IR 05000546/1980024
| ML19332A752 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 08/04/1980 |
| From: | Fiorelli G, Harrison J, Schweibinz E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19332A747 | List: |
| References | |
| 50-546-80-24, 50-547-80-24, NUDOCS 8009180221 | |
| Download: ML19332A752 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report Nos. 50-546/80-24; 50-547/80-24 Docket Nos.
50-546; 50-547 License 'los.
CPPR-170; CPPR-171 Licensee:
Public Service of Indiana Post Office Box 190 New Washington, IN 47162 Facility Name: Marble Hill Nuclear Generating Station, Units 1 and 2 Inspection.i : Marble Hill Site, Jefferson County, IN Inspection Conducted: June 24-27, 1980
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E.R.
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9-I-E'O Inspectors:
E. R. Schweibinz ( une 24-26, 1980)
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J. J. Harrison
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J. E. Konklin (June 24-26, 1980)
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! C. Williams Y[9/8e*
Accompanying Personnel:
G. Fiorelli (June 27, 1980)
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J. G. Keppler (June 27, 1980)
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Approved By: G. Fiorelli, Chief Reactor Construction and Engineering Support Branch
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8009180 6 k
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, Inspection Sum 6try
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Inspection on June 24-27, 1980 (Report Nos. 50-546/80-24; 50-547/80-24)
Areas Inspected: Project Quality Assurance manual implimentation; QA/QC Inspection Personnel Qualifications; Project Management Procedures to support receipt inspection; relationship between Project Quality Assurance Manual (PQAM) and the ASME Quality Assurance Manual (AQAM); and a management meeting. This inspection involved a total of 182 inspector-hours en site by eight inspectors.
Results: No items of noncompliance or deviations were id<ntified.
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-DETAILS
. Persons Contacted Public Service of Indiana (PSI) and Management Analysis Company (MAC)
+H. A. Barker, Chairman and Chief Executive Officer
+D. V. Menscer, President and Chief Operating Officer
+*S. W. Shields, Senior Vice President - Nuclear Division
- G. N. Brown, Project Director (MAC)-
- L. O. Ramsett, Quality Assurance Manager
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- C. G. Beckham, Manager, Quality Engineering D. B. Ingmire, Construction Verification Coordinator (MAC)
- C E. Chaielewski, Quality Systems Superintendent -
- J. M. Roberts, Superintendent - Inspection
- T. R. Burns, Project Engineering Manager
- R. J. Kime, Assistant Construction Manager
- J. M. Norris, QA Consultant (MAC)
- R. P. Keele, Superintendent - Quality Administration Authorized Nuclear Inspector (ANI)
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- W. C. Rice, Hartford Steam Boiler (ANI-PSI)
Nutech R. D. Pestorius, Project Manager
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-The inspectors also contacted and interviewed other licensee and contractor i
personnel.
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- Denotes those attending the exit meeting on June 27, 1980.
+ Denotes those attending the management meeting on June 27, 1980.
Licensee Corrective Actions and Restart Program for Marble Hill Background On August 15, 1979, NRC issued an Order Confirming Suspension of Construction of the Marble Hill plant because of numerous noncompliances to construction, construction management, and quality assurance requirements. Since that time,-the licensee has been in the process of.taking corrective actions.
On May 15, 1980, NRC issued a program for the step by step recision of the " suspension" order titled, " Graduated Recission of Order Dated August 15, 1979". The extent of the recision of the " August 15, 1979
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. suspension order" depends on the adequacy of the licensee's. corrective
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actions at each step of the May 15, 1980 " restart program" as determined by NRC.
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1.
Revision of'QA Program Description J
(Closed - initiated by NRR request) A consolidated QA program (QAP)
description was submitted to NRR on April 28, 1980 and supplemented by PSI letter dated May 6, 1980. Based upon review of the consolidated QA program description and it's supplements, NRR and IE have concluded that the revised QAP description is acceptable for use in construction of_the Marble Hill plants. This conclusion was transmitted to PSI by NRR letter dated May 23, 1980. These actions adequately resolve item A. 1.(a) of the May 15, 1980 Graduated recision of the August 15, 1979 order.
2.
Development of Quality Assurance Manual-(PQAM)
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(Closed)' Followup Item (546/80-17-01; 547/80-17-01) As previously
i documented in NRC Report Nos. 50-546/80-17 and 50-546/80-22, NRC RIII has conducted a detailed examination and evaluation of the Marble Hill
Project Quality Assurance Manual. This review included verification
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of the inclusion and adequacy of all requirements of 10 CFR Part 50,
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Appendix B, the related commitments established by the consolidated
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QA program description as approved by NRR by letter dated May 23, 1980.
On June 4, 1980, NRC RIII Management representatives finished a final review of the Marble Hill Project Quality Assurance Manual and-concluded that all applicable requirements have been adequately addressed. This constitutes acceptable resolution of item A.I.(b) of the " Restart Program.
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3.
Development of ASME Quality Assurance Manual (Open) noncompliance (546/79-11-02; 547/79-11-02)
The licensee has developed a Quality assurance program responsive to the requirements of the ASME Code. In December 1979, an ASME Survey Team reviewed this program and found it acceptable to support an interim letter of approval of the quality system described. This is outlined in ASME PSI letter dated January 7, 1980. NRC participated
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in this review. This QA program has been subsequently modified as appropriate, and approved by a " third party" inspection agency and concurred with by NRC RIII.
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In reference-to the ASME interim letter, this QA program is for "N" Certification for " Construction of Class 1, 2, and 3, piping at the Marble Hill Generating Station, Units 1 and 2; New Washington, Indiana'for which overall responsibility is retained and for which fabrication and installation of Class 1, 2, and 3 piping systems is subcontract'ed 'to appropriate certificate of authorization holders".
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NRC RIII also examined the licensee's program and processes for assuring a complimentary interface between the FQAM and the AQAM. This evaluation was found to be exhaustively comprehensive and the results are acceptable.
This entire effort is considered acceptable and constitutes resolution of item A.I.(c) by the " Restart program.
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of Appendix A to IE Report No. 50-546/79-11 (Item 4.b remains open).
Note: The implementation survey'by ASME is scheduled for
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November 1980. "N" certification is pending a successful implemen-i tation survey as determined by ASME.
No items of noncompliance or deviations were identified.
4.
Increase Project Staff Experience Levels (Closed) Noncompliance (546/79-11-01; 547/79-11-01)
a.
Subsequent to the NRC August 15, 1980 Order and the NRC
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identification of insufficient staff and experience levels, the -
licensee has successfully implemented a comprehensive program of reorganizing and manning the key site based organizations for the construction of the Marble Hill plant.
The purpose of this effort was to provide additional management controls andjto provide additional experience.
Key to this effort was the relocation of all principal PSI
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management organizations, construction, project' controls,
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engineering, procurement, and quality assurance at the site.
This effort' was effectively completed in January 1980.
NRC RIII has examined this reorganization as described in the licensee's reports, '= Description of Licensee Activities Addressing Order Confirming Suspension %f Construction", dated February 28, 1980, the " Consolidated Description Quality Assurance Program" dated April 28, 1980. As described in PSI /Stello letter dated' February 28, 1980. NRC has confirmed through ongoing examinations that the corrective actions outlined in PSI letter of March 6, 1980 (in response to NRC Item of non-
compliance involving. quality assurance (No. 546/79-11-01 547/79-11-01))
have been fully implemented. This matter is considered
. resolved.
This constitutes acceptable resolution of item A.I.(d) of the
" Restart Program...."
PSI site based semi professional and professional staff responsible for construction of the Marble Hill site has increased from 78 personsLin June, 1979 to 251 persons in June, 1980.
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Moreover, NRC RIII has confirmed through examination that personnel qualification and experience has increased significantly
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in all key areas. That is, quality assurance / control, construction management, and project engineering. The details of a part of this effort are documented in NRC Report No. 50-546/80-17 and as follows in the paragraphs below.
b.
Personnel Experience and Qualification Verification by NRC RIII Previous RIII Report (50-546/80-17; 50-547/80-17) discussed an RIII evaluation of the qualifications for management and supervisory level personnel involved in the Marble Hill project.
During this followup inspection, NRC inspectors evaluated the education, experience, and training of 35 additional personnel
<specifically associated with receipt inspection and receipt documentation review activities for Marble Hill.
The 35-individuals evaluated during this inspection include 11 persons certified as Level I inspectors, 19 persons certified as Level II, and five persons certified as Level III.
Sixteen of the individuals are certified as documentation reviewers; eight of those 16 are. employed by Sargent and Lundy.
RIII inspectors conducted interviews with five of the 35 receipt inspectors and documentation reviewers, to evaluate their education, experience, training, and knowledge of the work to be performed. The RIII inspectors also reviewed Revision 3 of PHP 3.01, " Qualification and Certification of QA Personnel",.to ensure compatability between PMP 3.01 and the Qualifications of the Marble Hill receipt inspection-personnel.
Revision 3 of PMP 3.01 does not apply specifically to personnel involved only in receipt documentation review activities.
During this inspection, the licensee agreed to include such specific document reviewer qualification requirements in PMP 3.01.
Subsequent to the inspection, the licensee issued Revision 4 of PMP 3.01, which. included appropriate qualification requirements for document reviewers.
RIII inspectors had concerns regarding the qualifications /
certifications for three of the 35 receipt inspectors and
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document reviewers evaluated. The licensee provided additional justification for two of the three persons in question, and changed the certification for the third person from Level II to Level I.
Resed on the additional justification and the certification change, tL P.III inspectors had no further questions.
No items of noncompliance or deviations were identified.
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5.
Receipt Inspection (Closed - follow-up item B.1-B.4 " Restart Program")
The objective-of this part of the inspection was to establish if PSI
has developed a quality program, the necessary project management procedures to implement the program and qualified its staff for receipt insp. ction of PSI procured materials and equipment.
The requirements for this receipt activity are contained in Appendix B to 10 CFR Part 50, the Marble Hill PSAR, the PSI Project Quality Assurance Manual, commitments documented in the booklet titled, " Description of Licensee Activities Addressing Order Con-firming Suspension of Construction" (Brown Book) and applicable codes and standards.
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a.
Project Management Procedures The following Project Management Procedures (PMP) are applicable in whole or part to the control of receipt inspection activities.
These procedures were reviewed and discussed with licensee representatives and were found to be consistent with NRC require-ments and licensee commitments.
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PMP No.
Title Revision 1.00 Organization and Responsibilities
i (General Management)
1.01 Preparation and Control of
Project Management Procedures 1.04 Training
1.07 Control of Nonconformance
i 3.00 Organization and Responsibilities
(Project Quality Assurance)
j 3.01 Qualification and Certification of
Quality Assurance Personnel
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3.02 Supplier and Contractor
Qualification 3.03 Control of Quality Assurance
Correspondence-7-
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~ 3.05 Planning and Preparation of Quality
Assurance Checklists 3.06-Source Surveillance Procedure
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3.07 Receiving Inspection
3.08 Site Construction Inspection
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and Surveillance 3.10'
Stop Work
1 3.12 Quality Verification Records
4 3.13 Audits
3.14 Control of Measuring and
Test Equineent 3.18 File Control and Maintenance of
PDPs and CDPs 3.21 Reporting of Defects and
Noncompliances to the NRC 3.24 Administration.and Control of
Quality Assurance Checklists 3.26*
Preparation and Control of Quality
Assurance Instructions j
5.00 Organization and Responsibilities
(Project Engineering)
5.02 Document Control
J 5.16 Special Process Procedures
1 6.02 Receiving of PSI 'urchased
Material
6.03
_ Storage, Handling and Maintenance of
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Plant Equipment and Materials Interim Change Number 1 Interim Change Number 2 Interim Change Number 3
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- PMP No. 3.26 was being reviewed for approval at the time of the inspection June 24-27, 1980. This procedure provides for the development of QA instructions. These instructions csn apply to receipt inspection in such areas as assuring that site receipt inspection includes any required PSI surveillance inspections that may be waived at the vendor's shop. The draft procedure was reviewed by the NRC inspector and discussed with the licensee's representative. The procedure was considered adequate for the development and control of QA instructions applicable to receipt inspection.
b.
Receipt Inspection and Documentation Checklists Twenty-two receipt inspections and three documentation checklists have been developed as of June 26, 1980, and are identified below. The checklists are reprepresentative of the estimated 150 that will be required to complete receipt inspection. The schedule for development of the remaining checklists is to be consistent with the licensee's
- y wir resumption of receipt inspection activities. A d t4iled review of the 25 completed checklists indicated that chey met requirements. A few minor discrepancies were identified during the review and were dis-cussed with the licensee. These are not considered significant and include such items as inconsistent format, revision number in some cases not included in specification references, type of purge gas not identified, etc. The licensee is in process of taking the necessary corrective action.
Checklist No.
Revision Discipline PRI-001
Mechanical (M)
PRI-002
M PRI-003
Civil (C)
PRI-006
Electrical (E)
PRI-007 E
PRI-008
General (G)
PRI-010
E PRI-011
E PRI-012
E PRI-013
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PRI-014
E PRI-015
E PRI-016
E PRI-017
E PRI-018
E PRI-019
E PRI-020
E PRI-021
E PRI-022
E PRI-023
E PRI-024
E PRI-025
E PDR-009
C PDR-010
G PDR-011
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c.
0ther Considerations Applicable To Receipt Inspection Since August 7, 1979 and in response to NRC confirmatory order dated August 15, 1979, receipt inspections were stopped. However,
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the licensee was permitted to take possession of.and store materials and components shipped to the site. Consequently, there is:a large backlog of material, etc. presently stored at the site.
In order to properly accommodate the transition from the " storage" mode to the " receipt inspection" mode, the licensee has developed an appropriately comprehensive set of procedures and instructions.
Principal among these is one titled, "Intergrated Plan for
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Laydown Area Upgrade Material Storage and Sequential Receipt Inspection"'(Special Process Procedure No. 17, Revision D).
Based on a detailed examination of..the above referenced procedure (SPP-17), discussions with the licensee's representatives, and demonstrations through the " flow charts ~for procurement and receipt activities" as prescribed by Section 7 and 7.3 of the Project Quality Assurance Manual, RIII inspectors conclude that
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all appropriate requirements and considerations have been adequately addressed.
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d.
Personnel Qualification for Receipt Inspection As it is outlined in paragraphs 4.A and B. above, NRC inspectors l
have confirmed through examination, discussion, and independent
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verification that PSI personnel are adequately qualified in accordance with the governing requirements to perform all
required duties in support of the project quality assurance program and-receipt inspection activities.
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Conclusions Based on the review of applicable project management procedures, other documentation, discussions with licensee cognizant personnel, i
observation of stored equipment, and review of staffing and qualification of receipt inspection personnel, it is concluded that adequate provisions are in place for the control of PSI receipt inspection activities.
Items B.1, 2, and 3 of the Restart Program have been satisfied q
and the " Order Confirming. Suspension of Safety-Related Construction"
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can be partially lifted, specifically for receipt inspection.
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6.
Management Meeting
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A management meeting was held at the site on June 27, 1980, to discuss restart plans and schedule with PSI Corporate Management
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o (denoted in the Persons Contacted paragraph) and to confirm that top management was totally comunitted to support quality construction.
Exit Meeting The inspectors met with site staff representatives (denoted in the Persons Contacted paragraph) at the conclusion of the inspection on June 27, 1980.~The inspectors summarized the scope and findings of the inspection.
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