ASME Div. 2 Construction Manager W
.
l G. M. Ahearn, Resident Construction Manager and various other engineering personnel
-
m
.-,-
w-..
--,-,,------*-i--
,,. -
w-
.
.ym-
-
,
_y.
- - - -,- --
m-
,a~
, _ _,,,.
r
- -. >-,..,
-,m
-.-
r
- +-
_
.
I
,
-2 d.
J. A. Jones Inc. (JAJ)
- D. H. Schweikert, Regional Manager
- H. E. Rice, Corporate QA Manager
- P. R. Cortez, Project Manager
- W. S. Roe Jr., Project QA Manager K. Dempsey, Construction Manager and various other inspection, craft, and engineering personnel, e.
G. F. Atkinson, Wright, Schuchart/ Harbor (AWSH)
- R. W. Wunderlich, V.P., G. F. Atkinson
- A. Y. Dernatter, Contract Manager
- M. D. Latch, Project QA Manager T. Canning, Assistant Project QA Manager M. Williams, Lead Concrete Inspector and various inspection and crafts personnel.
f.
H. P. Foley/Wismer and Becker (FWB)
P. Swanson, Manager, Purchasing T. Weinburg, QC Receiving Inspector M. Rochellet, Document Control Supervisor g.
Bonneville Power Administration (BPA),
-
- C. R. Bryant
,
h.
State of__ Washington l
- G. Hansen, Energy Facility Siting Council 2.
Background
,
!
On May 14, 1981, the Washington Public Power Supply System submitted PSAR deviation request number 17.1-6 (WP).
The deviation request recognized the revised corporate structure and the revised Supply System Project Quality Assurance organization. The deviation request was required to reflect the revised Supply System responsibilities wherein the Bechtel Power Corporation had assumed construction management and quality assurance j
services for the majority of the WNP-1/4 site and the Supply System
-
i had assumed an overview role.
In addition, UE&C had been contracted to provide construction management and quality assurance for ASME Div. 2 related activities as well as overall Architect-Engineering for WP-1/4 and vendor surveillance for prepurchased equipment.
l i
.-
-.
- - -
... -
---
-
-
-.
- - - - - - -..
,
-. - -
_
.
.
I
.
_3 This inspection by NRC was a special announced team inspection which addressed the new organizational relationships and the revised Quality Assurance Program. The inspection included five major areas:
a.
Project Management b.
Quality Assurance c.
Design Control d.
Procurement Control e.
Construction Control The nature of the inspection was atypical of the normal NRC inspection in that the focus of inspection included interfacing with licensee management and concentration on licensee program effectiveness and, in that light, did not concentrate in areas that would normally identify specific items of noncompliance in specific functional areas.
3.
Management Summary Conclusions The inspection team found that the licensee's management system showed significant strengths in the licensee's ability to organize and resolve problems. However, recent inspections indicated a weakness in the licensee's ability to identify quality problems.
Improvement in this area still appears to be warranted.
(Paragraphs 4.b and 9.g)
,
The team found that the Supply System's Quality Assurance Program was not fully defined or implemented. -(Paragraph 5)
The team was not able to determine if a problem existed with design verification since much of this work is performed off site.
However, a sufficient number of questions were raised to warrant followup.
(Paragraph 6.a)
The team look at procurement controls was not conclusive but identified potential weaknesses which warrant future inspection.
(Paragraph 7.c)
The team examination of current construction controls (AWSH and JAJ)
had generally favorable results. A potentially large problem with previously completed work documentation packages was identified.
(Paragraph 9 9)
The team's overall assessment was that the licensee's revised organizational structure has resulted in significantly greater effectiveness in resolving identified problems and, in general, there was a positive movement toward management systems which will provide early identification of problems, it was the opinion of the team and the licensee management interviewed that additional effort was still necessary.
It was
,
noted that the licensee management was actively working toward these
'
improved goal i
'
,
.
,
e
-4-4.
Project Management The inspector examined the area of project management through a series of interviews with management personnel, some staff personnel and a review of some management reports. The areas covered included program organization, structure, communications, planning and involvement.
The inspector interviewed the Wi4P-1/4 Program Director, the Assistant Program Directors for~. Engineering and Construction, the Project Quality Assurance Manager, one Senior Construction Engineer and one Senior Mechanical' Engineer and the WNP-1/4 Bechtel Project Manager.
,
,
a.
Organization The discussions indicated that the organizational structure, including lines of authority, communications, and spans of control, was satisfactory.
In the area of interface controls, certain problems regarding material responsibilities ha' arisen but were handled expeditiously by the licensee's forces. The interface problems encountered, the actions taken and responsibilities assigned were documented on a memorandum to the Program Director dated November 4, 1981.
b.
Management Information Management reports were reviewed and, in general, provided a comprehensive view of the project status including quality problems. The reports included quality trending and appeared to give adequate attention to quality compared to production matters.
The reports did not include an assessment of rework as it applied to quality, but personnel indicated they had initiated data gathering for rework as a step in that direction. Management meetings are regularly scheduled and the issues in the reports are discussed and explored. The inspector found the management personnel interviewed conversant with the quality problems brought to their attention through these vehicles. The only potential criticism identified is that certain problems are not brought to the attention of management. This subject, the threshold of management notification, has been addressed in a previous inspection report.
Licensee management had not completed the actions comitted during the previous inspection at the time of this inspection.
An example of a problem with
,
'
significant quality affecting potential is the problem discussed in paragraph 9.g. regarding completed work documentation in the J. A. Jones contract.
This problem had not been addressed in i
the various management reports.
However, it must be noted that
'
the problem was identified by the licensee's s reported on corrective action requests (CAR's)ystem, was formally
, and was relatively
!
i recent (October 1981).
l l
i i
-,.
-
-,,,,, -
,
- -,,
I
.
.
,
l
.
-5-
!
l l
l l
c.
Staffing
.
In the examination of staffing the inspectors became aware of
'
two potential staffing problems.
The Supply System personnel identified a potential staffing problem in engineering due to the assumption of the duties of an ASME owner stamp holder, l
l Secondly, as discussed in paragraph 5.c. of this report, the QA staff has not fully implemented their program; in part due to the amount of manpower devoted to procedural changes required
'
by reorganization. The immediate future also will require extra l
QA staff manpower for activities associated with obtaining the owner's ASME stamp.
l l
These potential staffing problems were discussed with licensee management at the exit interview.
d.
QA Staff Involvement
.
l l
Through the discuss' ions with the licensee managenent and staff, l
the inspector developed the opinion that the licensee's QA staff
'
did not appear to be sufficiently involved in the mainstream of activity. The Project Quality Assurance Manager appeared thoroughly involved and stated that pertinent information was passed on to
,
l his staff.
The inspector observed, however, that although regular meetings were held between Supply System construction management and Bechtel QC the Supply System QA staff does not attend these meetings.
.
Additionally,-a Supply System senior construction engineer interviewed l
did not know the identity of his QA counterpart.
It was also
!
noted, in previous inspections, that the QA staff was not aware of i
acute contractor inspection personnel unrest which resulted in allegations to the NRC and significant findings.
This apparent l
minimal QA staff involvement is considered a weakness in the implementation l
of the QA program.
This subject is discussed further in paragraph
!
5.c. of this report.
c.
Engineering Overview The inspector examined the methods by which Supply System Engineering
.
performed an engineering overview of the technical adequacy exercised l
at the contractor level by contractor engineering and by UE&C (
resolution of contractor nonconformance reports (CNCR's). The l
inspector recognized that the licensee's program does not require
!
a direct overview by 11;,see engineering personnel nor is such an overview specifical.y required by NRC regulations. The licensee i
depends on the architect engineer to perform the engineering overview l
of contractors. The licensee's program provides for engineering audits if and when they are determined to be necessary, but not on a regular basis.
The program provides for Supply System engineering review down to the level of contract specifications and all changes i
!
-
_
_
__.
,
.. _,
__ ____.._.. __ _
.
_ _ _ _
-
- -
-
_
_ _. _
_ - -.
.
.
.
.
$
-6-to the specifications. The exception to this is that the category of quick fix project change proposals are only sampled by engineering, not 100% reviewed. The inspector interviewed a senior mechanical engineer and determined that, for his responsible contracts, the engineer receives all implementing procedures and changes, reviews those of interest, is involved in weekly progress meetings with Bechtel, and visits the worksites on a regular basis..The licensee's program does not formally require Supply System engineering sampling of CNCR's and evaluations of contractor engineering but does achieve those ends somewhat by the informal methods described above.
The inspector had only one example of engineering implementation weakness from a previous inspection in the HVAC area dealing with a skewed fillet weld size specified by contractor engineering.
In the absence of other examples, the licensee method of engineering overview is noted here for information only. This item was discussed with licensee management at the exit interview.
t l
f.
Involvement in Reportability to NRC l
in an interview with a Supply System Senior Construction Engineer, l
I the engineer indicated a lack of knowledge on reportability requirements
for the notification of the NRC.
Followup by the inspector established l
that the engineer had received documented training in the area j
of reportability but had apparently not retained this knowledge.
'
This item was identified to licensee management at the exit interview.
The licensee management indicated that they would investigate and take action as appropriate.
!
g.
Positive Management Actions Through discussions with licensee management personnel the inspector was made awa e of certain rather unique management actions taken.
,
-
The WNP-1/4 site arranged for an engineering audit by independent home office UE&C' personnel to audit engineering methods and organizational adequacy.
-
The " Hotline" program was put in place. The Hotline program provides a vehicle by which contractor personnel can contact licensee management, anonytrously if desired, to report quality concerns.
l J. A. Jones initiated a " Quality Circles" program which provides
-
a forum for crafts and inspection personnel to present ideas on quality and productivity.
l
!
!
i
. -
___
_
_
..
...
....
_ _. _
___
__ -- - - _ _, _..
,.
.
,
,
,
-7-
,
s
-
The Supply System initiated a Team Building program for management which provides a less formal forum for the resolution of perceived differences in goals.
-
The Supply System is initiating a sampling examination, including disassembly of previously accepted hardware which has been
.
in storage for a considerable length of time.
,
The above actions demonstrated a management system which is taking positive actions to prevent problems as well as reacting to problems, h.
Effectiveness The inspector looked at the procedural structure for the organization's ability to react to significant problems.
It was determined there was an adequate vehicle in place and functioning in the management corrective action request (MCAR) system. The system is described
by procedure and requires involvement by management.
The inspector
,
examined some examples of recent MCAR's and found the procedure was properly exercised. Aside from the procedural controls, the inspector found the management system able and capable to deal
,
i with problems aggressively and decisively as evidenced by recent actions in the areas of clearing inspection backlogs, clearing open nonconformance reports, and actions in response to allegations.
,
l The inspector discussed the apparent need to couple an adequate l
direct feedback mechanism with the aggressive actions to ensure intent of the actions are carried through to the working level.
An example from a previous allegation inspection was discussed where well intentioned actions were not accurately implemented.
,
The action to reduce unnecessary contractor nonconformance reports (NCR's) was perceived at the working _ level of one contractor
,
i as an order to not write CNCR's. The licensee's actions for this previously ' identified item had not been finalized at the time i
of inspection but certain actions had been taken.
Specifically, l
the " Hotline" program had been implemented anc licensee QA personnel contact with the involved contractor had been increased.
i.
Summary To summarize, the inspector found the management's ability to take actions to be significantly strengthened by the organizational changes made. The licensee's ability to detect developing problems was not established by this inspection but recent inspections had indicated some problems in this area. However, the licensee's actions in this area were not complete at the time of this inspection.
s
-.
. -.
.
,
,
-8-5.
Quality Assurance - WPPSS a.
Quality Assurance Program
,
The Supply System Quality Assurance Program was reviewed to ascertain whether the program is consistent with the status of the nuclear project and regulatory requirements. The documents which define l
and establish the WNP-2 Quality Assurance Program include: the
!
PSAR (as modified by Deviation No. 17.1-6, approved May 27,1981);
the Interim Quality Assurance Requirements Manual, Rev.1; WNP-1/4 Project Site Procedures; and WNP-1/4 Departmental Instructions.
These individual documents are discussed separately below:
(1)
Interim Quality Assurance Requirements,, Rev. 1 The Quality Assurance Requirements Manual is an umbrella document which specifies the quality assurance requirements for the design and construction of Supply System nuclear power plants. This document was the most recently revised (October 15,1981) of documents defining the quality assurance program at WNP-1/4 and was issued as an " Interim" manual.
A statement by Corporate Quality Assurance which accompanied the manual noted that the manual contained some organizational l
discontinuities at the managerial level due to recent organizational
realignment.
I The inspector found that the quality assurance requirements l
manual adequately describes the overall quality program to
!
be implemented on Supply System projects. The program recognizes the major interfaces which are defined in more detail in project site procedures, and recognizes general regulatory commitments which are also defined more specifically in project documents and the safety analysis report.
Responsibilities and authority are clearly defined; however, a corporate organization chart has not been included and will not be provided until Revision 2 of the manual, which is not expected for 90 days.
The inspector examined the quality assurance requirements manual against the commitments in PSAR Deviation No. 17.1-6 and found inconsistencies between the documents in many of the corporate level positions and responsibilities. Some examples of corporate level positions which are not reflected in the quality assurance requirements manual are: Director
~
of Nuclear Safety, Director of Administration, Director of Contracts and Material Management, and Manager, Vendor Surveillance and Audits. Many of the responsibilities assigned to these positions in the PSAR have been assigned to other managers in the quality assurance requirements manual, however, some do not appear to have been retained, for example:
.
__
.
-
. _ _ _. _ _ _
.-
..
.
.
.
,
i
_g.
Maintaining a working knowledge of all pertinent regulations
.
(Director - Nuclear Safety)
J Assuring review of regulatory guides for applicability
.
,
to the projects (Director - Nuclear Safety)
'
-
Providing technical direction to selected Design Subcontractors
.
(Technical Director)
,
Ensuring the transfer of design experience among projects
.
(TechnicalDirector)
,
Assuring that code requirements are properly interpreted
.
i and included in the QA program requirements (Manager -
QA Engineering and Systems)
,
!
Additionally a sample indicates that project responsibilities specified in the PSAR for engineering, program management
,
and licensing have not consistently been transferred to the quality assurance requiranents manual.
(2) Quality Assurance Instructions Quality Assurance Instructions are developed to implement
'
the requirements of the PSAR and quality assurance requirements manual within the quality assurance department.
In some
,
instances corporate quality assurance instructions are adopted
'
i by the project if adequate to fulfill spec _ific project requirements.
In other instances, quality assurance instructions are prepared
by the WNP-1/4 project and receive; review and approval by the corporate quality assurance department.
The inspector examined a sample of quality. assurance instructions i
for consistency with the PSAR and quality assurance requirements manual.
The following inconsistencies or omissions were
identified:
The specific requirements of QAR 10 Rev. 1 Paragraph
.
3.3.2 for review of procurement documents for inclusion
'
of inspection plan requirements has not been implemented i
in QAI-1/4-4-1, " Procurement Document Review".
'
The specific requirements for Type I and Type II surveillances
.
in QAR-10, Rev.1, paragraph 3.6.1 have not been implemented in QAI-1/4-10-2, " Site Surveillance of Design / Construction".
i
I
,
k
.-
-
.-
,
~.
- -, - -
d
~
t
-
.
,
-10-The specific requirements of QAR-18, Rev. 1, paragraph
.
3.1.2 for annual audits of the architect-engineer and contractors have not been implemented in QAI-1/4-18-1
" Project Quality Assurance Audits" which allows audits on a selective basis depending on the complexity of work activities being performed and work performance history.
The specific requirement of QAR-18. Rev. 1, paragraph
.
3.1.6 that findings of previous audits shall be reviewed by audit personnel prior to performing an audit has not been implemented in QAI-1/4-18-1, Rev. 1, " Project Quality Assurance Audits".
References are still made in the quality assurance instructions
.
to positions no longer recognized in the' quality assurance requirements manual, for example, QAI-18-2 " Qualification
,
and Certification of Quality Assurance Audit Team Leaders" l
assigns responsibilities to the Manager, Vendor Surveillance and Audits, a title which no longer exists.
QAR-18, Rev. 1, paragraph 3.1.5 specifies that audits
.
are to be conducted by. trained personnel ~and that the use of adequately trained technical specialists or consultants as audit team members is acceptable. QAI-18-2 Rev. O
" Qualification and Certification of Quality Assurance Audit Team Leaders", specifies the training requirements for audit team leaders only and does not address training and qualifications of audit team members or technical specialists. Similarly, QAI-18-1, Rev. 0 " Quality Assurance Audits" specifies responsibilities for audit team members but does not specify training or capability requirements.
The above inconsistencies and omissions are not all considered substantive but are considered an indication that the quality assurance program has not yet been refined and that other
<
omissions and inconsistencies may exist which could adversely affect implementation of the Supply System's quality assurance overview responsibilities. The licensee is aware that inconsistencies exist (including)the specific omission of Type I and Type
'
II surveillances and attributes them to parallel development of the various quality documents and the further need to conform the quality assurance instructions to the ASME Quality Assurance Manual recently developed.
'
The corporate quality assurance organization has conducted a consistency review of the project site procedures which appeared to be quite thorough; therefore, these documents j
were not exaained for consistency by the inspector.
l i
--~
,
..
_
- _ _. -
.
.
.
_ -.
.
'
m,
.
o
.
-11-i
!
!
It appears from the inspector's review that'further efforts to ensure consistency between the various quality documents
and a PSAR Deviation to_ reflect the current organization is warranted.
Further revision to these documents may also be required when the Quality Assurance Requirements Manual
is again revised.
,
l (3) Organization and Position Descriptions The inspector examined the structure of the site quality assurance
organization and found definition of the structure, lines
'
of authority, independence, and access to upper management to be adequate. The responsibilit.ies of the project quality
I assurance manager are defined consistently throughout the
~
various quality documents'. Position descriptions have been
prepared for project quality assurance personnel which include
'
the nature <and scope of the position.and principal accountabilities.
,
A collateral assignment of major significance has been the preparation and review of the ASME Quality Assurance Manual.
It became apparent through interviews with project personnel that considerable effort has been applied to this project
,
and it appears to have had a detrimental impact on the performance
!-
of routine quality functions as described in paragraph 5.c.
No other collateral assignments were apparent.
i (4) _P_rocedures/ Directives i
Generally, it appears that there are adequate procedures
'
and directives to implement the quality assurance program.
No significant lack of written procedural guidance was identified
,
for quality assurance activities other than indoctrination
and training as described in paragraph 5.c.4.
>
r b.
Program Adequacy
During examination of the various quality assurance program documents, the inspector included a review for inclusion of regulatory requirements
'
and commitments. Overall regulatory requirements are specified in the Quality Assurance Requirements manual with project-specific regulatory requirements and commitments being specified in quality
,
!
assurance instructions. No deviations from applicable regulatory requirements or commitments were identified.
c.
Implementation (1) _ Planning and Staffing
,
J J
,--,-
e -
n,,
,-g,,
u
-,,-y, e
, + - -,,-g.,
- ~,.
r--
,, - -
wv
--,.- --,
- m
,
.
-
..
-
.
-
.
-12-The inspector examined planning and staffing levels against the activity to be performed. The project staffing
'
levels appear to be adequate to accomplish scheduled and unscheduled activities in the absence of significant collateral
.
j assignments such as preparation and review of the ASME quality assurance manual and preparation for the ASME Audit.
Provisions are made for overtime and temporary personnel if determined to be necessary. There has been no turnover of quality assurance personnel in the past 6 months.
Planning aids include a five-week activity schedule, a five-week floating calendar of events and weekly staff meetings. The Project Quality
,
Assurance Manager participates in the project review meeting i
and program review meetings and receives copies of the monthly progress reports issued by_the construction manager and Bechtel.
The surveillance supervisor has access to construction schedules for use in planning surveillances. Complex or significant construction activities are discussed during the project review meetings which are attended by the Project Quality Assurance Manager.
(2) Audit Activities t
The inspector examined the licensee's audit schedule for the third and fourth quarters of 1981. Current audit activities will be confined to followup on previous Bechtel and UE&C audits which were conducted following the transition activities.
This schedule appears appropriate and in accordance with quality program requirements.
A management audit'is scheduled for i
the fourth quarter of 1981.
(3) Surveillance Activities
The inspector examined survei_llance' activities conducted since March, 1981 to determin'e the scope and depth of surveillances.
l Licensee personnel stated that Supply System surveillances
_
are designed to be patterned after NRC inspections i.e.,
'
narrow in scope and of sufficient depth to assure that the construction management. surveillance and audi.t programs are i
effectively monitoring adherence by contractors to their quality programs.
t Surveillances conducted to date have focused on NRC identified
,
iter. or verification of corrective action required as a result of NRC findings, receipt and storage of equipment, drawing control, and Bechtel and UE&C procedures. There is a noticeable lack of surveillance of critical work activities such as concrete placements, welding, post weld heat treatment, nondestructive examination, and equipment installatior.. Licensee representatives-l attribute this to the drain on resources occasioned by the transition activities (from integrated to non-integrated
'
i
. _
.
.
-
_
.
_
_,
- -
.
.
u l
.
.
'
o-13-
organization and assignment of~new construction manager)
!
and preperation for an N-certificate. The licensee feels ~
.
'
that the surveillance program will be stabilized and reflect the aforementioned philosophy by January, 1982.
The inspector found that surveillance finding followup is
.
not being conducted in accordance with QAI-1/4-10-2, Rev.1,
" Site Surveillance of Design / Construction".
Paragraph 3.2.8
,
requires the quality assurance engineer to verify that corrective action by the construction manager has been inplemented within 10 days of the requested date as stated on the surveillance report.
In practice, the quality assurance engineer does not verify corrective action for 100% of the surveillance findings. Surveillance findings may be turned over to Bechtel
who may then include the finding on a listing of deficiencies or initiate another document, such as a nonconformance report to track the item. This practice does not appear to be consistent with QAR-10, Rev. 1, paragraph 3.6.2 which requires the surveillance report to remain open until the item is verified as corrected or until an appropriate self-closing document (e.g., NCR, QFR or equivalent document) is issued.
QAl-1/4-10-2 requires issuance of a Quality Finding Report only when the Supply
,
!
System and the managing contractor cannot agree on the validity of the deficiency.
The concern with~this treatment of surveillance findings
,
is that it appears to reduce the licensee surveillance organization to an extension of the managing contractor's surveillance organization rather than a critical overview surveillance of prime importance in determining the quality of construction management and contractor's adherence to their quality programs.
The surveillance procedure provides for trending of surveillance findings and a management corrective action request has been issued to Bechtel as a result of continued surveillance findings in the area of storage of equipment.
It appears that based upon these concerns, an examination of the surveillance program by the Supply System is warranted with recognition of (1) the limited surveillance resources available to the Supply i
System (2) the overview nature of the Supply System Quality organization (3) that surveillance findings may be symptomatic of a breakdown in the affected contractor and or Construction
.
Manager's quality assurance program; (4) the need to address
'
actions to prevent recurrence; and (5) the philosophy of surveillance of a narrow scope of work to adequate depth to provide assurance that quality' programs are. functioning.
,
&
+
.S
,
n
.,m:4
-
-m
- ---, er
-
r.---*
- - - -, -
- -. - - - = - - - - - - -
-
.
_
_
.
.
.
.
-14-
(4) Personnel Indoctrination and Training The inspector examined the certification and training records for approximately half of the surveillance and audit personnel.
All were found to have received initial indoctrination and required training courses, including procedure review training.
Lead auditors were certified in accordance with ANSI N45.2.23.
Although training and indoctrination of personnel was conducted in accordance with PSAR and Quality Assurance Requirements Manual provisions, it is not clear if any project quality assurance instruction was utilized.
QAI-1/4-2-1 references QAl-2-1, Rev. O, "QA Indoctrination and Training" for project use, however, this procedure is not appropriate for project use and has not, in fact, been implemented.
It appears that
>
i action is warranted to establish a project quality assurance j
instruction regarding indoctrination and training.
(5) Management Involvement
,
The inspector examined the degree of management involvement both direct, and indirect through reports and other communicatisns.
Personnel interviewed expressed satisfaction with the extent
of management availability and involvement in quality matters.
It is apparent that the Program Director and Corporate Quality Director are receptive to the concerns of the Project Quality Assurance Manager. The primary reports received by project quality assurance management are the Bechtel and UE&C monthly progress reports which are reviewed with the Program Director in the project review meeting. Quality issues are then discussed again with the Program Director and. Senior Staff during preparation
.
of the Program Director's Monthly Progress Report which is presented in a monthly meeting to the Managing Director.
!
The inspector examined recent monthly progress reports prepared by Bechtel and UE&C.
The licensee had not formally outlined the areas of quality assurance activities.to be discussed
!
in the reports. A noticable difference in the reports is the brief nature of the Bechtel report compared with the l
comprehensive nature of the UE&C report. The Bechtel monthly i
progress report for October cor,tained a brief summary of CNCR status, trending results, document control, QC assessment, NRC item status, and quality assurance initiatives with supporting data on contractor nonconformance reports. There was no discussion of quality assurance audits and results or quality control surveillances and results.
In contrast, the UE&C monthly progress report for the same period contains sufficient information to allow the Supply System to identify weak areas
l or poor performers, and enable direction of management attention l
on surveillances and audits. Data provided in the UE&C report i
- --,,.
,
-
,
,-
--
,
-
-
- -
-
~.
.
_
..
.
-15-include: corrective action reports, audit status report, surveillance activity, nonconformance assessment, engineering disposition status, quality assurance manpower, training sessions and subjects, corrective action request status and aging, audit summary including the number of deficiencies versus the subject of the deficiency and an analysis of the severity, open audit findings by month, audit aging report, and a similar summary and backup data on surveillances, nonconformance reports, and vendor surveillances. The Supply System Project Quality Assurance Managar performs the screening of these various reports and directs action, as appropriate, to his lead quality assurance engineers for surveillance and audit.
The Program Director's Monthly Progress reports are prepared and distributed to all key people on the project, in the corporate offices, and at other Supply System projects.
The corporate Quality Director _ is included on this distribution.
Quality assurance activities are presented in summary form with quality concerns highlighted. The corporate Quality Director also receives reports of-Supply System audits of managing contractors.
The corporate Quality Director requested, on September 11, 1981, that each Project Quality' Assurance
.
Manager supply monthly data so'that corporate quality assurance may fulfill its responsibility to develop trend. analysis of project and contractor performance and apprise the Managing Director of the performance of the Supply System quality programs. Data requested by the Quality Director included major discrepancies or critical events; the number.of surveillances performed by project quality assurance and the construction manager and the breakdown of those surveillances; the number of NCR's, QFR's, MCAR's, CAR's and SW0's by contractor-opened and closed; aging data on NCR's, QFR's etc.; number of ao - ved i
engineering changes sent to contractors; and quality assu once staffing strengths broken down for the supply system, construction manager, and contractors. This list is not all inclusive but indicates that the corporate quality assurance organization is cognizant of the variables which reflect on the performance of the quality program and which are necessary to evaluate the
overall effectiveness. Analysis of this data by corporate quality assurance and prompt management attention to adverse trends should prevent repetition of the difficulties experienced in the past.
The Project Quality Assurance Manager has not yet begun to supply this data to corporate quality assurance and has expressed apprehension about the availability of this data.
It appears that this data is necessary for the corporate quality assurance organization to fulfill its responsibilities as defined in the Quality Assurance Requirements Manual and that prompt
'
attention is warranted to comply with this request for monthly data.
_
-
'
.
r
.
a-16-
!
,
d.
_ Summary Actions taken by the licensee in early 1981 to abolish the integrated organization on all Supply System projects and to engage Bechtel Power Corporation as Construction Manager on the WNP-1/4 are considered to be beneficial changes as are the organizational changes and creation of the program concept. A detrimental side effect of these changes has been the need for significant revision of the documents which define the quality program during the construction period.
As discussed herein, it is not apparent that these various documents are as yet consistent with each other and with PSAR conrni tments. The potential exists for further disruptive changes when the quality assurance requirements manual is again revised.
Implementation of the Supply System quality assurance program at the project level particularly in the area of surveillance has been adversely affected by the collateral tasks of ASME QA manual preparation and preparation for the ASME Survey, Project
quality assurance data is not yet.being' supplied to the Corporate Quality Director to enable him to fulfill his responsibilities
<
for overall evaluation of Supply System quality programs. The status of the quality program definition and implementation when
.
compared to the magnitude of construction activity onsite is considered
!
an area of significant weakness (Followup Item 50-460/81-10/01).
6.
Review of On Site Design Activities a.
Design Verification
'
The related sections of the WNP-1/4 PSAR and applicable United Engineers and Constructors (UE&C), Foley Wismer and Becker (FWB)
and University Nuclear Services Inc. (UNSI) contracts and implementing procedures were examined to determine the conmitments that were addressed to the areas of management of the design process, design verification and design change control.
Af ter examining design activities presently being performed on site, it was determined that all design activities (except for limited design drawing changes) and design verification activities were being performed in UE&C home office.
UE&C is in the process
.
of transferring some design activities to the WNP-1/4 site. This transfer will take place in mid 1982. The design activities being transferred to the site will include large bore pipe stress analysis
,
and pipe support analysis.
The WNP-1/4 PSAR, paragraph 17.1.3, states that, "In all cases, prior to submittal to either the Supply System nr UE&C fcr review
,
and/or approval, the design contractors, including UE&C, are responsible
,
for verifying that the design meets the requirements of the specification,
_
_
.
.
,
,
-17-
,
is commensurate with good design practices and that the components can be readily inspected. This verification is achieved by the performance of design reviews, the use of alternate or simplified calculation methods, or by the performance of a suitable testing program.
The verification or checking process is performed by individuals or groups other than those who performed the original design."
The WNP-1/4 PSAR, chapter 3.12, specifies that WNP-1/4 complies with the guidance set forth in Regulatory Guide 1.64 entitled
" Quality Assurance Requirements for the Design of Nuclear Power
Plants".
Regulatory Guide 1.64 endorses ANSI N45.2.11 which states,
"The results of design verification efforts shall be clearly documented,
,
with the identification of the verifier clearly indicated thereon"...
" Documentation of results shall be auditable against the verification methods l identified by the responsible design organization"..."Where changes to:previously verified designs have been made, design verification shall be required for the changes, including evaluation
-
of the effects of those changes to the overall design"..."The responsible design organization shall identify and document the particular design verification methods to be used", and where the design review method is used, " Established procedures for design review shall be followed, the results of the review documented,
and measures taken to ensure that the findings are implemented."
The ANSI N45.2.11 standard also specifies that, where the design review method is selected, a number of basic questions should be addressed where applicable.
The inspector could not locate any evidence that a comprehensive design verification program, defined and prescribed by a procedure incorporating the requirements of ANSI N45.2.11 is in place at WNP-1/4.
However, the major design effort, as stated above, was accomplished at UE&C home office.
Since the design activities taking place at UE&C home office were outside the scope of this
,
inspection of on site design activities, this item will Le inspected further during a future inspection (Followup item 50-460/81-10/02)
b.
Concrete Anchor Bolt Installation During a review of pipe support calculations, the inspector observed that a pipe support concrete anchor bolt hole had been drilled i
oversize. A note had been made, on the calculation, for the oversized hole to be grouted and then redrilled to the correct size and Hilti bolts were to be installed in contact with the grout.
-
The. inspector interviewed several UE&C engineering personnel including the manager of Construction Support and the assistant manager of Construction Support. The inspector was told that the Hilti anchor bolt installation -in grout was not a common practice but
,
_ _ _ _.
--
.. - -
.
,,,
,
-18-such installation had occurred in the past and engineering approval is given for such an installation.
,
The licensee had performed qualification testing for Hilti anchor
"
bolt installation in concrete, however, no qualification testing or calculation was located by the inspector to verify the adequacy i
of a Hilti bolt installed in grout.
At the exit interview licensee management committed to examine this area and determine if Hilti's have been installed in grout and if such installations have occurred, the adequacy of such installations would be determined. The licensee also stated that a hold will be placed on all such installations. This item is considered unresolved.
(Unresolved Item 50-460/81-10/03)
c.
Drawing Control During the inspection the inspector observed drawings on a stick-file located on a J. A. Jones area engineer's desk in the diesel generator area of the General Services Building. There was no status indicated on some of the drawings as required by J. A.
Jones document control procedure no. P0P-N-300W.
Bechtel had recently performed a surveillance of document control in the diesel-generator area and had started to perform corrective action. The licensee stated that similar problems with document control have been identified and increased surveillance would be continued.
This item was ident'ified to licensee management at.the exit interview and will be examined in the normal course of future inspections.
7.
Procurement Con _trols
'
a.
Program Implementation The inspector examined the procurement controls exercised by the Supply System in awarding the contracts for major equipment supports
,
i (contract no. 9779-134)land the main electrical construction contract (contract no. 9779-218).
The contrac'. specifications for these
,
contracts were prepared by the Engineer (UE&C)~for the Supply Systems review, approval and eventual issuance for bid after resolution of all coninents by the Engineer.
No deviations from the licensae's and the Engineer's approved programs were identified,
,
b.
Owner Procured Components The specift;ations, receipt inspection and storage relating to the owner's procurement of the core flood tank and steam generator i
l supports (item 11, drawing 101327 and BEC Piece No. 275-N0028-5 l
l
,
-.-
.
.
,
'
j
. * *
.
.
i-19-
respectively) were specifically examined. The procurement, vendor surveys, receipt inspection and storage of materials for these items were handled by the Engineer. The CM0 (Construction Management Organization - Bechtel) now has responsibility for the receipt and storage of materials and components.
It was determined that the procurement document identified the applicable codes and standards. The requirements of 10 CFR 21 had not been imposed on this contractor since the contract was let in 1975. The procurement documents did identify appropriate quality assurance requirements and did require a certificate of conformance along with the appropriate data packages.
Examination of the receiving inspection records and documentation for these supports showed that'the following information had been furnished:
Certificate of Conformance
.
Final Data Package Checklist
.
As Constructed Certification
.
.
Contract Waiver Requests /Nonconformances
.
Bill of Materials / Cross Reference to Fabrication Records
.
Welding Summary
.
Fabrication Documentation (included material and weld test
.
reports, certified material test reports, heat treat / stress
'
relief reports and nondestructive examination reports)
On Site Storage Requirements
.
Storage of the steam generator supports was examined and found to be in accordance with the manufacturer's recommendations.
The core flood tank supports had already been released to construction.
The Engineer has audited the supplier on three different occasions since the contract was awarded. Results of these audits were not being maintained on site and, therefore, were not readily available for review by the inspector. Vendor audits are submitted
'
to the project quality assurance organization for information, but are discarded after review according to the Quality Assurance
' tanager.
No items of noncompliance or deviations were identified.
.c.
Contractor Procurement Contractor procurement problems were identified by JAJ in corrective action request CAR-20 as discussed in paragraph 9.g. of this report.
The inspector examined controls for the procurement of materials by the electrical contractor (Fo. ley-Wismer and Becker (FWB)).
FWB only purchases connectors and consumable materials as Quality Class I items. Cable trays and supports are procurred as Quality i
,
,
, <.,.-
__
_
,_r
-.-,
. _ -
-
--.
.
,.
.. *
.
-20-
Class II items. Cables'and components such as switch gear and junction boxes are procured under pre-purchased contracts by the Supply System. The inspection included an examination of selected portions of-Specification 9779-218, section 16; quality control instructions and procedures (QCI-2, QCP-2, QCP-4 and QCP-29);
Approved Supplier Lists; Supplier Evaluations; Supplier Audit Log; and records relating to purchase orders Nos. CA0599, CA0668 and CB0315. The inspection also included a tour of the contractor's warehouse to examine the storage of materials purchased under the aforementioned contracts.
The procurement documents did identify the codes and standards and did require a certificate of conformance. They also imposed
the requirements of 10 CFR 21 on the supplier. Recent purchase
orders were reviewed and found to agree with the Approved Supplier's
'
List. Receiving records were available for the three purchase orders identified above. Storage of materials appeared to comply with the requirements of ANSI N45.2.2.
The area of supplier evaluation and auditing appeared to warrant additional attention.
The program permits suppliers to be evalual.ed by phone or written correspondence. The supplier evaluation checklist does not indicate how this is accomplished, nor if other information was available to assist the four managers responsible for approving suppliers. The program does not provide any criteria and/or basis j
for acceptance of suppliers, i
A supplier evaluation checklist is used to identify whether the i
supplier has previous experience with the nuclear industry and i
a quality assurance program, quality control inspcction/ inspection plan, records of incoming and outgoing shipment inspections, segregated storage of controlled material, and controls in effect to assure traceability of items and records. The supplier must be found
!
'
acceptable by three department managers with final approval by the Manager of Quali.ty. Assurance. Of the three suppliers-of the purchase orders examined, only one had a positive response to i
all questions (AMP Spe'cial' Industries);-the.other two responded negatively to most of the questions except for whether controls were in effect to assure traceability of items and records.
It was not apparent to the inspector how quality is assured without records of incoming and outgoing shipments and with the lack of segregated storage for controlled material (e.g., see approval of Graybar
'
Electric Company, Inc., on March 19,1979). This. item will be examined further during a future inspection.
(50-460/81-10/04)
Examination of thu supplier audit log showed that six audits were conducted in 1979, none in 1980 and only three to date in 1981.
Most of these audits were of suppliers of Quality Class II equipment.
.
Supplier audits will be inspected further in a future inspection.
(50-460/81-10/05)
.-.
-
__.
.
.
-
-
.
._
,
_ _
-.
.
4...
-21-No deviations or items of noncompliance were identified.
!
8.
Construction Controls - Guy F. Atkinson Company and Wright /Schuchart/
Harbor (AWSH)
a.
Scope Guy F. Atkinson Company and Wright /Schuchart/ Harbor (AWSH) is the civil contractor responsible for construction of the containment shell and dome in accordance with the ASME Boiler and Pressure Vessel Code,Section III, Division 2 for the WNP-1/4 site. AWSH is the prime civil contractor whose duties and scope of work encompass i
both code and non-code activities, however this inspection focused primarily on the contractor's construction controls, the Architect /
Engineer's, and the licensee's overview functions with respect to code activities.
The contractor's technical direction is specified in Contract Specification Number 253 which provides the technical requirements
for both code and non-code work with the n,ajor portion of the code technical direction given in Division 3, Sections 38, 3C and 3D of the specification.
b.
Status For the week ending November 14, 1981 the contractor estimates that all code work is approximately 90% complete, with all non-code work to be approximately 97% complete.
It is estimated that all work (both code _and non-code) wil1 be completed by June 1982 for Unit No. 1.
The bulk of the remaining code work consists primarily of concrete construction. work for the Unit 1 dome.
With the shutdown and mothballing of Unit 4 all contractor activities have ceased on that unit.
c.
Manpower Resources The contractor's manpower requirements peaked early due in part
~
to the slowdown and then mothballing of Unit 4.
At the peak which occurred in July 1981 a total of 164 persons were employed by the QA/QC organization with the total number of persons employed by the QA/QC organization steadily decreasing since that time.
The present level of QA/QC persons is 68 which translates to a QA/QC to craft ratio of 1:5.
d.
Personnel Qualification
.
The contractor's r/ stem for training and indoctrination of QA/
QC personnel was examined. The system appeared to conform to
i
~ -..,.
,,.. _, -..
..m
. - -
-
-
-
,, -.,
.. -
,
...
.
-22-the applicable requirements of ASME Section III, Division 2, ANSI ~
N45.2.6, and SNT-TC-1A. All new employees receive indoctrination sessions on quality and safety requirements before being assigned to a specific area. A positive factor in the Q?/QC organization observed by the inspector was the low employee turnover.' ate. AWSH has had only one QA Manager since the start of construction and most QA/QC personnel have been with the organization for two or more years. Also, the resultant mothballing of Unit 4 has created a decided advantage in that as the work declined, only the most qualified personnel were kept.
e.
Employee Morale / Personnel Interviews The inspector interviewed a number of persons in the QA/QC organization, including the QA Manager. All personnel projected a strong positive attitude toward quality and safety. The inspectors all felt that they were satisfactorfly controlling quality and had the support of their supervisior., the field engineers and the superintendents.
They indicated that they were properly trained and were aware of the licensec's program to resolve questions / problems which employees might feel were not being adequately answered by their own organizations, f.
Audits /Surveillances The AWSH audit and surveillance program was~ examined for compliance with the AWSH QA Manual and appl.icable procedures. Audit plans and schedules are established to audit all applicable requirements of 10 CFR 50 Appendix B on a yearly basis.
The inspector reviewed three internal audits, one management audit, and a number of surveillances. All documents reviewed were found to be comprehensive and applicable to the activity being audited.
No items of noncompliance or deviations were identified.
g.
Document Control The inspector examined the AWSH document control system to determine if documents were being issued, revised, handled, stored or discarded in accordance with the AWSH quality assurance program.
Seven drawings from various locations, within the AWSH area of control were selected and the current revision, appropriate stamp-applicable design changes compared to the master control cards or drawing copies <
All documents were found to be readily located,
,
properly marked and found to be of the most current revision.
'
No items of noncompliance or deviations were identified.
l l
.
_ _..
.
. -. -
- - -.. - _.
,
,
_ _.
.
.
...,
-23-
i h.
Handling and Storage of Materials Considering the present state of contract completion the only items the contractor has in storage is reinforcing steel, cadwelds
and cadwelding equipment, and approximately 30 bags of cement
'
(forpatchingpurposes). The contractor's storage areas were-toured by the inspector and no items of noncompliance or deviations-were identified.
,
i. Reinforcing Steel Bending
The inspector examined the controls instituted by AWSH to control
!
bending of reinforcing steel for compliance with Specification No. 253, ASME Section III, Division 2, CC-4320 and ACI-318 (Building
l Code Requirements for Reinforced Concrete).
AWSH Quality Control
Construction Procedure No. 17 details the system employed by the contractor to control this activity. The actual bending pin diameters, i
templates, and fabricated reinforcing steel were examined.
No items of noncompliance or deviations were identified.
j.
Concrete Placement
.
The inspector examined completed containment dome concrete placement
'
No. C-3003 which is the first concrete placement above the springline.
Also reviewed were the concrete record packages for this placement which included curing records, batch plant tickets, and pre-placement
,
checklists.
'
No items of noncompliance or deviations were identified, k.
Interfaces The inspector examined the licensee's and the Architect / Engineer's
(A/E) interfaces with the' AWSH organization as they pertain to the AWSH code work. Since May of 1981 Bechtel Corporation has served the WNP-1/4 site as Construction Manager replacing United Engineer and Company (UE&C), however UE&C has retained Construction Manager duties for the ASME Division 2 work and for prepurchased materials.
The inspector examined surveillances, audits, and nonconformance
.
reports generated by the two organizations.
The qualifications of the individuals who performed these activities were also examined.
1 The inspector noted that UE&C was performing all duties as required by the contract and their quality assurance program, except that UE&C was not formally auditing design drawings in the field (for the ASME Division 2 work) as required in their quality program and in NRC commitments.
Further investig + hion revealed that Bechtel
.
-
_ _ _ _ _ - -
--
. _ _. _..
w...
-24-had been auditing _all design documents in the field including the code drawings, only because Bechtel auditors could not differentiate between UE&C responsible code drawings and Bechtel responsible non-code dradings. On September 11, 1981 UE&C provided Bechtel a list of drawings identifying the code drawings (UE&C responsible drawings).
A review of licensee surveillance reports indicated that on July 15, 1981 Surveillance Rerort No. 1-9779-108 was written which stated there were a number of out of revision drawings in the field and that drawing cards were missing from the UE&C Document Control files. The report also stated that no internal UE&C program existed
,
for checking / auditing drawings internally distributed to UE&C Engineering and Construction groups. Previous licensee commitments to the NRC (response to NRC Report No. 78-02) included a coninittment to audit regularly all drawings issued to the field including the contractor's and UE&C's. On November 17, 1981 the surveillance report was returned to the licensee by UE&C indicating what corrective action had been taken and the date of full compliance.
However, Attachment No.1, item 7 to the report and conversations with licensee personnel indicate that a program for auditing of AWSH code documents was not, in fact, in place or working. At the time of this inspection, licensee personnel had not formally verified the UE&C stated actions or closed the surveillance report.
The failure of the licensee's personnel to recognize that a serious problem existed and still exists with the A/E's quality assurance program is considered an example of a perceived weakness in the implementation of the licensee's quality assurance program.
9.
Construction Controls-Mechanical Contractor-J. A. Jones Suninary:
The WNP-2 NRC resident inspector examined the management controls of the mechanical contractor at WNP-1.. The inspector. interviewed
J.A. Jones senior site management and intermediate management regarding
!
construction controls and the nature of monitoring and control of quality.
He attended a craft training session,-and: interviewed craft and quality verification personnel regarding implementation of. management policies and procedures. He examined records of routine management reporting, site and corporate audits, deficiency tracking, corrective action plans, manpower planning and qualifications, and procedures for work package control.
He toured work areas, interviewing various craft and inspection personnel, noting working conditions, supplies, and availability of governing work instructions.
i
_
.
....
-25-The inspector found senior management personnel with significant experience in nuclear plant construction, conversant with quality assurance terms and issues, and familiar with general, if not the specific, corporate quality assurance conmitments.
Implementation of recent and current corrective action plans was apparent, involving engineering and construction organizations' lead actions, with aggressive monitoring of the quality assurance organization.
Since just prior to the NRC Systemmatic Appraisal of Licensee Performance (SALP) in July 1981, J. A. Jones has supported the site quality assurance organization with intensive corporate audit and consultant activities, which have been fruitful in identifying significant quality concerns, and initiating corrective actions. Such actions have encompassed the NRC SALP concerns regarding bypassing of inspection hold-points and training of craft personnel.
(Implementation of the newly established corrective actions will be assessed during future routine inspections.)
Corrective action plans currently being implemented, and those which are still under development, address procurement quality assurance, installation control,'and records inadequacies. The corrective actions include provisions to address significant adverse quality trends relative to control of work packages.
In addition to improving work methods for future work, the plans call for review of all existing work packages (those which are not being worked) for document deficiencies by December 31, 1981. However, at.the time of this inspection, personnel
.
resource requirements and scheduling were not in place.
The responsible
'
contractor personnel interviewed were not familiar with any details of the very extensive similar' effort, which is under Bechtel/WPPSS direction'at the Bechtel managed WNP-2 site. The J. A. Jones effort has not had the benefit of the experience gained and methodology developed at the WNP-2 site..Th_is point was discussed with licensee management dt the exit interview..The potential for a large quality problem and the benefit of utilizing the WNP-2 developed methodology were also discussed.
,
With the exceptio'n of the records inadequacies and the yet untested improvements in the quality assurance program, the inspector identified no items of co_ncern in the areas examined. The specific areas examined and the related findings are detailed below.
a.
J. A. Jones Management Involvement QA/QC Organization Corporate
,
The inspector interviewed the Corporate Quality Assurance Manager, site Quality Assurance Manager, Project Manager, Construction Manager, and various intermediate level management personnel in construction and quality assurance. The objective of such interviews was to ascertain the degree of management involvement in qual'ty assurance policy implementation, and the nature of corporate office support of the site quality assurance function. The inspector examined records which supported statements.
__
_
- -
-
.
.
.
.-....
-26-The QA Manager identified the corporate policy statement in the ASME QA Manual, but the Project Manager and Construction Manager did not; however, these individuals provided their nuclear experience and indoctrination with the company as the basis for their commitment to quality assurance on the WNP-1 project.
The company has established a regional office in Seattle, at which there are both project management and quality assurance management representatives. The corporate. involvement with the project includes receipt / review of;the detailed quality assurance monthly reports, monthly quality assurance manager visits to the site, routine corporate audits, annual management quality assurance program evaluations.which in 1981' included an outside consultant (MAC),
and a specially assigned consultant engaged in continuous evaluation of aspects of the QA program for at least 7 weeks in September and October 1981. The Executive Vice President routinely visits the site, as described in the ASME QA Manual, 'and is familiar with the site Quality Assurance Manager. Correspondence between the
>
Corporate QA Manager and the Vice President clearly identifies corporate probing into reported quality issues and the commitment to attend to these. The inspector perceived no indication of
,
lack of corporate support 'for the quality aspects of the work.
.
b.
J. A. Jones QA/QV Facilities / Supplies Quality assurance and verification personnel facilities and supplies are the responsibility of J. A. Jones site management. The quality verification supervisory personnel facilities were commensurate with those of other J. A. Jones site management personnel. The QV-inspectors have been assigned to field locations. The inspector i
noted that one work desk in the containment building contained a full set of procedures and sufficient space for dispatch of the inspectors. The inspectors contacted during this inspection, and also during October 1981 evening inspections, were equipped with weld joint fillet gages, hi-lc gages, rulers, lights, mirrors
'
.
and other miscellaneous supplies. They appeared to be satisfied that they had the materials necessary to perform their inspections.
t c.
J. A. Jones QA/QV Manpower Resources The quality assurance organization's supervisory and other personnel
,
appear to have sufficient nuclear experience, and have been associated with the J. A. Jones company or another WNP-1 contractor at least
since 1979. The personnel appear to be aggressive and familiar with the problems associated with first-line inspection personnel.
The quality personnel are managed by the site. Requests for QA/QV
,
personnel are processed through the Project Manager; however,
,
!
-.. - -.-
,
-
-
.
,- -
-
_
.
...
.
-27-
personnel interviewed expressed no reservations in this regard and were satisfied with all actions to date.
Unavailability of inspection personnel from the local union hall has led the contractor to seek personnel from the Pennsylvania based firm, Nuclear Inspection Consultants (NIC). Additional national recruiting is underway to increase QV-staff.
Responsible intermediate level nanagement reports that the ratio has been about 12 inspectors for 175 two-man teams of welder / fitter (1:15) for work in the general service building.
The QV-inspector supervisor stated that a ratio of 1:12 is preferred, and recruiting is targeted in that direction.
Senior management stated that it does not monitor such ratios due to other variables, and leaves specific manpower decisions to direct supervision. The current QV inspection manpower appears to be somewhat low, but there was no indication that workloads were unmanageable at this time. The recruitment effort appeared to be consistent with a planned near-term build-up of work activity in the containment building. The QV inspection supervision apparently has sufficient communication with the area superintendents to project manpower needs in advance.
d.
J. A. Jones QA/QV Personnel Qualifications The J. A. Jones ASME QA Manual commits to ANSI-N45.2.23 and N45.2.6-
1973. The company has developed a Training Certification Manual which provides for evaluation of inspectors' initial qualification; testing in general, specific, and practical knowledge similar to SNTC-TC-1A approach; on-the-job training as needed; and certification i
by management for specific categories of capability (e.g. welding, receivinginspection,etc.).
Each QV inspector is given a card which identifies the categories for which he is qualified.
A central record is also maintained.
More than one supervisor stated that about 40-50% of the inspectors dispatched from the union hall fail to pass the examination.
Although this appears to be rigorously selective, the inspector noted that the examination allows 80% as a passing grade and does not appear to be unreasonably demanding of technical knowledge.
The inspector selected eight inspector names from the November 9, 1981 organization chart, and examined their personnel files.
,
i Two of these individuals were from the NIC agency, and two were apprentices.
The inspector examined the resumes, the certification
!
records, and the examinations taken by two of the individuals.
The examinations included questions which required the applicant to respond in his own words; this provided obvious insight into the individual's familiarity with critical terms and concepts.
No discrepancies were identified, s
s I
[
-.-
---
... _
-
-
,
_
.
_
.
....
-28-e.
J. A. Jones Craft Personnel Qualifications
,
The craft personnel are dispatched from the local union halls, which have supported the nuclear facilities of the Department of Energy at the Hanford reservation for many years. Apprentice programs leading to journeyman status provide basic craft training.
Apprentices are used at the site as assistants to journeymen.
Recent emphasis on craf t training has included assignment of a training coordinator and training assistant, with a training class
,
in a room adjacent to the J. A. Jones Area Manager's office.
Training classes are held with foremen and crafts, regarding site work procedures. Video training films are being developed.
The inspector attended a typical training session involving a video film for pioe hanger installation; it included instructions by a senior quality verification inspector and the area superintendent.
This provided a minimum amount of instruction relative to site specific procedures, and alerted the craftsmen to the existence of the procedures and their availability for review or reference in the work areas, f.
J. A. Jones Employee Morale d
During interviews of management, staff, and craftsmen, the inspector asked specific questions and solicited general comments relative i
to the working of the construction management system, iaterfaces and harmony between construction and QA/QV personnel, working conditions, supplies and facilities, personnel practices, workloads, personnel safety, use of the new WPPSS " Hotline", and any general quality affecting matters which may be of concern to the individuals.
As a general rule, the eniployee morale appeared to be good, with positive attitudes and projected confidence that problem areas
,
were being addressed. There were no indications that any quality
'
a concerns were being disregarded.
,
Some crafts commented on the dust in the containment building and accumulated debris on scaffolds falling into their eyes, sometimes interfering with performance of their work. The licensee advised that the situation should be improving with the assignment of a 40-man cleanup crew within the last 3 weeks. The, crew works inside the containment building on the third shif t.
Additionally, an October 30, 1981 report from an outside consultant (Environmental
~
Health Sciences) demonstrated the implementation of a routine monitoring program. The program not only includes dust levels, but also welding fume monitoring in general and within enclosed spaces. The report shows compliance with the state limits on respirable dust. The inspector had no further questions on this ite.
....
-29-During the above interviews and during brief questioning of other contractor personnel while on a walk-through tour of the general services building, the inspector inquired about the WPPSS " Hotline".
The employee awareness of this reporting system varied; the foremen, supervisor and quality verification personnel reflecting more awareness than the craftsmen. There appeared to be sufficient general awareness to assure that an individual would learn of this mechanism should he need a reporting route for an unresolved quality problem.
g.
J. A. Jones Document Control The contractor has established three control levels for documentation.
Control Level-I has been designated as-Issued-For-Construction and involves using pink or green paper for easy recognition of approved versus unapproved issues of procedures and design changes.
This system facilitates monitoring by the contractor, Bechtel, or WPPSS personnel. The inspector observed appropriately colored documents during tours of work stations in the' containment building in October.
Crafts and foremen interviewed stated that they had access to procedures and documents in the work areas, and were free to refer to these as necessary. Where,needed changes to such documents are identified by personnel, ' management stated that they are expected to identify such changes to their supervisors; personnel interviewed confirmed this direction.,
Document control includes the compilation,. issuance, and control
~
of work packages for construction / installation activities. The J. A. Jones quality assurance trending of discrepancies since July 1981 led to the October 9,.1981 issuance of Corrective Action Request CAR-21. This identifies work packages with missing design change documents, missing weld records, incomplete data on weld records, missing heat numbers from pipe spool records, by-passed ASME inspector hold points, missing and improperly completed nonconformance reports, work performed to void information drawings, and improperly completed records.
An October 19 action plan was issued by the J. A. Jones Construction Manager, and augmented on November 16 by the Project Manager.
It established a Special Work Package Group from Engineering and Construction to review Quality Class I work packages for proper contents prior to issue for work being performed by Construction at this time.
It required that by November 13, QA will be requested to perform a review of work packages presently being worked.
It established a November 30 completion date for these activities.
The inspector observed that a Work Package control area had been set up for the general services building work, and that daily reviews were being performed to ascertain that proper documents were available for work performance. The Construction management refers to " Clean Work Packages" in this regard. The QA engineering supervisor stated that consideration was being given to future involvement of QA personnel into this activity.
.
-.
.
.
.
.
.
.
-30-The CAR-21 reply also requires that Work Package Control personnel
.'
will review all the remaining Quality Class-I packages for document deficiencies by December 31, 1981. They also are to develop a set of recommendations for revising the work package control procedure (WI-017) and develop a related training program. A QA review of this effort is also specified for mid-December.
Similar to the work package problems discussed above, J. A. Jones CAR-20 identifies document control problems-relating to procurement.
i It describes issuance of purchase-orders to unapproved suppliers and issuance of purchase orders without adequate specification or code requirements. An October 6,1981 corrective action plan discusses a task force to review all Quality Class I purchase orders. The inspector examined the list of J. A. Jones ~ suppliers and noted that a great deal of these are the same suppliers which supplied materials to the WNP-2 mechanical contractor.
That contractor has been engaged for several months in detailed review of the purchase orders and the vendors.
The inspector interviewed the J. A. Jones QA engineering manager
,
involved in CAR-20 and CAR-21 and determined that he'had no information regarding the WNP-2 project (where a similar extensive effort has been underway for the past several months, under the direction of Bechtel and WPPSS).
No information nor personal contacts had been established to convey the WNP-2 lessons learned, regarding procedures, checklists, generic types of problems, or solutions identified for such problems.
The inspector declined to serve as the source of such information, but cannitted to refer this matter to the appropriate WPPSS management.
The inspector examined the J. A. Jones internal QA monthly report dated November 10, 1981, and identified only the briefest reference to CAR-21 (and CAR-20).
The November Bechtel reports to WPPSS also did not discuss this deficiency in current work control practices and documentation. The WPPSS QA personnel interviewed during this inspection demonstrated unfamiliarity with the problem and the corrective action plans. The J. A. Jones aggressive corrective actions appeared to be proceeding in relative isolation from the relevent data at the other WPPSS site, and without detailed cognizance and inter-project management by the owner (WFPSS).
Corrective action plans for current and past work have not yet i
been fully defined. Current work appears to be proceeding without fully developed instructions and procedures. This matter is unresolved pending further NRC inspection.
(460/81-10-06)
i
,
I
_
_
,. _,
_
_ _
.
....
-31-h.
J. A. Jones Audits and Surveillance Program The J. A. Jones ASME QA Manual prescribes an audit program to include audit schedules, plans, checklists, meetings, commitments, reporting, followup, and auditor qualification. The principle elements of the ANSI-N45.2.12 appeared to have been addressed.
Qualification of Auditors to ANSI-N45.2.23 is prescribed for the project.
The procedure P0P-N-708W prescribes-similar requirements, but clarifies that audits will be conducted.by both corporate staff and site staff.
The prescribed yearly site audit schedule was available, and showed that the prescribed elements of the QA. program were.each scheduled for audit in 1981. The quarterly audit schedule showed that the audits scheduled for the last quarter of 1981 were redundant to earlier audits this year and would be omitted:in favor of an effort to followup on previous audit findings (seven audit findings have recently been reissued for corrective action). The inspector
~
verified that the earlier audits had been performed.in 1981, as documented in the audit reports' numbered 81-02, 04, and 05. The inspector noted that the audit staff had been-recently augmented and now consisted of four lead auditors.
Corporate audits CQA-81-02 and 81-04 (June and October 1981) showed implementation of the corporate audit function.
The audit reports i
clearly documented the findings and demonstrated followup of corrective
,
'
action conmitments of prior audits. The nature of the audit findings
'
implies corporate attention to site issued reports, such as nonconformance trend analysis. The findings clearly focus on issues which have now been subject to significant corrective actions regarding work package control, final reviews of Code Data Packages, training procedures and program, purchase order reviews, and strengthening of the site audit program. The transmittals on the audit reports clearly establish response target dates and are addressed to appropriate site management, with copies to the corporate senior management.
Correspondence to the corporate QA Manager and to the Executive Vice President in July thru October 1981 shows key
,
management attention to issues being raised and encompasses those l
relating to significant audit findings.
Discussions with senior l
site project / construction management showed some awareness of l
significant quality findings and commitments.
i.
J. A. Jones Inspection Hold Point System J. A. Jones inspection hold points are established on work process control forms in the work packages at the work locations and are defined in procedures applicable to the specific work. An inspector pool concept is currently used, where the craftsman l
l l
l
.
_,
_,
.-
'
...
.
t
.
signs a list at the inspectors' dispatch desk in the general work
.
area to signify that he has reached a hold point. A QV inspector
"
is thence dispatched to the work. However, Project /QA management discussions are currently in progress relating to assigning inspectors to specific work crews.
As a result of past surveillance and audit findings, craft training has been increased and has emphasized hold point compliance.
The construction managers have required daily processing of any nonconformance report relating to a bypassed hold-point, to assure prompt corrective action. A documented policy has been issued within J. A. Jones which imposes reprimands and employment termination for repeated cases of hold point violation. All elements of senior site management interviewed displayed awareness of the issue and commitment to reduce occurrences. Crafts who were interviewed clearly expressed knowledge on this subject. The QA manager's monthly report includes a trend report on this subject, and showed a reduction from 7-15 instances per month (June to October) to
,
only 3 cases for the November report.
j.
J. A. Jones Stop Work /Stop-Process System The QA Manager stated that only one J. A. Jones initiated general stop work order has been issued; this.had to do with pipe supports.
It arose from direction received from the Engineer (UE&C), regarding
a skewed joint issue raised by the NRC in October 1981. The general stop work has been released, although skewed joint work. itself has not yet been released.
There. appeared to be general knowledge of the stop work order at all organizational levels.
l Item specific, localized stop-work controls are exercised by the QV inspectors routinely, through their placement of a " Hold-Tag" on the item in question. The J. A. Jones procedures prohibit further work on the item until the hold tag is cleared.. There appeared to be no inhibitions for the placement of such hold tags.
k.
J. A. Jones Nonconformance Control and Related Trending The J. A. Jones ASME QA Manual describes the principal deficiency control documents as the Nonconformance Reports (NCR), the Corrective
-
Action Reports (CAR), and the Audit Findings Reports (AFR).
Specific implementing procedures have been issued for each of these. The site has also implemented an Inspection Nonconformance Report (INR) for Quality Class II activities, and a Document Deficiency Correction Request (DDCR) for records discrepancies. Each of the above categories of deficiency are analyzed in the QA monthly
report.
The report categorizes deficiencies by type (e.g. hold-point violations, material defects, welding,...),
displays statistics
,
t m..
--,
_. - _
,_.-
.
'4 a.
.
-33-and graphical trends relative to prior months, and presents aging data regarding status of disposition. Other records and interviews of personnel substantiated that adverse trends have been monitored and corrective actions have been taken.
Recently the profect and construction managers have expressed increasing concei.n with some of the nonconformance reports and hold tags issued by the QA inspectors, in that such items may not have been justified.
The Project Manager's November 16 memo to the QA Manager shows concern that hold tags may be placed by the inspectors who are uncertain of the requirements or who may be imposing requirements beyond the procedures / specifications,
due to their opinions of what is correct. The J. A. Jones management concern in this area has led to formation of a review panel, consisting of the Project Manager, Engineering Manager and QA Managet, who will meet weekly to review NCR's written that week. The stated objective is to identiij areas where inspector training or procedure i
improvements are warranted. The QA Manager stated that his participation will assure that improper QV inspector disincentives will not
,
arise from this activity.
1.
J. A. Jones Construction Controls
,
Construction is governed by a work package system which includes interfaces with the quality assurance organization. QA engineering, inspection, nondestructive testing, records, and audit functions are involved.
In-process surveillance and inspection activities are provided and prescribed by procedures.
Work procedures are available at QV and at craft-foremen stations in the work areas.
In the general services building area, the area manager described his weekly meetings with area lead inspector. Such meetings apparently serve as basis for QV inspection manpower planning.
In the containment building area, the second shift construction supervisors and crafts clearly communicated freely with the inspection personnel.
Interview
<
of the GSB area manager, and a typical containment area foreman and crew indicated that construction was not experiencing significant problems with availability of inspection personnel at required
,
l hold-points.
No significant interface problems were identified, m.
J. A. Jones Quality Records Examined Relative To The Above Matters The inspector examined the following particular records relative to the topics discussed in the preceeding paragraphs of this report:
'
l (1) ASME QA Manual Revision 6 dated May_21,1981 (2) QA/QV Training and Certification Manual dated October 15, 1981
,
.
.
I
!
l
..
.
-.
.
.
'
'
a,.
..
-34-(3) Procedures:
JAJ-WI-010.1 Revision 3A dated June 25, 1981 Permanent Plant Hanger Installation JAJ-WI-017 Revision 1 dated December 29, 1980 Process Control Package Preparation & Control JAJ-WI-010.5 Revision OE dated July 24, 1981 Installation of Hilti Kwik Bolt Concrete Expansion Anchors P0P-N-100W Revision 3, dated June 26, 1981 Organization and Responsibilities P0P-N-108W Revision 1 dated April 8, 1981 Process Control Package System P0P-N-300W Revision 7 dated August 20, 1981 i
Control of Engineering Documents P0P-N-703W Revision 6 dated May 12, 1981 i
Nonconformance Reporting P0P-N-707W Revision 5 dated May 28, 1981 Site Inspection and-Test i
P0P-N-708W Revision 4 dated June 9, 1981 Quality Assurance Audits
P0P-N-713W Revision 4A-QC-1 dated August 17, 1981 Corrective Action P0P-N-715W Revision 2 dated May 14, 1981 Reporting'of Inspection Nonconformances ITI-021 Revision 08 dated April 8, 1981
UE&C Conditional Rele'ase Items (JAJ)
DRI-001 Revision 0 dated September 25, 1981 Document' Review Instruction PC-102 Revision.O dated October 30, 1981 Quantity Tracking'& Reporting"
,
(4)
J. A. Jones Monthly Report'for October 1981
Quality Assurance Department WPPSS #1 and #4 j
(5) Audit Reports:
,
,
Corporate Audits CQA-81-02 and CQA-81-04 Site Audits 81-02, 81-04, and 81-05
'
Site Audit Findings #10-80 Item #4; #05-80 Item #1; 81-04 Item #8 Yearly Audit Schedule 1981
.
Quarterly Audit Schedule 4th Quarter 1981
'
Corporate Consultant Report to QA dated September 25, 1981 Corporate Consultant Report to QA dated October 15, 1981 Corporate QA Manager Report to Vice President dated July 31, 1981 Site Report to Corporate QA (QAL-81-108) dated November 13, 1981 (6)
J. A. Jones Site Directives / Correspondence JRC-81-111 dated April 8, 1981 re: Corrective Action Guidelines JAJ Work Instruction 013 (Notice) " Pipe Cleaning" JRC-81-415 dated November 16, 1981 Quality Suggestions
'
.
.
-
. _. - ~
.. -
_. _.
-
.-.
..'
a..
.
,
-35-
,
(7)
J. A. Jones Corrective Actions Requests:
1-211/257-CAR-20 dated September 29, 1981 1-211/257-CAR-21 dated October 9,1981 (8)
J. A. Jones Corrective Action Correspondence CAR-20: QAM-81-172,10M-18 (WP Harris), ENG-81-335 CAR-21: QAM-81-183,QAM-81-189 Construction Manager Reply dated October 19, 1981 Project Manager Reply dated November 16, 1981 (9) Miscellaneous Documents:
QAD-81-0249 Qua'ntity/ Inspection Tracking System Analysis Hanger Reinspection Checklist-Support # CSS-55-SG2 (10) QV Inspector Qualification Files:
C. Hoover, J. Dale,-R. Vigne, R. Rahmig, G. O'Rourke, L. Webb, R. Harbison, and S. Baker n.
UE&C Materials Conditional Releases The inspector reviewe'd the status of owner-procured items which had been conditionally released for installation by J. A. Jones.
Some of the releases dated to early 1979, and involved cases where
vendor documentation had not been available at the time of installation
'
of the material. The amount or aging of such conditional releases was not an item that was routinely monitored by the licensee, and a sumary of the total value or amount of risk released items i
was unavailable.
The inspector examined the log of UE&C conditional releases (July 1977 through July 1981) and the log of Bechtel issued conditional releases since the Bechtel assumption of construction management in May 1981.
Several items were selected from each of these
,
logs. The selection emphasized the oldest open items relating
'
to Documentation Deficiency Notices (3DN's). The inspector examined the DDN or nonconformance report for each selected item, to ascertain
the nature of the backlogs and the prospects of encountering unresolvable quality situations that could require removal, or compromise of specitication requirements, of installed hardware. The following specific records were among those examined:
'
(a) Conditional Releases:
206, 207, 209, 212, 229, 230, 275, 276, 284, 303, 306, 318, 320, 327, 328, 330, 384, 392, 395, 439, 456, 491, 548, 669, 686, 738, 739, B-5, 10, 11, 15, 17, 18 l
l
'
--
. -.
--
_ _ -
'
so.,
-36-(b) Documentation Deficiency Notices:
P-207-2,P-02-54(1),P-02-55(2),P-02-56(3),P-02-57(4),
P-35-8, P-35-9, P-10, P-100-1, 2, 3, 4, 5, 6
,
(c) Nonconformance Reports:
CNCR-211-268, CNCR-211-290, CNCR-257-1551, CNCR-257-1599, NCR-123-05, NCR-02-114 The inspector found that Bechtel has made a specific effort to close out cach DDN. Some of the results of the effort had not yet led to closing of related. conditional releases. Following inquiry by the inspector, the Bechtel records personnel identified information that permitted closing of several of the conditional releases, and they then closed the items.. Additionally, the ronconformance tracking system is now being r'evised to identify conditional releases, to better permit monitoring status of this matter. The current number of open DON's did not appear excessive, and the Bechtel actions-in-progress to obtain resolution of old DDN issues appears appropriate. Attention to this area appears somewhat overdue for items dating to 1979. However, the current Bechtel progress on this task did not appear unreasonable, considering the mobilization period from the May 1981 Bechtel assumption of construction management responsibility. No items of noncompliance were identified.
'
10.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noni-liance, or deviations. Unresolved items disclosed during this inspection are discussed in Paragraphs 6.b. and 9.g. of this report.
11.
Exit Interview
,
!
The inspectors met with the licensee and contractor representatives
denoted in paragraph 1 on November 20, 1931. The scope of the inspection and the inspectors findings as described in this report were discussed,
i
l
l i
__,
.
-.
-
_
_. - - -
-
.
- -..
-
..
-
._._
.-