IR 05000546/1979018

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IE Insp Repts 50-546/79-18 & 50-547/79-18 on 790813-14 & 0904-07.Noncompliance Noted:Failure to Follow Procedure & Design Changes Not Approved by Proper Authority
ML19256F055
Person / Time
Site: Marble Hill
Issue date: 09/24/1979
From: Hawkins F, Hayes D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19256F046 List:
References
50-546-79-18-01, 50-546-79-18-1, 50-547-79-18, NUDOCS 7911210046
Download: ML19256F055 (17)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-546/79-18; 50-547/79-18 Docket No. 50-546; 50-547 License No. CPPR-170; CPPR-171 Licensee: Public Service of Indiana 1000 East Main Street Plainfield, IN 46168 Facility Name: Marble 11i11 Nuclear Generating Station, Units 1 and 2 Inspection At: Marble Hill Site, Jefferson County, IN Inspection Cor ducted:

ugust 13-14 and September 4-7, 1979

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G Inspector:

F. C. Hawki 9-27-77 Accompanying Person el:

D. W. Hayes

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.:::::7 Approved by:

D. W. Hayes, i

@-W-79 Engineering Support Section 1

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Inspection Summary Inspection on August 13-14 and September 4-7, 1979 (Report No. 50-546/79-18; 50-547/79-18)

Areas Inspected: Follow-up on unresolved items identified in IE RIII Report No. 546/79-16; 547/79-16 by the Waterways Experiment Station (WES)

U. S. Army Corps of Engineers; Review of PSI and contractor nonconformance reports. This inspection involved a total of 50 inspector-hours onsite by one NRC inspector.

Results: Of the two areas inspected, one apparens item of noncompliance was identified in each area; (infraction - failure to follow procedures -

Pa ragraphs 1. d, 1. f, 1.j. (1), 1.j. (2), 1.1, 1.m, 1.n. (2), 1.n. (3), 1.n. (4),

1.n.(5), and 1.n.(1); infraction - design changes not approved by proper authority - Paragraph 2).

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Introduction This report is one of several reports docurating results of inspections performed at the Marble Hill construction site over the past several months by the NRC Office of Inspection and Enforcement (IE) Region III and by the U. S. Army Engineer Waterways Experiment Station culminating in the issuance of an Order Confirming Suspension of Construction on August 15, 1979.

bnJune 12, 1979, the NRC received information that a former worker at the Marble Hill site had alleged improper repairs of honeycomb areas in concrete. The allegations were contained in a sworn statement submitted to the Office of Nuclear Reactor Regulation (NRR) through an attorney representing an indiana intervenor group. Subsequently Region III IE received a copy and initiated an investigation on June 22, 1979. The results of this investigation are documented in Report No. 50-546/79-08.

Prior to receipt of the allegations during inspections conducted in April 3-6 and April 30-May 3, 1979, problems were identified relative to the placen.ent and repair of concrete. A management meeting with PSI was held on May 15, 1979, to discuss these findings. The results of the inspections and the May 15, 1979, meeting are documented in Report Nos.

50-546/79-03, 79-04 and 79-05.

On June 26, 1979, a second meeting was held with PSI officials to discuss the findings of the investigation at that point and the fact that deficient repairs of concrete had been identified. As a result of this meeting PSI agreed to stop concrete activities for safety related structures, perform non-destructive examinations of various concrete structures, identify and evaluate repaired areas for adequacy and review their entire program for concrete activities on site. An Immediate Action Letter (IAL) dated June 27, 1979, was issued confirming this agreement. A copy of this letter is attached to Report No. 50-546/79-07.

On June 27-29 and July 2-7, 1979, an inspection was conducted relative to items 1, 2, 3, 4 and 5 of the IAL. Based on the results of this inspection, documented in Report No. 50-546/79-07, IE: Region III concurred in the resumption of concrete placement for Safety Related Structures. The conditions for this concurrence are contained in a Region III letter to PSI dated July 13, 1979. A copy of the July 13 letter is attached to Report No. 50-546/79-07.

Report No. 50-546/79-09 documents results of an inspection conducted during the period July 9 through July 27, 1979.

Initial results of this inspection led to a site management meeting on July 20, 1979, and an understanding that PSI would again stop concrete activities for Safety Rhlated structures. A second IAL dated July 23, 1979, was issued documenting this understanding aad a copy is attached to Report No. 50-546/79-09.

Report No. 50-546/79-10 documentsthereeultsofaninspectionc5nducted July 10-13, 1979, relative to the erection of safety related steil structures.

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On July 25, 1979, IE: Region III learned that a team from the National Board of Boiler and Pressure Vessel Inspectors had conducted an inspection on June 12-14, 1979, at the Marble Hill site during which numerous items of noncompliance with the ASME Code were found. As a result of the National Board's inspection and the IE: Region III findings a comprehen-sive team inspection was conducted during the period July 26-28 and July 31-August 3, 1979. The purpose of this inspection was to identify

.the underlying causes leading to the concrete and ASME code deficiencies and to determine if they were symptomatic of problems in other areas.

The results of this inspection, documented in Report No. 50-546/79-11, indicated that problems in the Quality Assurance / Quality Control (QA/QC)

program in concrete construction activities extended to other construction areas as well.

At the request of PSI, representatives of Region III and PSI management met again on August 1, 1979, to discuss PSI's planned actions to correct the programmatic QA/QC problems at the Marble Hill site. The meeting included a discussion of the desirability of stopping all safety related construction activities at the Marble Hill site until such time as the licensee demonstrates that it has an effective QA program acceptable to the NRC. The licensee issued a stop work order on August 7, 1979, for all safety related construction. An order confirming this suspension of construction was issued on August 15, 1979, by the NRC. A Meeting was held with PSI management in the Region III offices on August 15, 1979, to discuss the conditions of the confirming order. The meeting is documented in Report No. 50-546/79-14.

On June 28, 1979, NRC headquarters personnel met with Congressman Deckard of Indiana. During this maeting Congressman Deckard provided information concerning allegations he had received involving improper activities by the concrete testing laboratory at the Marble Hill construction site. As a result of this information the U. S. Army Engineer Waterways Experiment Station was requested to perform an independent inspection of the testing laboratory activities. The results of the Corps of Engineers inspection conducted July 25-27, 1979, are documented in Report No. 50-546/79-16.

Report No. 50-546/79-18 documents the results of NRC Region III follow to inspection conducted August 13 and 14 and September 4-7, 1979, relative to the unresolved items identified by the Corps of Engineers in report No. 50-546/79-16.

Report Nos. 50-546/79-06, 12, 13, 15 and 17 document results of routine or surveillance inspections conducted May 29-June 1, August 7-10, August 3-17, August 21-24 and August 27-31, 1979, respectively.

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i DETAILS Persons Contacted Public Service of Indiana (PSI)

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A. Crews, Vice President - Construction

~*R. M. Brown, Construction Project Superintendent

  • I. L. Mc Larty, QA Construction Supervisor S. K. Farlow, Site Design Control Supervisor
  • D. L. Shuter, QC Engineer U. S. Testing boratory D. Lanham, Lab Manager W. Thompson, Field Concrete Testing Supervisor Other Personnel A. M. Weiss, Concrete Technologist, S & L
  • Denotes those present at the September 7, 1979 exit meeting.

Functional or Program Areas Inspected 1.

Follow-up on WES Inspection The following is a list of the items identified as areas of concern by WES on July 25, 26, and 27, 1979 (Report No. 546/79-16; 547/79-16)

in response to the allegations provided to the NRC by Congressman Deckard of Indiana on June 28, 1979. The specific findings related to each and their present status is documented as follows.

(0 pen) Unresolved Item (546/79-16-01; 547/79-16-01):

Cement a.

Sample No.

2 taken on March 6, 1978 exceeded the total alkalies allowed (0.6%) as specified in ASTM C150-73a, Table 1A., " Optional Chemical Requirements".

S & L Specification Y-2850, Section 4.2 requires that only a test for " actual Na 0 content" be performed for each cement

sample. The test for total alkalies which was performed on Cement Sample No. 2 in accordance with ASTM C150-73a and reported is not required by S & L Specification Y-2850. Further, ASTM C150-73a, Table 1A, test for alkalies in Type II cement, footnote d. states that "This limit may be specified when the cement is

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to be used in concrete with aggregate that may be deleteriously

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reactive." Review of the six month aggregate (fine and #57 coarse) test results for Potential Reactivity (ASTM C239)

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revealed that aggregate used at tha Marble Hill rite is not

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potentially reactive, thereby not requiring the test for total alkalies as specified in ASTM C150-73a. The following six month test results for Potential Reactivity were reviewed:

Date Sampled Results (Fine and #57 Coarse Aggregate)

March 1, 1978 Innocuous October 3, 1978 Innocuous

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March 7, 1979 innocuous During the review of the Cement Sample No. 2 test results, the RIII inspector noted the test resulti, for Na 0 content had been

erroneously omitted. This item is considered open pending review of the Na 0 test restats presently being obtained from

UST by PSI for Cement Sample No. 2.

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(Closed) Unresolved Item (546/79-16-02; 547/79-16-02): Three consecutive flyash samples in May and June of 1978 exceeded the 34% maximum for Fineness, No. 325 siete (ASTM C430-75).

The RIII inspector reviewed ICAR No. 1036-19.0 which stated that UST had incorrectly used for calculation purposes the residue retained on the No. 325 sieve as 12.2 percent. The residue on the No. 325 for standard reference material 114m is specified by the National Bureau of Standards as 6.9 percent.

UST Control Tests No. 4, 5, 6, 7, 8, 9, 10 were affected by this error. Tests 6, 7, 8, 9 were addressed in the WES Report No. 546/79-16; 547/79-16. Recalculation of the percent passing the No. 325 sieve for tests 4 through 10, using the correct value of 6.9%, yielded satisfactory test results. All Ccntrol Test reports were amended to these corrections. This item is closed.

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(Closed) Unresolved Item 546/79-16-03; 547/79-16-03): UST Daily Coarse.iggregate (DCA) Sample No. 292-158 failed on June 7, 197S to meet the percent passing requirement for the 1/2" sieve size as required by S & L Specification Y-2722.

The RIII inspector reviewed DCA test report no. 292-158 and confirmed that the material failed to meet the 1/2" sieve requirement of 60% passing.

S & L Specification Y-2850, Amendment 4, Section 406.3 requires that two additional samples be taken if a failure occurs, and both of these retests must pass to approve use of the aggregate. The RIII inspector reviewed the results of retest No. I and 2 for sample DCA-292-

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158 and found both to meet the specification gradation require-a ments. This item is closed.

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(Closed) Unresolved Item (546/79-16-04; 547/79-16-04):1 The

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compressivestrengthloadingrateexceededtheallowab{erate 5!5

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specified in ASTM C39. Further RIII review of this matter indicated it is an item of noncompliance and consequently it will be assigned a new tracking number (see below).

During the WES inspection, the loading rate for the compressive strength testing machine was observed in one instance to exceed the allowed rate of 20-50 pri/sec as specified by AS C39.

Specifically, cylinder Nos. 2360-3 and 2360-4 were observed to

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be broken et 71 psi /sec.

This failure to accomplish activities affecting quality in accordance with documented instructions, procedures, or drawings is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion V.

(546/79-18-01; 547/79-18-01)

Subsequent to the WES inspection, UST generated ICAR No. 1036-53 to assure proper identification and disposition of this occurance.

(0 pen) Unresolved Item (546/79-16-05; 547/79-16-05): The No. 8 e.

(U. S. Standard Sieve) and 3/4" (Gilson) gradation sieves were found to exceed the allowable opening sizes specified in ASTM Ell.

During this inspection, WES personnel determined that the No. 8 sieve (ID #202.0) contained one opening which exceeded the

" maximum individual opening" allowed by ASTM Ell., Table 1.

In addition, the 3/4" sieve (ID #244.0) was observed to contain several loose wires. Both the No.

8 and the 3/4" sieves were used for Category I (safety-related) work.

UST personnel stated that each sieve had met all dimensional requirements at the tir of its last calibration.

ICAR No.

1036-58 was generat;d by UST to assure proper identification and disposi-tion of the sieves. This item remains open pending review of the engineering disposition of ICAR 1036-58.

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(Closed) Unresolved Item (546/79-16-06; 547/79-16-06): ASTM C136 allows no more than 200g of sieved material to be retained on any one eight inch diamteter sieve. Further RIII review of this matter indicated it is an item of noncompliance and conse-quently it will be assigned a new tracking number (see below).

WES personnel found several instances in which the sample fraction retained on a sieve at the completion of the sieving operation weighed more than 4g/sq. in. of sieving surface. This amounts to 200g for the standard eight inch diameter sieve.

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This is a further example of noncompliance as cited previously in Paragraph 1.d. of this report.

(546/79-18-01; 547/79-18-01)

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Subsequent to the WES inspection, UST generated ICAR No. 1036-54 to assume proper identification and disposition of these deficiencies.

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(Closed) Unresolved Item (546/79-16-07; 547/79-16-07): The containers used to perform the Materials Finer Than No. 200 test were not of standard size.

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ASTM C117-69, Section 3.3, states that, "A pan or vessel of a

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size sufficient to contain the sample covered with water and to permit vigorous agitation without loss of any part of the sample or water" will be used. WES inspection personnel stated that the containers presently used by UST for fine and coarse No. 200 wash tests were adequate if proper precautions were taken, but that it was preferable to use larger, deeper containers for sample agitation.

Licensee personnel stated that larger containers will be immediately obtained and used. This item is closed.

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(Closed) Unresolved Item (546/79-16-08; 547/79-16-08): UST is presently using a microwave oven in lieu of the conventional hot circulating air oven.

UST is presently using a microwave oven to dry fine and coarse aggregate moisture samples and fine aggregate gradation samples.

Results of initial and on-going correlations between the conven-tional drying oven and the microwave oven were reviewed.

Approval by S & L for microwave oven drying of aggregate samples for the specified tests was also verified. This item is closed.

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(Closed) Unresolved Item (546/79-16-09; 547/79-16-09): The sample part used in conjunction with the test specified in ASTM C702 exceeded the overall width specified.

ASTM C702 requires that the sample splitter "be equipped with a hopper or straight edged pan which has a width equal to or slightly less than the over-all width or assembly of chutes".

WES personnel stated that the pan presently being used by UST lab personnel exceeded the over-all width by approximately 1/2" and if proper precautions were taken, the existing pan could be used effectively.

In response, licensee personnel stated that smaller pans or hoppers would be immediately obtained and used.

This item is closed.

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(Closed) Unresolved Item (546/79-16-10; 547/79-16-10):

Improper test method for Lightweight Pieces in Aggregate (ASTM C123) is

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being used. Further RIII review of this matter indicated it is

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an item of noncompliance and consequently it will be assigned a new tracking number (see below).

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WES inspection personnel observed UST lab personnel perform the Test for Lightweight Pieces in Aggregate and noted the following:

(1) The specific gravity of the heavy liquid (Zine Chloride)

was not monitored during test with a calibrated hydrometer to verify that it remained within i0.01 of the specified value at all times.

(2) The specific gravity of the heavy liquid (Zine Chloride)

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was not confirmed to he 2.0 as specified by ASTM C33 for the

coal and lignite test which is required by S & L Specification Y-2850, 406.1 f.

Items 1.J.(1) and (2) above, are further examples of noncompliance as cited previously in Paragraph 1.d of this report.

(546/79-18-01; 547/79-18-01)

Subsequently, PSI DCR Nos. C-070-79, C-073-79 and UST ICAR No.

1036-57 have been generated to assure proper identification and disposition of this ncnconformance.

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(Open) Unresolved Item (546/79-16-11; 547/79-16-11): The Forney DR QC 200 Compression Machine was found to be out of tolerance.

During the WES inspection, WES inspection personnel found the DR QC 200 Compression Machine to exceed the 11.0% error allowed for loads within the loading range as specified by ASTM E4.

The specific percent error for each dial indicator at different loads is contained in IE RIII Report No. 546/79-16; 547/79-16.

This item remains open pending resolution of this matter by the licensee.

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(Closed) Unresolved Item (546/79-16-12; 547/79-16-12):

2" grout cube molds are not being pre-treated as specified by ASTM C109. Further RIII review of this matter indicated it is an item of noncompliance and consequently it will be assigned a new tracking number.

ASTM C109 requires that a mixture of three parts of paraffin to five parts of rosin by weight, be applied to "the outside contact lines of the molds and base plates so that watertight joints are effected between the molds and the base plates".

The WES inspectors verified that this requirement was not being met by UST at the Marble Hill site.

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e Thisisafurtherexampleofnoncomplianceascitedpr$viously

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in Paragraph 1.d of this report.

(546/79-18-01; 547/7p-18-01)

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Subsequent to the WES inspection, UST generated ICAR 1036-55 on August 9, 1979.

In response to the ICAR, UST held training classes to emphasize the requirements of ASTM C109 and the S & L Site Design Control Group satisfactorily dispositioned the nonconforming 2" grout cubes. No response to this item is required since the licensee initiated and completed actions to correct the matter and to prevent recurrence.

(Closed) Unresolved Item (546/79-16-13; 547/79-16-13): Field

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cast 2" grout cubes are not being initially cured in accordance e

with ASTM C109, Section 8.5.

Further RIII review of this matter indicated it is an item of noncompliance and consequently it will be assigned to a new tracking number (see below).

S & L Specification Y-2850, Section 411A.I. refers to ASTM C109 which in turn requires that 2" grout cubes should be immediately placed in a moist closet or moist room for storage after casting.

WES inspectors verified that this requirement is not being met by UST a;.6 ".:rble Hill site.

This is a further example of noncompliance as cited previously in Paragraph 1.d. of this report.

(546/79-18-01; 547/79-18-01)

Subsequent to the WES inspection, PSI generated DCR C-069-79.

This DCR in conjunction with FCR No. 867 R, satisfactorily dispositioned the nonconforming 2" grout cubes and took adequate steps to prevent recurrence of this practice. No response to this item is required since the licensee has initiated and completed actions to correct the matter and to prevent recurrence.

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(Closed) Unresolved Item (546/79-16-14; 547/79-16-14): Deckard Allegation No. 4

"The qualifications of U. S. Testing personnel was questioned." Further RIII review of this matter indicated it is an item of noncompliance and consequently it will be assigned a new tracking number (see below).

No direct observation or specific information was obtained that would indicate at the present time that Laboratory Testing personnel are performing tests for which they are unqualified.

Questions were raised in the past concerning qualification of U. S. Tesing Personnel. These are documented as follows:

PSI Audit No. 16-01 of U. S. Testing Company conducted: May 3-4, 1978 at Marble Hill site.

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Finding:

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High school graduates certified to Level I without completing required six months job

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training.

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ProficiencyEvaluationformsmissingfo[rtwo inspectors.

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PSI Audit No.16-02 of UST conducted: July 11-12, 1978 at Hoboken, N.J.

Finding: Training records are missing and some personnel had not received eye examinations.

PSI Audit No.16-03 of UST conducted: May 22-23, 1979 at Marble Hill site.

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Finding: Two inspectors did not receive eye color examinations

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(or documentation missing).

PSI Audit No. 16-04 of UST conducted: July 7-11, 1979 at Hoboken, N.J.

Finding: Two lead auditors were not examined per ANSI N45.2.23, paragraph 2.3.5. (examination to evaluate comprehension and ability to apply required knowledge).

PSI Field Corrective Action Requests (FCAR)

No. 52 - November 14, 1977 - No proficiency evaluation on file or physical and visual test record for several UST inspection personnel.

No. 63 - November 16, 1977 - UST Technicians performing work they are not qualified for.

No. 550 - January 3, 1979 - Physical and visual examinations performed late.

Newberg-Marble Hill Field Nonconformance Reports (FNRs)

No. 68 - July 3, 1978 - QA training documentation lacking in UST personnel files.

No. 92 - December 27, 1978 - No physical and visual examination records on file for some UST technicians. Also no eye charts.

The RIII inspector reviewed the training and qualification records of all past and present Marble Hill UST employees. The records were reviewed for conformance with UST procedures and ANSI N45.2.6. with the following results:

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(1) UST Company Procedure No. UST-TQ-1, Revision 9, states in Section V Paragraph 3.2.

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"To be considered for certification, a candidate pust

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(subject to the conditions of 3.1.2) satisfy one of the following requirements:"

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"(2) High school graduate plus six months of related experience in equivalent testing, examination or inspection activities at power plants, heavy industrial facilities or other similar facilities."

ANSI N45.2.6 - 1973, states in Paragraph 3.1.1 Level I.

"To be considered for certification, a candidate must

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satsify the following requirements:

High school graduate; plus one year of experience in

quality assurance, including testin;, or inspection (or both) of equivalent construction and installation activities.

Contrary to the above, records show that at least seven currently employed inspectors (high school graduates) were certified to Level I requirements with less than eleven days experience.

(See attachment A, Item 1)

Paragraph 3.1.2 of UST-TQ-1, Revision 9 and Paragraph 3.1 of ANSI N45.2.6 are recognized. These paragraphs state in part, that the education and experience requirements specified for the various levels should not be treated as absolute when other factors provide reasonable assurance that a person can competently perform a particular task.

Based on information provided to the inspector the three to ten days experience by the subject UST inspection personnel does not meet the intent of ANSI N45.2.6.

It is very questionable that ten days is sufficient time to obtain the required experience and needed knowledge of the Quality Assurance Program criteria, applicable procedures and instructions (including the identification and processing of nonconformances) specifications, specification changes, and applicable standards.

(2) UST Company Procedure No. UST-TQ-1, Revision 9, states in Section IV, paragraphs 1.5 and 1.6 that Level III personnel are authorized to evaluate and certify Level II and Level I personnel and Level II personnel are authorized to evaluate and certify Level I personnel.

Contrary to the above, records show that on at least four occassions UST Level II personnel evaluated other UST Level II personnel.

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(3)

U. f Testing Company Procedure No. UST-TQ-1 Revision 9, st tes in Section V paragraph 4.1 that the qualification

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procedure shall be determined by oral interview and prac-tical demonstration to evaluate the candidate's proficiency for each level of qualification in each major area of inspection and/or testing which he is required to perform.

Contrary to the above, records show that on at least five occassions U. S. Testing personnel were certified to Level I requirements prior to completion of the interview and s.

practical demonstration of their proficiency.

(See

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(4)

U. S. Testing Company Procedure No. UST-TQ-1 Revision 9, states in Section V paragraph 5.0 that for Level III, II or I personnel, an eye examination for visual acuity and color vision shall be required.

Contrary to the above, records show that on at least two occassions U. S. Testing personnel were certified to Level I requirements prior to receiving the visual examinations.

(See Attachment A, Item 3)

(5)

U. S. Testing Company Procedure No. UST-TQ-1 Revision 9, states in Section V paragraph 7.2 that the examination specified in paragraph V.5.0 (i.e. physical and visual examinations) shall be repeated annually.

Contrary to the above, records show that on at least four occassions the required examinations were overdue for periods up to two months.

(See Attachment A, Item 4)

Items n(1) through (5) above, are further examples of noncompliance as cited previously in Paragraph 1.d of this report.

(546/79-18-01; 547/79-18-01)

The names of specific UST personnel who failed to meet the training req:,irements specified in UST-TQ-1, Revision 9 have been forwarded to PSI for their follow-up action and response to the item of noncompliance.

(6) Further review of UST Company procedures and practices relative to the following is planned for subsequent inspections.

(a) Qualification and certification of inspection personnel.

(b) Verification of applicability of education and previous s

experience to site specific requirements.

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(c) Provisions to maintain qualifications current with requirements and inspection assignments including procedure and specifications changes.

This item is considered unresolved.

(546/79-18-02; 547/79-18-02)

(0 pen) Unresolved Item (546/79-16-15; 547/79-16-15): Deckard o.

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Allegation No. 6

" Reportedly PSI had been made aware of concreting problems in writing and had ignored the notification."

The RIII inspector was unable to specifically locate the documented notification of PSI concerning concrete related problems from any organization other than UST.

In addition to the information in IE RIII Report No. 546/79-16; 547/79-16, the RIII inspector obtained a copy of the minutes of an August 1978 meeting between UST and PSI representatives. Additional follow-up on the concerns addressed in these meeting minutes is planned.

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(Closed) Unresolved Item (546/79-16-16; 547/79-16-16): Deckard Allegation No. 7

"Apparently PSI inspectors were supposed to witness all pours completely and they have not."

Marble Hill Construction Manual, CMP-3.8 - Surveillance of Site Activities Revision 3, Section 4.0, states that, "QA surveillance shall be maintained on, but not limited to, the following:

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concrete placement (including formwork, rebar placement, post placement, etc.)."

The Marble Hill Quality Assurance Manual defines surveillance as:

"The act of verifying the adequacy of inspection work, general conformance of work procedures or adequacy of control process work performanced, checking the work after completion or in process, and/or reviewing documentation to assure that the work is in accordance with specification, procedure, drawing, code, and standard requirements."

CMP 3.8 clearly states that the PSI scope of work does not include 100% inspection of all concrete placements. This item is closed.

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(Closed) Unresolved Item (546/79-16-17; 547/79-16-17):f Deckard q.

Allegation No. 14

"Apparently there have been a large number

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of nonconforn,ances reported in connection with Categorp I columns."

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The RIII inspector reviewed all PSI and N-MH nonconformance reports (NCRs) and found only one report which dealt with Category I columns. N-MH NCR No. 316 concerned five Auxiliary Building columns which were partially exposed to freezing conditions during the required seven day cure period. Due to the general nature of this allegation, the RIII inspector was unable to further specifically address the concern as stated.

This item is closed.

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During the review of PSI and N-MH nonconformance reports, the

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RIII inspector did identify several areas of concern related to the disposition of the reports, including NCR No. 316. This is discussed in detail in Paragraph 2 of this report.

(Open) Unresolved Item (546/79-16-18; 547/79-16-18): The r.

Forney LT-1000 Tensile Machine was found to be out of tolerance.

During the WES inspection, WES inspection personnel found the LT-1000 Tensile Machine to exceed the 1.0% error allowed for loads within the loading range as specified by ASTM E4. The specific percent error for each dial indicator at different loads is contained in IE RIII Report No. 546/79-16; 547/79-16.

This item remains open pending resolution of this matter by the licensee.

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(Closed) Unresolved Item (546/79-16-19; 5/79-16-19): Materials tested for Clay Lumps and Friable Particles (ASTM C142) should be percent retained for each individual sieve rather than cumulative percent passing.

Through observation of test methods, review of C142 test results and interviews with UST lab personnel, the RIII inspector verified that the test for Clay Lumps and Friable Particles is being performed and reported as required by ASTM C142. A subsequent telephone conversation on September 5, 1979 between the RIII inspector and WES personnel revealed that a misunder-standing had led to the original identification of this item in report 546/79-16; 547/79-16. This item is closed.

2.

Review of Nonconformance Reports and Reporting Procedures The RIII inspector reviewed the PSI Field Corrective Action Request (FCAR), Field Nonconformance Report (FNR), Deviation Control Record (DCR), N-MH Nonconformance Report (NCR), and the UST Internal Corrective Action Request (ICAR) logs. Certain reports pertaining to concrete

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activities were selected from each category for review. This review

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included regulatory requirements for the identification and. disposition of nonconforming conditions. The following specifics were pbserved.

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a.

FCAR No. 69 dated December 22, 1977 - This FCAR concerned concrete cylinder specimens which were not cured in accordance with ASTM C31 and ASTM C511.

b.

FNR No. 018, dated February 21, 1978 - This FNR concerned concrete cylinder specimens which were not cured in accordance with ASTM C31 and ASTM C511.

c.

NCR No. 314, dated January 8, 1979 - This NCR concerned portions

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of placement no. ICW-Ext.-1A which were exposed to freezing conditions during the required seven day cure period.

d.

NCR No. 316, dated January 16, 1979 - This NCR concerned portions of placement nos. 2SS-367-B, AC-383-31, AC-383-33, AC-383-54, AC-383-57 and AC-383-59 which were exposed to freezing conditions during the required seven day cure period.

e.

NCR No. 183, dated June 8, 1978 - This NCR concerned fly ash UST Control Test Nos. 4-7 which failed to meet the specification fineness (No. 325 sieve) requirement. This matter was correctly resolved when the actual facts surrounding the nonconforming material became apparent.

(Reference Paragraph 1.b. of this report.)

ANSI N45.2-71. Section 4.4 states that, "It is the intent of this standard that design change be reviewed and approved by the organizations that perform the original design, review, and approval.

In the event that it is not practical for the original organizations to perform the required review or approval, other responsible design organizations may be designated..

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Each case noted above (a. through e.), in effect represents a design change and therefore requires a design organization evaluation.

This evaluation is not evident for the five nonconformance reports which were reviewed.

This failure to assume that design changes are approved by the organization that performed the original design or a responsible designee is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion III.

(546/79-18-03; 547/79-18-03)

It is apparent from this review that contractor nonconformance reports (NCR's and ICAR's) are not assured of disposition by the proper authorities and in the past that PSI FNR's and FCAR's were incorrectly used to identify nonconformances which require the design organization review. These procedural discrepancies as well

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as their effect on past nonconforming conditions are of concern.

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This matter remains unresolved pending further review.

(546/79-18-04; 547/79-18-04)

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Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in the Details Section, Paragraphs 1.n.(6) and 2.

ExitInterview fheinspectorsmetwithsitestaffrepresentatives(denotedunderPersons

' Contacted) at the conclusion of the inspection on September 7, 1979. The inspectors summarized the purpose and findings of this inspection and the inspection conducted by members of the U. S. Army Engineer Waterways Experiment Station. The licensee acknowledged the findings reported herein.

Enclosure: Attachment A i5/S !/6

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ATTACHMENT A Item 1 Previous Date of Date Certified Inspector Education Experience Hire Level 1

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A High School None 7/10/78 7/14/78

B High School None 4/17/79 4/27/79 C

High School None 7/5/78 7/14/78 D

High School None 4/3/78 4/6/78 E

High School None 4/20/78 5/1/78 F

High School None 7/31/78 8/11/78 G

High School None 4/16/79 4/27/79 Item 2 Date Certified Date Proficiency and Inspector Level 1 Evaluation Documented B

4/27/79 5/22/79 H

7/5/78 7/11/78 E

5/1/78 5/5/78 G

4/27/79 5/11/79 I

11/20/78 12/4/78 Item 3 Date Certified Date Physical and Visual Inspector Level 1 Examination Documented J

8/28/78 9/6/78 K

11/29/78 12/7/78 Item 4 Visual Visual Examination Inspector Examination Due Performed L

10/3/77 10/14/77 L

10/14/78 12/18/78 M

10/17/78 12/18/78 N

10/4/77 11/23/77 N

11/23/78 12/18/78

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O 6/8/79 7/6/79 a

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