IR 05000528/1981002
| ML17297A411 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/06/1981 |
| From: | Dodds R, Eckhardt J, Elin J, Narbut P, Vorderbrueggen NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17297A409 | List: |
| References | |
| 50-528-81-02, 50-528-81-2, 50-529-81-02, 50-529-81-2, 50-530-81-02, 50-530-81-2, NUDOCS 8105200325 | |
| Download: ML17297A411 (68) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Inspection at:
Palo Verde Construction Site, Wintersburg, Arizona Inspection conducted:
J nuary 26 - February 5, 1981 Inspectors:
5~
R. T.
dds earn Leader Da Si ne REGION V
Report Nos. 50-528/81-02; 50-529/81-02 and 50-530/81-02 Docket Nos. 50-528, 50-529, 50-530 License Nos.
CPPR-141,
-142, -143 Licensee:
Arizona Public Service Company P. 0.
Box 21666 Phoenix, Arizona 85036 Facility Name:
Palo Verde Nuclear Generating Station - Units 1, 2 and
.
E.
o er ruegge Resid nt Reactor Ins ector at S
e J.
H.
Ec a t, eactor Inspector P>l Q
.
P.
ar ut Reactor Inspector Dat S gne
~ II ate S gne a
. 0.
E n, Reactor Inspector Approved by:
R.
.
o s,
C e
, Reactor ProJects at Sl ne Section 2, Reactor Construction Projects Branch Da e S gne 81-02 and 50-530 1-Summary:
Ins ection on Januar 26 - Februar
1981 Re ort Nos.
50-528 81-02 50-529 Areas Ins ected:
Special construction assessment team inspection of quality assurance, essgn controls, procurement controls, construction controls and project management of construction at the Palo Verde site.
The inspection involved 356 inspector hours on-site by five NRC inspectors.
Results:
No items of noncompIiance were identified.
The fo11owing perceived strengths and weaknesses were identifie r~
Summary (cont. )
-2-Perceived Stren ths:
(1) Management visibility; (2) management communication wit t e sta wor ers; (3) strong gA/gC project image - staff/workers appear to be working towards a corrmon goal for a quality product; and (4) strong construction management.
Perceived l/eaknesses:
(1) Performance of receiving inspection function (paragraph
.
contro of special handling or inspection requirements for components (paragraph 6.b.(2));
and (3) storage and maintenance of equipment (paragraph 6.c.(3)).
DETAILS 1.
Persons Contacted a ~
b.
Arizona Public Service Com an APS)
- E. E.
Van Brunt, Jr., Vice President, Nuclear Project Management
- J. A. Roedel, Quality Assurance Manager
- J.
M. Allen, Nuclear Engineering Manager
- D. B. Fasnacht, Nuclear Construction Manager
- A. Carter Rogers, Nuclear Engineering Manager
- R. J.
Kimmel, Field Engineering Supervisor
- W. E. Ide, Site QA Supervisor
- G. Pankonin, QA Engineer
- D. E. Fowler, QA Engineer Bruce S. Kaplan, Quality Systems Supervisor L. Souza, QA Engineer D. Wittas, QA Engineer D. Nugent, Site Procurement Supervisor R. Forrester, QA Engineer Bechtel Power Cor oration Bechtel)
- W.
- R.
- D.
- J
- S.
- A.
- D
- R.
J.
J.
R.
R.
R.
R.
A.
D.
H.
G.
G.
J. Stubblefield, Construction Manager L. Patterson, Division Manager, Quality Assurance T. Krisha, QA Manager, Projects D. Houchen, Assistant Project Manager M. Nickell, Project Superintendent K. Priest, Project Field Engineer R. Hawkinson, Project QA Supervisor M. Grant, Project Field QC Engineer Black, Resident Engineer Pfunder, Project QA Engineer Doskocil, QA Engineer Roehn, QA Engineer Rosen, QA Engineer Condie, QA Engineer Moore, Receiving/Storage QC Supervisor Hess, Design Document Control Center Super visor Klopp, Project Field Procurement Manager Brush, Rod Room Coordinator Dannenburg, Unit 1 Superintendent
co d.
Combustion En ineerin CE)
S. Mager, Site Manager A. Kalfas, Assistant Site Manager S. Knight, QA Engineer P.
De Grief, Internals Installation Supervisor The Waldin er Cor oration Waldin er)
R. Yarges, QA Supervisor G. Clapper, QA Engineer J.
Love, Technical Supervisor In addition various field engineers, craftsmen, inspection personnel, and other QA engineers were contacted.
- Denotes those attending exit meeting.
I. ~III II a.
Qualit Assurance Pro ram and Pro ram Ade uac The documentation that establishes and defines the Palo Verde Quality Assurance Program was reviewed.
These documents included the APS Quality Assurance Manual, the Bechtel Quality Program Manual, the APS Project Procedures Manual, and Chapter 17 of the PSAR.
The APS OA Manual contains a policy statement from the APS President and Chief Executive Officer that states "...the management of APS,
... recognizes its responsibility for assuring that the PVNGS is designed, constructed, and operated in such a manner as to provide for the health and safety of the public.
The importance of quality assurance in contributing to this safety as well as contributing to station reliability is also recognized."
QA Directive 2.0 of the QA Manual provides an overall description of the QA Program which consists of (1) a formal, documented system of administrative controls over activities affecting quality, (2) quality verification, and (3) quality assurance.
It defines the QA roles of APS, Bechtel, and suppliers.
The program appears to be adequately defined, interface control between the various organizations is established, and the program description contains a matrix of cormitments to 10 CFR 50 Appendix B requirements.
Also, QAD-2.0 provides for the Vice President, Nuclear Project Management,to review the status and adequacy of the QA program annually.
Organization charts are provided in QAD-1,0 that clearly define lines of authority and responsibility.
Also, the independence of the QA organization from design and construction is clearly indicated, with
-3-the APS gA Manager reporting directly to the Vice President, Nuclear Projects Management.
Written position descriptions exist for the President and Chief Executive Officer, the Operations Executive VP, the VP-Nuclear Projects Management, the gA Manager, the guality Systems Supervisor, and the Site gA Supervisor.
These job descriptions appear consistent with the organizational structure and define responsibilities and interfacing.
b.
ualit Assurance Pro ram Im lementation Various aspects of the quality assurance program were examined to verify that the written program is being adequately implemented.-
Specific areas examined included planning, organization, and activity review.
1)
~Pl anni n gA planning was examined to ascertain consistency with project status and adequacy to monitor'he project activities in an effective manner.
Presently the onsite APS gA organization
'. consists of five gA engineers (gAEs) and a supervisor, plus one temporary gAE.
The home office APS gA organization consists of four gAEs. and a supervisor.
The onsite Bechtel gA organization consists of sixteen gAEs and a supervisor.
Although this appears to be an effective number of gAEs for the present activities, the projected increased workload due to Unit 1-system turnover and startup gA activities could possibly result in a decrease in monitoring of future construction activities.
Also, there is no formal provision for providing for a temporary increase in gA manpower.
Although no firm plans had been established to increase manpower, the APS gA Manager was aware of the possible gA manpower shortage when Unit 1 system turnover and startup activities are underway, and indicated that provisions would be made to increase manpower when necessary.
The morale of the gAEs (both APS and Bechtel)
appears to be good and is reflected in the high retention rate of gAEs.
Approximately 60 percent of the gAEs have been at Palo Verde for three years or more.
The APS and Bechtel gA organizations plan their activities based on the projected project activities.
Construction schedules and project status reports are utilized for planning activities.
gA also participates in pre-planning of complex construction activities such as reactor vessel installation and containment tendon installation.
Audit and surveillance schedules are then based on this inpu ~ 4
A review of both APS and Bechtel site gA audit schedules for 1980, indicated that audits were performed as scheduled, that schedules are realistic and that the gA staff level is appropriate for present activity.
The audit checklists appeared to be adequately planned and they incorporated previous audit findings and suspected problem areas.
2) ~ai ii The gA organization as implemented appears to be consistent with the organization as described in applicable manuals.
In the past year no organization changes had been made and the turnover rate of gAEs has been low.
3)
~Atl
2 In order to verify the implementation of gA activities, the inspector reviewed supporting documentation, observed activities, and held discussions with gA personnel.
a)
OA Review of Desi n/Procurement Documents Bechtel site gA reviews Field Change Requests and field generated Procurement Documents.
The review process w'as discussed with Bechtel and documents were examined to verify that the reviews had been accomplished.
Approximately eight to ten FCRs and/or Procurement Documents per week are being reviewed.
1)
Audits Both the Bechtel and APS audit programs were examined to ascertain compliance with the applicable gA manuals.
There are three on-site audit groups who perform audits of site activities.
APS site gA performs audits of Bechtel's and 'other contractor's activities.
Bechtel site gA performs audits of Bechtel activities.
Bechtel site gA performs audits of subcontractor activities.
The 1980 and 1981 audit schedules for these organizations were reviewed and they indicated that all applicable elements and subcontractors were audited in 1980 and are scheduled for audit in 1981.
In addition, selected audit reports for 1980 were reviewed.
The audit checklists appeared to be comprehensive and applicable to the activity being
-5-audited.
The reports indicated that the audits were documented in a timely manner, exit interviews were conducted; and the audit results were communicated promptly in writing to the concerned organization.
In addition to the on-site QA audit organizations, the APS home office quality systems organization audits the APS site QA activities as well as auditing Combustion Engineering and Bechtel home office activities.
The 1980 and 1981 audit schedules for this organization were reviewed.
c)
The auditor and lead auditor qualification records of Bechtel and APS site QAEs were reviewed to ensure qualification criteria are being met.
Also, seven QAEs were interviewed to ascertain their understanding of auditing.
Surveillance Both the APS and Bechtel surveillance programs were examined.
APS QA does not have a formal surveillance schedule but does perform surveillances based on the construction activities in progress, NRC Bulletins and Circulars, Bechtel QA Bulletins, and other industry problems.
Each of these surveillances is documented with a copy given to Bechtel QA if the surveillance results in a finding.
All findings are followed up to verify that corrective action has been taken.
Bechtel QA performs surveillances based on a schedule.
Their surveillance schedule for the period of January 19 to February 13, 1981 included 20 sur veillances.
For 1980, an average of 99 surveillances per month were performed by Bechtel QA.
On February 2, 1981 the inspector accompanied and monitored a Bechtel QAE during a surveillance of weld rod control in Unit 2 containment.
Prior to the surveillance, the QAE reviewed the WPP/QCI regarding weld rod control.
The surveillance consisted of an examination of one rod issue room and a check of rod control for six welders.
It resulted in three findings.
The inspector considered the surveillance to have been conducted in a thorough and professional manner.
The three findings were corrected on the spot, and surveillance of weld rod control was conducted the next day to ensure a generic problem did not exist.
c.
Hang ement Involvement in A
Interviews were conducted and records were examined to determine the extent of management involvement and understanding of QA functions and findings, and also to determine their attitude toward quality and the image QA has at the projec )
Pro ect Ori inated Re orts One information channel used by APS management to keep informed of gA activities is periodic project originated reports.
These reports include monthly Bechtel gA sunmries, quarterly APS gA summaries, APS and Bechtel audit reports that include findings, and Deficiency Evaluation Reports (DER) that result in 50.55(e)
items.
Additionally, APS gA writes an annual gA report and presents this annual su+vary to the APS President and Chief Executive Officer in a formal meeting.
External Ori inated Re orts Management also receives external originated documents including NRC Bulletins and Circulars,
>LRC Inspection Reports, Bechtel gA Bulletins, and NRC inspection findings from other projects.
Where appropriate, problem area reports are transmitted to gA for action.
I 3)
Corrective Action P
~,mll':,
- .~
Ile I< t>>
=
l
"tl I ~Iy'llIlig.a
~
ill~
-
Corrective action was evaluated to determine the effectiveness and influence of gA in the organization.
This included corrective action regarding APS audit findings, Bechtel Corrective Action Requests (CAR), and NRC inspection findings and items of noncompliance.
The follow(up systems to verify corrective action were also examined.-
Corrective action appeared to be timely and included long term corrective action as well as immediate short term action.
In addition, the effectiveness of stop work orders was examined.
In 1980, ten stop work notices were issued and they appeared
'to have been supported by construction management.
Re ulator Interfacin During NRC inspections, the gA Manager keeps informed on a daily basis of the progress of the inspection and is responsive to any NRC concerns or findings.
He also attends all NRC exit meetings.
Also, the APS Vice President, Nuclear Projects Management, attends approximately 90 percent and the Bechtel Construction Manager approximately 50 percent of these meetings.
5)
~Ima e It appeared that APS upper management and Bechtel construction management projected a strong positive attitude toward quality.
Interviews with gA and construction personnel indicated this same attitude with respect to the gA organization, realizing that they are a meaningful part of the construction functio The APS gA Manager and Vice President, Nuclear Project Management visit the site frequently (usually more than once a week)
and make their presence known to both construction and gA personnel.
These site visits include communication with the gA personnel concerning the role of quality.
Additionally, the lines of communication between APS management, gA, Bechtel construction management, gC, and the craftsmen appear to be very effective.
All personnel interviewed indicated that problems could be readily discussed with management and effective action would be taken if necessary.
3.
Design Controls - Site a ~
~Pro ram The organizations involved in the design of the Palo Verde plant are as follows:
NSSS - Combustion Engineering, Inc.
HVAC - The Waldinger Corporation A/E 5 BOP - Bechtel Power Corporation All design activity by CE and Waldinger is performed at their home office engineering departments in Windsor, Connecticut and Des Moines, Iowa, respectively.
This includes the.handling of all situations that involve a design interface.
For field identified interferences, nonconformances, and similar problem items that may involve a design change, CE uses the Field Action Request (FAR) and Waldinger used a Supplier
"
Deviation Disposition Request (SDDR).
The FAR documents the situation in detail and is sent to the CE home office for resolution.
The SDDR also identifies the situation in detail, but it goes to Bechtel for resolution.
If the resolution involves a design change, it is detailed on a Waldinger Change Notice (WCN) which is then sent to Waldinger home office for initiation of a drawing change.
With regard to Bechtel, the only independent design work performed at the site is for temporary facilities/utilities, lighting layouts, yard piping (non-safety related), scaffolding, concrete formwork systems, rigging for hoisting activities, conduit routing details, and instrument tubing layout.
In the case of conduit and instrument tubing, basic requirements are established by Bechtel home office engineering.
These design activities are performed by Construction Department field engineers under the cognizance of the Project Field Engineer.
The Bechtel guality Program requires that design changes be subjected to the same level of internal project controls that are applied to the original design.
Design changes are governed, just as original design, by the formal Engineering Department Procedures (EDP) and
-8-Project Internal Procedures (IP).
Minor design changes that must be accommodated because of interferences, misfits, omissions, etc. which develop during installation are dispositioned at the site using the Field Change Request (FCR).
The design change is detailed on the FCR to the extent that the document can stand alone in identifying and resolving the situation.
All FCR's must be reviewed and approved by home office engineering and, to expedite'his review, the Project Engineering Manager has established a
Resident Engineer at the site.
He supervises a staff of liaison engineers (9 at the present time) with expertise in the various disciplines in accomplishing this approval function.
All FCR's are subsequently sent to home office engineering for second level (final) review and approval.
In cases where the Resident Engineer considers a change to be beyond the technical capabilities of his staff, he defers the approval, and sometimes the identification of the solution, to the Project Engineer.
The Nonconformance Report (NCR) is used for dispositioning defects, failures, deviations from procedures, or other deficiencies that render the quality of an item unacceptable or indeterminate.
The disposition of a nonconforming condition may be identified by Field Engineering, but any that are intended for "use-as-is" or "repair "
must have review and approval of home office engineering.
This review and approval requirement's also fulfilled by the Resident Engineer..
Pro ram Ade uac The program manuals of Bechtel, CE, and Maldinger that contain the procedures which govern the respective actions described above were examined by the inspector.
The procedures were found to be of the latest revision, were appropriately approved for use, and appeared to reflect good industry practices.
The scope of the procedural coverage was such as to satisfy regulatory requirements and SAR commitments.
The procedures also appeared to provide an adequate interface control system between the organizations involved at the site, The licensee has a comprehensive tabulation of structures, systems and components which have a safety relationship to plant operation.
This identification is extended to the various design documents.
The listing is in both the Project Design Criteria Manual and the PSAR.
Those documents also list the Regulatory Guides and Industry Standards applicable to the project.
Design changes developed through the site desi,gn control process are verified during installation/erection by inspections performed by independent quality control engineers.
This inspection function, as well as the field design change program, is audited by each organization's QA group and the licensee's QA staff.
The licensee has a program in effect for reviewing, analyzing and reporting construction deficiencies.
The Resident Engineer and the Bechtel home office engineering team perform the principal technical role in this progra ~0
Implementati on Site design control is effected through the use of the procedures contained in the Bechtel Engineering Department Procedures Manual, the Project Internal Procedures Manual, and the Field Construction and guality Control Manual.
The inspector verified that these procedures are readily available to, and are understood by, the involved individuals.
The Project Design Criteria Manual and the SAR is also readily available.
From a review of the contents of these manuals, the inspector observed that detailed coverage was included for: (1) revising drawings and specifications; (2) developing and reviewing supporting calculations; (3) adhering to codes, standards, Regulatory Guides, and IE Bulletins; (4) document and drawing control; (5) deficiency corrective action; and (6) interfacing with the home office and the licensee.
Also, a review of several procedures, drawings, specifications, and FCR's indicated that requirements were satisfied and good engineering practices were being followed.
Two Bechtel liaison engineers on the Resident Engineer's staff were contacted, and the FCR approval activity they were currently involved in was discussed.
One FCR related to modification of a pipe support and the other to a small-bore piping configuration change to avoid an interference.
In each case, it was obvious that there was definite need for the change, and the changes being made did not compromise the original design intent.
Both engineers demonstrated a good understanding of the change control procedures and were able to demonstrate that the design parameters were within the established criteria.
Independent checking and further acceptance review would be done in the home office upon receipt there of the completed FCR documents.
The inspector examined several other previously completed FCR's and verified that the home office verification had been completed in timely fashion and that the parent design drawings had been revised to reflect the field change.
The inspector also reviewed the technical qualifications of the two liaison engineers referred to above and found that they both were graduate engineers, and each man had extensive experience in the particular task in which he was involved.
From the master drawing control listing, five drawings were selected with current revisions in each of three areas of installation (containment, mechanical piping and electrical wiring).
In each case, the site Design Document Control Center (DDCC) had on file the latest revision of the master reproducible drawing (microfilm).
The drawing distribution file also indicated that the latest revisions had been distributed to the field work stations in a timely manner.
The documentation pertaining to the review and approval of the latest revisions appeared satisfactory.
The Bechtel, CE, and Waldinger facilities utilized for permanent storage of drawings, specifications and procedures were examined.
They
~t
-10-d.
appeared to be adequate.
Discussions were conducted with document control personnel at each facility and it appeared that their practices were in conformance with their procedures and commitments.
Ten drawings and two controlled manuals were selected at field work stations for each organization and compared with the master document list.
All documents were found to be of the latest revision.
The procedure for processing field generated nonconformance reports (NCR) provides for prompt review for reportabi lity to the NRC.
This review is performed in a joint meeting of the Resident Engineer and the Project guality Assurance Engineer, normally within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the NCR is initiated. If the review shows that a reportable situation may exist, the Bechtel Deficiency Evaluation Report (DER)
is initiated by Bechtel gA and the licensee is iamediately informed so that telephone notification to the NRC can be effected.
Disposition of all NCR's that constitute "use-as-is" or "repair" are reviewed and approved/rejected by the Resident Engineer in order that the original design conservatism (margin) is not compromised.
In those cases wherein Construction intends to depart from or modify a design document requirement, an FCR is prepared and the NCR is dispositioned by that action.
The inspector observed several of these situations and noted that the FCR dispositions were appropriately reflected on the affected design drawings.
tucana ement Involvement Because of the minor nature of design changes at the site, licensee management does not have any day-to-day involvement in the change process other than the surveillance and audit activities by their site gA staff.
Bechtel Project Engineering does have a coordinator who analyzes change requests on a monthly basis and issues a report to the Project Engineering Manager (PEM).
An interoffice memorandum is then issued by the PEM to the Project Manager which indicates any quality trends and identifies any appropriate action that has been taken or recommended.
These trend analyses are routinely discussed with the licensee during the monthly project review meetings.
4.
Procurement Controls - Site
'a ~
Pro ram Im lementation The organizations involved in installing safety-related permanent plant items are CE, Haldinger and Bechtel.
No procurement is performed at the job site by CE and Waldinger, their materials/equipment are procured by their home office operations.
The only procurement by Bechtel at the job site is for bulk type expendable materials, such as, nuts and bolts, weld filler materials, flat steel plate, and structural steel shape For Bechtel procurements, they act as agent for the licensee in preparing the Field Material Requisition (FNR) and the resulting procurement documents.
The actual Purchase Orders (P. 0. ), while issued by Bechtel, are actually the licensee's orders.
Consequently, all FNR's and P.O.'s are reviewed and approved by the licensee.
This review and approval process is intended to assure that all procurement requirements are satisfied, including technical and quality program requirements.
All FMR's and their subsequent P.O.'s are routed through both Bechtel and licensee gA groups in order to assure that the proper gA program aspects are satisfied.
The inspector randomly selected seven PO packages for examination.
Three were for weld filler material, two were for A325 bolts, nuts and washers, one was for A36 flat steel plate, and one was for structural steel angle.
In. all cases, the FMR's had been reviewed by the appropriate discipline gA engineers and had the respective List of Approved Suppliers attached, as required.
All suppliers that were listed had been audited by the licensee and/or Bechtel in order to be considered as
"approved".
Also, in all cases, the procurement package included the appropriate technical requirements and applicable industry codes and standards.
The Bechtel procurement system utilizes a form (G-321-V) which specifically identifies all documentation that the supplier must furnish and which also references the specification paragraph where the requirement is called out.
This form is designed in such a manner that. it can serve as the Bechtel
"source inspector's" release for shipment document, and as the supplier's Certificate of Conformance.
The form identifies the supplier and the PO number, has space for listing any of the procurement requirements that were not met, and has a certification statement for signature by the supplier's authorized gA representative.
This G-321-V form was included in each of the seven PO packages examined by the inspector.
From the appropriate presence and location of signatures, recording in logs, orderly arrangement of files, and apparent adequacy of the seven PO packages examined, the inspector concluded that the protection, handling and control of procurement specifications and purchasing documents was satisfactory.
Peceivin Ins ection All safety-related items are inspected upon arrival by Bechtel guality Control inspectors.
For each shipment received, a Receiving Inspection Plan (RIP) is developed by the assigned inspector which identifies the PO number, the supplier, the Material Receiving Report (NRR) number, and describes the item.
The RIP documents the conditions and characteristics found during the receiving inspection, and is filed in the gC documentation vault along with the documents received from the supplier.
The receiving inspection records are
-12-filed by MRR number and are readily available for review.
The gC inspector uses the procurement documents, particularly the technical specifications, as his basis for completing the RIP.
Standard verifications required by the RIP form are that the items are properly identified and marked, and the documentation required of the supplier (including the Certificate of Conformance, as applicable)
complies with the specified requirements.
The RIP also identifies the storage classification of the item(s).
The completed RIP serves to demonstrate compliance with acceptance requirements.
Items found to be nonconforming, either from a physical standpoint or because of missing or defective documentation, are tagged and segregated in an appropriate quarantine area; an NCR is prepared and must be cleared by the responsible discipline engineer before the item can be used in the plant.
Regarding the supplier documentation, all material test reports for ASME materials are sent by the receiving inspector to the Authorized Inspector for technical review and acceptance.
The technical adequacy of other documentation is verified by the Bechtel Supplier guality Representative (SgR) at the supplier's facility at the time he releases the item(s) for shipment.
Bechtel gA performs unscheduled audits of supplier documentation in the gC vault to ascertain the adequacy of the documentation review performed by, the SgR's.
The NRC inspector reviewed the report of one such audit (No. US-S-80-10) that was performed on March 3-7, 1980; the documentation for 73 items was examined and no discrepancies were found.
The auditor's qualifications were verified.
Audits are performed annually by the Bechtel Procurement Supplier guality (PS()
group on all suppliers of safety-related items.
Bechtel or the licensee gA groups participate in these audits as deemed appropriate from the performance history of the respective suppliers maintained in the Bechtel gA jobsite files.
The inspector examined the RIP's associated with the in-process receiving inspection of a shipment of shielded instrument cable (not site procured)
and a shipment of site-procured weld filler metal.
In each case the gC Inspector appeared knowledgeable in his assignment and the storage classification that the inspector had indicated on the RIP form agreed with that specified.in the master storage specification (13-MM-511, Storage Requirements).
The required certified Materials Test Report for the weld filler metal was stamped as acceptable by the Authorized Inspector.
No discrepancies on either RIP form was observed by the NRC Inspector.+
Storacte The site has no need at the present time for class A storage facilities.
The facilities for Classes B,
C and D appeared to be satisfactory at the present time.
It was pointed out to the licensee, however, that some upper limit temperature control provisions for class B storage may be necessary to accomodate the safety-related storage Note:
See paragraph 6.b.(1) for perceived weaknesses identified during the examination of receiving inspection for electrical component batteries when they arrive on site.
Protective measures against damage during storage appeared adequate.
Testing equipment for use on stored equipment is readily available and is suitable for the intended use.
l(ork and gA/gC procedures for storage related activities for class B,
C and 0 levels of storage were found to be generally adequate; however, a weakness in the follow-up of maintenance performed on stored equipment was pointed out to the licensee and immediate efforts were undertaken to upgrade that situation.
Access to storage areas appeared to be appropriately controlled and limited to designated personnel.
The areas reflected the application of good housekeeping practices.
A large, chain-link fenced quarantine area in the large warehouse was toured by the inspector.
The items in the area were observed to be "red-tagged" and appropriately covered. and arranged on pallets or shelves.
The area is maintained in a padlocked condition with the key controlled by one designated individual.
5.
~lleldin The inspector examined the general area of welding and the gA/gC program as it applied to welding.
The specific areas examined, the criteria used, and the findings are detailed below.
a ~
Pi in La down Areas The inspector examined the main large bore piping laydown area, the small bore piping subassembly laydown area, the small bore pipe material rack area, and the Unit 1 piping laydown area for conformance to ANSI N45.2.2, Regulatory Guide 1.38 and Specification 13-PM-204.
b.
No items of noncompliance or deviations were observed.
The laydown areas were generally orderly, the pipe ends were capped and pipe was on dunnage or racks.
Purchase Order S ecification for Small Bore Pi e and Fittin s The inspector examined the purchase order specification 10407-13-PM-307 Rev.
12 "Nuclear Service Pipe and Fittings 2 Inches and Smaller" for compliance to PSAR committments and ASME BSPV code requirements.
Ho items of noncompliance or deviations were observed, however the following two items were noted.
(I)
The same item of material had two different material specifications called out in different parts of the purchase order.
On ~age 66 of the material list, Item 1735 is 'described as 2" x 1'
stainless steel sockolets to ASME SA 312 Gr 304.
ASME SA 312 is a specification for pipe.
On page 4-3 paragraph 4.4.1.1 stainless steel socket weld fittings are required to be ASME SA 182 Gr F 304.
SA-182 is a specification for forged fittings.
The sockolets provided were SA 182 material.
The responsible site personnel stated the call out for SA 312 material was probably an editorial error.
Licensee personnel committed to issue a specification change to correct the material callout.
Therefore this item will be inspected further during a future inspection.
(50-528/81-02/01)
(2)
The body of the technical portion of the specifications require austenitic stainless steel materials to be furnished in a heat treated condition.
However the specification includes a checklist, Form G-321-D "guality Verification Docuement Requirements".
The checklist is used by source inspectors and receiving inspectors to verify the required documentation has been received.
For specification 13-PM-307 the checklist does not include an item for heat treatment certification documentation.
Paragraph 5.c.
below describes a case where this specification problem resulted in delivery and acceptance of pipe nipples without heat treatment certification documentation.
The action taken on this item is described in paragraph 5.c. below.
c.
Recei t Ins ection The inspector interviewed receipt inspection personnel and reviewed the documentation and hardware for one delivery of fittings; stainless steel nipples and sockolets.
The inspector verified chemical and physical test results met the material specifications.
The documentation associated with the stainless steel nipples, Item 1533, MRR 103541 did not contain certification that the nipples were heat treated as required by specification 13-PM-307 paragraph 4.4.4.
As stated in paragraph 5.b,(2) above, the specification checklist used by source inspectors and receiving inspectors does not contain an item for heat treatment documentation.
Subsequent to the inspector's finding, the heat treatment certification was provided by the vendor substantiating the fact that the nipples were suitable for use.
The licensee personnel wrote a guality Assurance Finding (OAF-SF-81-2)
recommending corrective action and action to prevent recur rence.
Therefore, this item will be inspected further on a future inspection.
(50-528/
81-02/02)
The inspector examined a sampling of other fitting material receipt packages and determined that other fitting manufacturers had provided heat treat certifications.
The packages sampled were MRR 11418, 12683, 19538, 21654, 79662 and 22554,
-15-The inspector examined the duties and responsibilities of the source inspector and the interrelated duties and responsibilities of receiving inspector through review of Bechtel Procedure
"Procurement Supplier guality Manual" Sixth Edition and "Surveillance Inspection Plan for Nuclear Service Pipe 5 Fittings, 2" and Smaller",
Rev. 0.
The requirements of ANSI N45.2.2 for item inspection were implemented in those procedures.
Meld Procedure Review The inspector examined a weld procedure specification, P1 AT Lh CVN Rev.
4 of April 18, 1979 for compliance to the detailed ASYiE BSPV Code requirements.
Also examined were the procedure qualification records and the supporting test data in conjunction with the specification.
The procedure qualification-records supported the procedure specification for position, thickness range, preheat, rod sizes and postweld heat treatment range.
The inspector also verified that tensile test, impact test and guided bend test results met code requirements.
A discrepancy between the welding procedure specification (MPS)
and the procedure qualification records (P(R) for an essential variable was identified.
The MPS provided a heat treatment temperature range.
The P(R's did not provide information on interpass temperature.
This discrepancy was identified after the inspection; therefore, a licensee representative was notified by telephone.
Discussion with the licensee indicated the discrepancy was acceptable on the basis that the PgR was performed in 1968 and the code at that time did not include interpass temperature as an essential variable.
The preamble to the code Section IX states it is not the intent of revisions to the code to require requalification of processes qualified to earlier versions of the code.
The inspector had no further questions.
The inspector examined the general welding specifications and determined the fitup and final weld configuration were not specified for full penetration piping branch connection corner welds such as would be used for sockolets, threadolets, and weldolets.
The inspector did not identify any case where a safety related branch connection using that type of fitting had been made dur ing site fabrication.
The inspector did observe g class sockolet fittings in the site warehouse.
At the exit interview licensee personnel coomitted to issue fitup and weld configuration instructions for full penetration corner welds in accordance with the applicable requirements of the ASIDE BEPV code and to determine more completely whether any such safety related joints had been previously performed and to perform reinspection as required.
Therefore, this item will be inspected further on a future inspection.
(Item 50-528/81-02/03)
q ~
P
-16-Field Weldin The inspector examined the welding of two field fabricated piping weld joints; 24" carbon steel weld W 018 SG 005 DLBB on Drawing 13 P-SGF 119(8) welded to procedure P1AT Lh CVN(4) in mid layer welding and 4" stainless steel weld W004 PCE 073 HCBA on Drawing 13P PCF 201(5) during fitup inspection and root welding.
Through observation of field work and subsequent records review the inspector verified certain specific activities were in compliance with applicable codes and standards.
For both welds the inspector verified the requirements of the weld procedure were included on the weld traveler form regarding preheat, interpass temperature, and filler metal.
The inspector verified the welders and QC engineers were qualified, that required nondestructive examination was specified, and that inspections applicable at the time of observation had/were being performed and properly signed off on the traveler.
The accuracy of the rod withdrawal slips was verified.
. For the carbon steel weld, the inspector observed that post weld heat treatment was not required and that the weld preheat had been properly increased to exercise that option in accordance with code requirements.
The inspector's observation of work and the visual weld quality did not disclose any items of noncompliance or deviations.
."
The inspector examined a completed 12" stainless steel field weld, W004 SI 220 CCBA.
The visual appearance of the weld was satisfactory.
Rod Room The inspector examined Rod Room 13 Unit 3 and verified oven settings were in accordance with FSAR committments.
The inspector observed proper material segregation and current oven calibration stickers.
The inspector selected three lots of material in the rod room and-later verified, by records review, that the detail requirements of the code and referenced standards were properly documented on the material certifications.
The details verified were the chemical
.
and physical test results including impact test results for P-I weld material and delta ferrite measurements for P-8 material.
The weld rod lots examined were E 309-16 Lot 10564-3 MRR 85479, E 308L-16 Lot 5D 923 M04 HRR 57618 and E 7018 Lot 2F018T01 MRR 92247.
No items of noncompliance or deviations were identified.
Audits The inspector examined the two most recent audits oi'he welding area by the Bechtel QA.
Welding audits are performed by the MQIIS Division.
The audits examined were performed in 1980.
The scope and depth of the audits appeared satisfactory.
The inspector examined the corrective action on two of the audit findings in detail (CAR
-17-005 and 013 of November 21, 1980) dealing with radiographic examination and socket welds respectively.
The corrective action appeared to be sufficient to prevent recurrence.
In regards to the CAR 013, the problem identified by the YigES auditor was that of a welder performing a socket weld without having first scribed the pipe with a reference line to ensure the pipe was properly positioned in the socket fitting, i.e.
1/16 inch from bottoming out.
The weld had not been inspected by the FACE at that point and would have been identified as not in conformance when inspected.
The inspector interviewed involved personnel including the welder, FACE, FWE, the Unit Assistant Lead Field Weld Engineer, and the Unit Superintendent.
The problem had occurred because the welder had been teamed with a new pipe fitter.
The welder's previous fitter had been performing the scribing during fitup for the welder.
The new fitter was unaware of the requirement and the problem was not noted by the welder prior to welding.
Through the interviews the inspector determined that the general problem with absence of scribe lines on socket weld fitups had been previously identified and reported on a nonconformance report and a
CAR S-80-80 of 7/23/80.
Both the CAR's were given to the Unit Assistant Lead Field Weld Engineer for disposition by the Unit Superintendent.
At the exit interview the inspector indicated that since CAR's are generally written for significant items, repeat CAR's are indicative of a possible need to escalate the level of management involved in the resolution.
Licensee management agreed to consider this point.
The inspector had no further questions.
Personnel Interviews The inspector interviewed a number of site personnel regarding the gA/gC program as it related to welding activities.
The inspector interviewed the Project guality Control Engineer, two quality control engineers, a unit assistant lead field weld engineer, a field weld engineer, two welders and two fitters.
There was a consistent attitude throughout the site organization that quality was second in importance only to personnel safety and was being achieved.
The quality control engineers felt that they were satisfactorily controlling quality and had the support of their supervision, the field engineers and the superintendents.
The only potential administrative weakness identified in the course of the inter views was that the gC personnel have no documentation vehicle to request action or clarifications from engineering.
The vehicles used are speed memos and interoffice memos.
However none of the personnel interviewed felt that this lack of a formal vehicle had resulted in a lack of action.
This item was discussed at the exit interview.
Licensee management agreed to consider the need for a formal vehicle.
The inspector had no further question.
Review of Ins ection Stora e
and Maintenance of Permanent Plant Materials In conjunction with a review of r ecords and observation of work in the area of electrical components and systems, the licensee's system of receipt inspection, storage, and maintenance of permanent plant items
'as audited for compliance to industry standards and licensing commitments.
The following areas of weakness were noted by the inspector in the licensee's program.
a ~
Personnel uglification (I)
The licensee's system for training and indoctrination of inspection personnel was reviewed.
This system appeared to conform generally to the requirements'of Regulatory Guide 1.58, and ANSI N 45.2.6,
"gualifications of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants."
The inspector noted however, that the licensee's procedure gCI 8.0, "gualification, Certification, and Training of gC Personnel",
did not expressly state the education and experience requirements defined in ANSI N45.2. 6, section 3, 1, "Levels of Capability."
The licensee's instruction stated
"Each candidate...shall have sufficient education and experience to assure understanding of the principles of gC...".
The licensee stated that other factors were sometimes used to provide assurance that inspectors met minimum capability requirements as allowed by the ANSI standard.
These factors were not formally documented or detailed as required by Revision 1, September 1980, of Regulatory Guide 1.58.
This revision to the Regulatory Guide states that "Since only one set of recommendations is provided for the education and experience of personnel, a commitment to comply (with ANSI N45.2.6 and Regulatory Guide 1.58) in lieu of providing an alternative to the recommendations of the standard means that the specific education and experience recommendations of the standard will be followed."
The licensee stated that a change to gCI 8.0, "gualification, Certification and Training of gC Personnel",
paragraph 6.0,
"certification requirements" would be made to clearly state the criteria used to establish the capability requirements for Level I and Level II inspectors when the education and experience requirements of ANSI N45.2.6 are not met.
Moreover, the licensee stated that each instance would be documented in the inspectors training file with a notation by the Level III examiner as to how capability requirements were determined.
Level III inspectors would meet ANSI N45. 2.6 requirements as specifically stated.
The inspector noted that only 3 to 5 gC inspectors out of 75 to 80 did not fully meet the ANSI N45.2.6 requirements
I
-19-(2)
for experience and education of Level II inspectors.
The training program for inspectors as implemented did appear to provide adequate capabilities to qualify these personnel to perform quality control functions as Level II inspectors.
The receiving inspectors interviewed appeared weak in their knowledge of the requirements of ANSI N45.2.2,
"Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants."
Some confusion was noted among receiving inspection personnel between ANSI N45.2.2 storage level A, B and C areas and Palo Yerde warehouses A.
B and C (all designated ANSI storage level B).
The storage of station batteries (non class IE items which were erroneously listed as quality class g items on receiving inspection documentation)
was examined.
The batteries were found to have been designated on the receiving inspection plan (RIP) as ANSI storage level C and placed in warehouse C.
ANSI N45.2.2 classifies batteries as storage level B items.
It was noted that the written tests receiving inspectors take, as part of their certification, contained no questions directed at the specific requirements of ANSI N45.2.2, even though this standard provides specific instructions for receiving inspection and storage.
The written test was directed at insuring proper document control and had many questions of this nature.
b.
Performance of Receivin Ins ection The inspector noted that receiving inspection (gC) personnel tend to rely on procurement supplied documentation such as the Naterial Receipt Record (HRR) rather than performing an independent check or verification of the procurement department functions.
The station batteries (noted previously)
had been erroneously designated as ANSI N45.2.2 storage level C items by procurement on a handwritten list of purchase specification storage requirements which was in use as an aid to HRR preparation (i.e. Specification 13-EM-050, Station Batteries, required ANSI N45.2.2 storage level B).
Procurement personnel had therefore erroneously indicated storage level C on the f1RR. It appeared that the receiving inspector noted the storage level designation on the NRR and indicated
"storage classification C" on the Receiving Inspection Plan (RIP).
As previously noted, the inspector appeared to associate storage level C with storage in warehouse C,
an ANSI N45.2.2 level B area, and did not question this designation.
The receiving inspector did not appear to have verified the storage designation with either specification requirements or ANSI N45.2.2 guidelines.
A similar problem had been subject of a previous item of noncompliance concerning unit 1 emergency generators (Inspection Report 50-528/79-02).
-20-(2)
There appeared to be a lack of positive control of special handling or inspection requirements.
The receiving inspection personnel (gC) and procurement personnel get special handling information from the discipline field engineer after the field engineer receives the MRR from procurement signifying site arrival. If no special instructions are forthcoming from the discipline field engineer, the receiving inspection (and procurement)
personnel assume that none are required.
The station batteries noted previously had no special handling, storage, or receiving inspection instructions.
The requirements of L/PP 28.0,
"Maintenance of Materials and Equipment", paragraph 8. 10, "Station Batteries";
and specific vendor instructions were not relayed to procurement or receiving inspection (gC)
personnel.
No action was taken to meet special receiving and storage requirements.
.Furthermore, these items had not been properly included in the permanent plant equipment maintenance system so that when observed by the NRC inspector on January 28, 1981, no check of the batteries fluid level or state of charge had been made since arrival on site in April 1980.
The last accurately documented charging of these batteries was by the vendor on Sunday, March 16, 1980.
~
'he station batteries are not safety related, consequently no enforcement action was taken, however the personnel and procedures involved will apply directly to safety related batteries when received on site.
Stora e and Maintenance (1)
(2)
It was noted that the storage level B warehouses did not have provisions to provide heating or cooling.
The temperature and humidity in these areas was continuously monitored by strip chart recording ~nstrumen]s.
Due to the mild environment, temperatures in the 40 F to 140 F range required by ANSI N45.2.2 for storage level B equipment was maintained.
The licensee did not however seem to have provisions to control temperatures for equipmen$
whose maximum storage condition might be less than the 140 F maximum such as storage batteries.
The maintenance of permanent plant items is performed under the direction of discipline field engineers, but the adequacy of quality control or quality assurance surveillance of some activities appeared questionable.
Previous NRC inspections have identified permanent plant items not included in the licensee's maintenance program (Inspection Report 50-528/80-17).
This inspection disclosed station batteries which had not had checks on fluid levels or state of charge, and had not been given periodic freshening charges as required, although maintenance action cards indicated that these activities had been performed.
(As these batteries were found to be non-safety related items no followup of this item was performed by the inspector).
These events do however bring questions to light as to the adequacy of the licensee's maintenance progra The licensee was aware of these problems and is performing a
review of permanent plant items to insure proper inclusion in the maintenance program.
The licensee has scheduled quality assurance audits of this area for early 1981.
This area will be reviewed by NRC inspectors as a followup item during a future inspection.
Specific items to be reviewed include (1) the licensee's method of assuring that all permanent plant items are included in the maintenance program and (2)
the licensee's methods of assuring that specific maintenance requirements are properly performed and documented for these permanent plant items.
(50-528/81-02/04)
7.
Review of Electrical Com onents and S stems The inspector observed work performance, and completed work associated with the four safety related DC busses, load centers, inverters, and vital AC instrument power panels in unit 1.
Areas reviewed included equipment maintenance, construction inspection and qualification of inspection (gC) personnel, documentation relative to nonconforming components, and missile protection and separation requirements.
The following areas of weakness were noted by the inspector in the licensee's program.
a.
Incom lete 10 CFR 50.55 e
Submittal On November 5, 1980 the licensee submitted a final report on a reportable deficiency related to a mechanical interlock device on battery charger 1-E-PKA-H15.
This interlock could be defeated, allowing simultaneous the closure of breakers supplying redundant DC busses thereby placing these busses in parallel.
The final report stated that "this condition is isolated to the above identified battery charger".
An improved design was provided for Units 2 and 3.
On January 29, 1981 the inspector noted an identical fault in the mechanical interlock on redundant battery charger 1-E-PKB-H16 in Unit 1.
This condition was apparently not identified by the licensee.
The inspector noted that, in addition, the mechanical interlocks were not labeled to alert operating personnel of the possibility of electrically connecting two redundant DC busses if the interlock was defeated.
moreover, the breakers themselves were not labeled or color coded in a manner that would indicate them to be part of redundant trains.
The inspector was concerned that a full evaluation of the deficiency had not been made prior to the submittal of the final report.
The licensee stated that this item would be re-reviewed and an amended final report submitted.
This will be a followup item during a future inspection.
(50-528/81-02/05)
-22-b.
Im ro er Identification of Class IE Conduit and Cable The facility design as detailed in the FSAR incorporates a standby or third-of-a-kind safety related load.
This load is the third charging pump.
The FSAR states that conduit from the power source transfer switch to this standby or third-of-a-kind charging pump is to be marked with red and green stripes indicating power from either safety related division A or safety related division B.
The licensee's one line schematic of this circuit shows that the conduit is to be labeled with red and green striped identification tags per the FSAR.
The drawing however gives an
"N" series number to the circuit which by the licensee's standards indicates non-safety related.
(Safety related circuits and conduits have "A, B, C or D" series numbers).
Additionally the cable was specified on the circuit one-line schematic drawing as black cable.
(The licensee utilizes red, green, yellow or blue colored cable in safety related circuits).
The conduit installation drawings showed only the conduit numbers, from which safety classification could be determined.
As this conduit number was an "N" series number the conduit was labeled in the field as non-safety related and the conduit did not provide the cable with separation from other non-class IE circuits associated with monitoring pump performance.
IEEE 384 requires that both raceway (conduit) and cable should be identified so as to readily distinguish between redundant class IE systems and non-class IE divisions.
The system of identification is required by Regulatory Guide 1.75 to be "simple and should preclude the need to consult any reference material."
The use of "N" series cable and conduit numbers and the use of black colored cable seems to defeat the licensee's otherwise simple system.
The licensee stated that this matter would be reviewed and appropriate FSAR and design changes implemented.
This area'will be a followup item during a future inspection.
(50-528/81-02/06)
c.
Ouestionable Breakout of Cable from Racewa to Conduit The inspector noted a routing of safety class IE cable from horizontal raceway to vertical conduit that did not appear consistent with normal industry practice.
In unit one, division A cable (safety related)
was observed to be routed out of horizontal tray IEZJ1AATKAC to vertical conduit IEZJ1AARK22 by rising approximately 6 inches to clear the tray edge (edge protector provided), running approximately 15 inches horizontally (unsupported)
and then dropping approximately
-23-20 inches (unsupported)
to enter the conduit vertically.
This type of breakout was noted in several other instances for cables of divisions A, B and D of unit one.
Normal industry practice, and the practice in use at unit 2, has
'he cable rising from the tray to enter conduit horizontally near the tray edge with the transition to vertical conduit accomplished by means of a 90 degree elbow in the conduit.
An alternate industry practice would utilize a tray end dropout to support the cable during this direction change and provide tray edge protection.
The licensee installation, as observed in unit one, appears to provide questionable support to the cable at the loop formed by the direction changes.
The licensee's drawings specify the maximum unsupported distance for cable in free air shall be 18 inches horizontal and 24 inches vertically.
These criteria may not however be sufficient in this situation where an unsupported
"loop" of cable is formed due to a major direction change.
The licensee stated that this situation would be brought to the attention of design engineering for review.
Use of Flexible Conduit as a Means of Providin Se aration of Redundant a
es The FSAR states in paragraph 8.3.1.4.1.1.C.8 that, when "isolation between separation groups...is less than... (3 feet horizontal and 5 feet vertical)..., all but one of the separation groups (is) routed in ri id steel conduit or wirewa maintaining a one inch separation between con uits....
In t e FSAR section 8. 3. 1.4. 1.2 when the 6 inch minimum physical separation within control boards and other panels is not maintained the separation groups shall be installed in an "enclosed racewa ri id steel conduit ENT or enclosed t t In practice the licensee is using a flexible spiral wound metalic conduit as a cable support in areas where certain flexibilityis required in the cable system.
The licensee also considers this flexible metalic conduit equivalent to rigid steel conduit as a barrier for meeting separation requirements.
The inspector questioned this application of flexible conduit.
The. licensee stated that this area would be reviewed for compliance to industry standards and regulatory guidelines.
This item will be examined further pending review with I'iRR of specific separation requirements and the use of flexible conduit.
(50-528/81-02/07)
Note:
Emphasis adde e.
Se aration of Redundant Circuits b
Means of Conduit or Enclosed
~acewa s
IEEE 384 in paragraphs 5.1.3 and 5.1.4 state that
"Hhere plant arrangements preclude maintaining the minimum separation distance, the redundant circuits shall be run in enclosed raceways that qualify as barriers...."
Figure 3 of IEEE 384 shows two redundant divisions, both enclosed in solid barriers with 1 inch spacing between the barriers.
The licensee in the FSAR states that the requirements of Regulatory Guide 1.75 and IEEE 384-1974 are met.
In section 8.3. 1.4, 1 of the FSAR "separation criteria" it states in paragraphs 8.3. 1.4. 1.C.7 and 8.3. 1.4. 1.C.8 that "all but one of the separation groups" shall be run in enclosed raceway; The addition of the words "all but one of" dilute the requirements of IEEE 384 to have each separation group in enclosed raceway where minimum separation distances are not maintained.
In practice the licensee has considered separation to be adequate, in situations where minimum separation distances are not met between two redundant divisions, by routing one of the two groups in conduit and leaving the other in exposed raceway.
(IEEE 384 requires both groups to be routed in conduit with a 1" minimum separation between conduits.)
This apparent exception to industry standards was discussed with the licensee.
This item will be examined further pending review with NRR of the specific separation requirements and the use of enclosed raceways to achieve separation.
(50-528/80-02/08)
8.
Review of Structural Concrete Activities I
The inspector observed work performance, and completed work associated with concrete placement activities.
Areas examined included post-placement activities associated with unit one refueling water storage tank (first lift), and condensate storage tank (5th lift). Additionally, Cadweld activities on unit three containment were observed.
The inspector identified no areas of weakness or concern.
9.
Pro 'ect Mana ement Control The project management portion of the inspection was directed towards verification that management has been exercising control in a manner that should assure a quality product.
The inspection included (1) interviews with selected field and office engineers, clerks and management personnel
-25-up through the level of the APS Vice President, Nuclear Project Management, and the Bechtel Field Construction Manager, and (2) examination of selected procedures, various types of reports, logs, minutes of staff meetings, trending analysis, personnel records and analysis of equipment and systems.
Attachment A is a listing of most of the documents and procedures examined during this portion of the inspection.
Principal areas of review included:
(lit-gg l tt,t l tt, dgt g
C t l:(t)~l Plann>ng, ctivity Review, and Inspection; and (3) Mana ement Involvement-Reports, Management Revie>c, Other Information Channe s, an Management Image.
Results of the inspection are as follows:
a ~
~Pro ram (l)
~0" l* tl Organization charts for the licensee and contractor were current.
Lines of authority and communications between APS and Bechtel (A/E - Construction Manager/Contractor)
have been clearly defined and were understood by parties interviewed.
Written and approved detailed position descriptions had been prepared for engineers and managers and were found to be consistent with the current organizational structure and program description.
Individuals interviewed had a good understanding of interface controls relating to changes, notifications, reports, approvals and stop work authority.
~ ~
(2)
Communications d
The APS and Bechtel program procedures clearly define channels of communications and responsibilities for communications in IP-2. I, NS-1, NS-2, NS-3 and NS-4.
The types of reports in use have been identified in procedures IP-3. 2, gAD 10. 1 and gAD 2.4.
They include progress reports, trending analysis, studies, surveillance reports, and periodic reports.
A management Review Meeting is scheduled and has been held annually to discuss the Annual gA Report with the President, Chief Executive Officer and other members of APS management.
(g)
~cl t t The program incorporates controls to effect changes in response to: (I) NRC Circulars, Bulletins and Information Notices; (2)
design changes, field generated specifications, and field change requests; (3) corrective action resulting from audit findings; and (4) regulatory requirements.
The document control logs in the several departments require a close out of these type of items.
In addition, the licensee receives and evaluates 4'
-26-for action industry experience reports, Bechtel gA Bulletins, NRC items of noncompliance reviews (agency wide), all of which are routed through the Vice President, Nuclear Project Management, to OA for followup action as appropriate.
(See section on gA program for additional information in this area.)
b.
Implementation
~Pl annwfn gAD 2.4 identifies the type of reports to be submitted to management to assure that management is apprised of conditions found during the reporting period that could be adverse to quality.
Examination of these reports and minutes of management meetings disclosed that management has been responsive to adverse trends to assure the controls have been initiated when trouble spots appeared, such as for apparent excessive rework on hangers and supports.
Discussions with management (APS and Bechtel)
and the licensee's engineers in gA, engineering, and construction indicated that interfaces between the various licensee organizations and contractors were clearly understood.
The several managers interviewed appeared comfortable with the size of their staff for the current work load.
All felt they had management backing and could obtain additional resources when necessary.
Several cases were cited to demonstrate this support.
Staff members generally felt that, while kept busy, their work load was not excessive to preclude the review of various reports and to detect trouble spots.
The review of staff qualifications disclosed those examined to be consistent with position description requirements.
Personnel interviewed had a good understanding of their responsibilities and authorities.
(2)
Activit Review Several recent activities performed by the engineering, construction and gA staffs were examined, including several jobs in progress.
Areas considered included construction deficiency reports, activity planning, record accessibility, manpower, interfaces, engineering coverage, and identification of regulatory requirements.
No weaknesses in the licensee's activities were identified.
Ins ection The frequency of and quality of field inspection/surveillance and performance reviews, conducted by department heads, discipline engineers and other management staff who impact on contractor
-27-c.
Mana performance were examined.
Personnel job descriptions specify individual responsibilities with respect to the surveillance of construction activities.
APS personnel, other than gA, do not perform inspections per se, but rather perform a surveillance type function.
gAD 10. 1 provides guidelines for reporting surveillance activities at the site by licensee project personnel.
Project staff normally complete a surveillance report "...after each site visit involving noteworthy activities or observations...."
The site construction engineers maintain log books of their daily activities and only prepare site surveillance reports when significant observations are made.
Their log books are examined at least once per month by the Field Engineering Supervisor.
The site construction engineers interviewed did not work to a surveillance plan, but did follow the activities in progress in their respective disciplines.
The engineers from the engineering department habitually prepare site surveillance reports for each visit.
They attempt to get to the site several times a month and work with their APS and Hechtel counterparts.
The Surveillance Report Log was examined, as were several surveillance reports, to assure that reports were properly distributed, that persons were assigned to take appropriate corrective actions and that items were tracked through correction.
It appeared that items were being appropriately reviewed and an effort made to improve performance.
ement Involvement
~Re orts Management's utilization of various operational reports was examined in detail with principal managers and supervisors, including the APS Vice President, Nuclear Project Management.
Utilization of reports by the Company President and Executive Vice President was also ascertained.
Issues examined included staffing, construction deficiency reports, trends and rework.
All conscientiously reviewed the analysis of trending reports, and did not believe rework to be a problem at this time.
Where problem areas were identified, management attention was being given to correct the situation such as that cited earlier with respect to hangers and supports.
The managers interviewed felt their staffs were adequate for the current work load, even though it was "heavy", and all felt they had management backing to obtain additional personnel once the need was justified.
Education and experience of the staff appeared to be comensurate with the job descriptions examine Deficiency Evaluation Reports (DERs) are prepared by Bechtel for significant matters and evaluated for Part 21/50.55(e)
reportability.
APS gA is responsible for tracking and auditing DERs to their ultimate conclusions and to report to the Commission as appropriate.
It appeared that actions taken - upward and downward - to resolve issues were adequate, timely, and communications were complete.
Mana ement Review Management conducts annual reviews of department performance, including a compensation review and performance by objectives review.
Each supervisor is required to conduct a similar review of his department and staff.
The Equipment Utilization Department does field audits and work sampling on adequacy of equipment.
The various managers interviewed demonstrated knowledge of gA findings and field engineering reports.
All were familiar with the systems used to follow up on and verify corrective action.
It is the. practice of the Vice President, Nuclear Projects Management to attend all NRC-IE exit interviews unless he has an unavoidable conflict.
Likewise gA, Construction, and Engineering management and their counterparts in the Bechtel organization usually attend exit meetings.
All negative findings are personally reviewed by the Vice President, Nuclear Projects Management.
An action item list is used to track open items and assure a timely response to findings.
Bechtel determines the corrective action.
They are audited by APS gA to assure answers are meaningful and reflect timely corrective action.
The NRC Regional Office has not experienced any problems in this regard with the licensee.
Other Information Channels Licensee management does not have a written program for handling allegations, nor has management guaranteed protection to workers in writing who bring in such complaints.
However, it has been the policy and practice that allegations be handled by the gA Manager.
All workers and staff members interviewed by the team members believed that management had an
"open door" policy and believed that their concerns would be attended to satisfactorily.
They did not have any adverse comments in this regard.
Management stated, and the staff concurred, that this unwritten policy and adherence to quality standards has been continually stressed to the staff.
When allegations have been received, the record supports that they have been-.
handled promptly and the alleger notified of the resolutio From the discussions, it was found that the Executive Vice President has personally talked to QA/QC type inspectors to assure that they are not being intimidated by management with respect to identified deficiencies.
Allegations received by Bechtel are directed to the Construction Manager who directs the investigation and keeps abreast of'findings.
The licensee has an effective suggestion-award system for improving quality and/or performance.
The staff was aware of the system and it appeared that it was easy to submit suggestions.
The licensee does not have a grievance system since there are no union members under APS Nuclear Project Management.
~MI The methods used by management to maintain contact with site construction and the people performing the work were examined.
The examination included employees'erception of management's interest in the job, dedication to quality, interest in employees, availability to employees, and general knowledge of what is going on.
The Vice President, Nuclear Projects Management holds a staff meeting with the managers at least once a month.
Periodically he meets with them and the employees.
Approximately once a
month he meets with the site construction and QA staff.
Personnel interviewed confirmed his attendance at their staff meetings and the holding of general staff meetings.
Department staff meetings are held at least monthly, while supervisory staff meetings are usually held weekly at the construction site.
The licensee has initiated programs to improve communications within the APS and the contractor/craft organizations.
Nuclear Projects has a communications consultant who periodically holds seminars with the staff on a volunteer basis.
Through Arizona State University APS also sponsors an annual one-and-a-half day Cotrmunications Seminar for APS and Bechtel staffs down to the craft general foreman level.
At the end of the session, the craft foremen are given ample opportunity to discuss their problems with construction management.
All participants are invited to rate the program and identify concerns anonymously.
The program has been in effect for three years.
A total of about 360 will attend one of the six seminars to be held this year.
The several managers and engineers interviewed thought the program to be very beneficial.
This feeling prevailed in the course evaluation sheets reviewed by the inspecto It was found that all levels of management periodically tour work areas from several times a week to at least once a month.
The Nuclear Projects Vice President formally tours the site once a month with the Bechtel Project Manager and Construction Manager.
Since 1977, the APS Board of Directors have annually held a meeting at the construction site that includes a site tour and a status/progress report.
Personnel interviewed confirmed managements visibility on site, at staff meetings and general meetings.
They perceived management to be dedicated to quality, genuinely interested and supportive of employees, available to employees through open door policy at all levels of management, and that management had a good understanding of the job.
All felt that substandard work would not be accepted or "engineered away."
10.
Exit Inter view At the conclusion of the inspection the scope and findings of the construction assessment teams inspection were discussed with the licensee representatives identified in paragraph I of this report.
The licensee's representatives agreed to examine the identified items of concer ATTACHMENT "A" DOCUMENTS EXAMINED DURING REVIEW OF PROJECT MANAGEMENT 1.
Organization charts for APS on Bechtel 2.
Minutes of Staff Meetings a.
Engineering -
ANPM 10341 - EEVB/ACR 3.
guality Assurance Progress Report, December, 1980 4.
Annual gA Report, January 1,
1980 to December 1,
1980 (Draft)
5.
quarterly gA Report, October 1, 1980 to December 31, 1980 6.
Weekly Reports (construction)
PVNGS Update of significant items for Weeks Ending January 16 5 23, 1981.
7.
Unit >1 Schedule Analysis Report P4, January 27, 1981.
8.
Testimony of Keith L. Turley, President and Chief Executive Officer and Edwin E.
Van Brunt, Jr., Vice Pt esident, Nuclear Project Management, Arizona Public Service Company Before the President's Nuclear Safety Oversight Committee, December 17, 1980.
9.
Nuclear Services Department Procedures 10.
Deficiency Evaluation Reports and Acceptance Forms for Report Nos. 80-41, 79-13 and 80-44.
11.
Work Plan Procedure/guality Control Instructions 12.
Construction Site Surveillance Report Log 13.
Site Action Items List 14.
Injury Frequency Rates for December, 1980 15.
PVNGS Construction Site Surveillance Reports - selected reports for the year 1980.
16.
guality Assurance Manual (APS)
17.
Nuclear Construction Project Procedures Manual (APS)
18.
Nuclear Services Department Project Procedures Manual (APS)
19.
Bechtel Progress Reports
20.
Integrated Leak Rate Test Procedure File, including Trip Report ANPM-10130-ACR/BSE, 21.
Minutes of Project Review Meeting on 1/21/81 22.
Position Description of selected staff 23.
Personnel resumes of selected staff 24.
Selected Construction Field Engineers Log Books 25.
Diesel Generator Systems Description, Rev.
2 B/ANPP-E-65282 comment letter 26.
Study of Electrical System Reliability (still under review by engineering)
27.
Auxiliary Feedwater Pump Shaft Hardness Report and NCR file 28.
Modification Change Notices (4 examined)
29.
Pipe flodification due to Home Office Drawing Changes - Trip Report ANNP-OC-20630 1/26/81 30.
guality Assurance Finding SF-81-3, 1/29/81.