IR 05000546/1981018
| ML20011A695 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 10/16/1981 |
| From: | Harrison J, Hawkins F, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20011A691 | List: |
| References | |
| 50-546-81-18, 50-547-81-18, NUDOCS 8110290299 | |
| Download: ML20011A695 (17) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT
REGION III
Reports No. 50-546/31-18; 50-547/81-18 Docket Nos. 50-546; 50-547 Licenses No. CPPR-170; CPPR-171
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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 Conducted: September 8 and 9, 1981
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J. H 'r(son
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Inspectors gsidentInspector
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Accompanied By:
W. S. Littic, Chief Reactor Projects Section 2C C. C. Williams, Acting Chief Engineering Inspection Branch C '. e t r A -
C C. Williams, Acting-Chief
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Approved By:
Enginee' ring Inspection Branch
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Inspection Summary Special Inspection on September 8 and 9, 1981 (Reports No. 50-546/81-18; 50-547/81-18)
Areas Inspected: Review and observation of all active areas of construction:
Examination of Project management organizations; interrogation of principal project management personnel; review and examination of principal commitments status pun uant to August 15, 1979 order confirming suspension of construction.
The inspection consisted of 64 inspector-hours onsite by four (4) members of the R'gion III inspection staff.
Results: No items of noncompliance or deviations were identified.
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DETAILS A.
Persons Contacted Public Service of Indiana (PSI)
- A. Barker, PSI Chief Executive Officer
- D. Menscer, President
- W. Shields, Senior'Vice President, Nuclear Division
- L. Ramsett, Executive Director, Nuclear Quality Assurar-*
- W. Petro, Executive Director, Nuclear Project Management
- W. Wogsland, Executive Director, Operations
- W. Boshear, Executive Director, Personne)
- T. Burns, Project Engineering Manager
- J. Bott, Nuclear Safety and Licensing Manager Hartford Steam Boiler Insurance Co.
Allen Clark, Authorized Nucl tr Inspector (Certification No. N-2456)
- Denotes those attending the exit interview.
Other members of the licensee's and contractor staff were contacted as a matter of routine during this inspection.
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B.
Functional or Program Areas Inspected This special inspection consisted of a summary review and final assess-ment of the licensee's response to the Order Confirming Sucpension of Construction dated August 15, 1979, in conjunction with the May 15, 1980
" Graduated Recission of Order dated August 15, 1979" (Attachment "B" to this report).
1.
Principally, the actions required by the order and the associated Region III inspection reports were as follows:
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a.
Revise and provide acceptable quality assurance programs in response to 10 CFR Part 50 Appendix B, and the requirements of the American Society of Mechanical Engineers.
b.
Reorganize the project management, construction, engineering and QA organizations, and provide adequately qualified staff in sufficient numbers to support PSI and its contractors'
tanstruction efferts.
c.
Develop and implement material and construction verification progrars to assess the degree of conformance to all pertinent requirements for all existing areas of safety related con-struction and associated materials. Provide a program for the resolutica of all discrepancies uoted, d.
Implement a comprehensive receipt inspection program and-2-
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Successfully resume construction and problem resolution in conformance with the revised and approved organizations, programs, and materials.
2.
Based on the numerous NRC inspections and investigations since August 15, 1979, as outlined in Attachment "A" to this. report, the licensee has satisfactorily accomplished each of the correc-tive actions and commitments established by the order and subsequent NRC/ PSI correspondence.
Attachment "A" to this report is a tabulation'of all Region III inspection reports regarding the licensee's performance in response to the Order beginning with Reports No. 50-546/79-11; 30-547/79-11; including subsequent and relevant reports to date.
Inese inspection records demonstrate the region's review and
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evaluation of each principal corrective action taken by the licensee in response to tha order.
By way of summary, only the major actions and the inspectors'
current evaluations will be discussed in the following paragraphs.
The result of personnel interviews with PSI principal site management is also summarized herein.
3.
General Background The following is a summary and status of the Quality Assurance Programs at Marble Hill beginning with the Stop-Work-Order to the presenc time:
On August 15, 1979 the Nuclear Regulatory Commission (NRC) issued an order to Public Service of Indiana confirming suspension of construction at Marble Hill. Earlier on August 7, 1979 PSI had voluntarily halted all safety related construction ctivities. On February 28, 1980 PSI responded to the Confirmatory Order,-letter S. W. Shields (PSI) to V. Stello (NRC), subject was " Description of Licensee Activities A' dressing Order Confirming Suspension of Cons truction. " Included in this document was a " Revised Quality Assarance Program." On May 15,.1900 the NRC responded to PSI with a document entitled " Graduated Rescission of Order Dated August 15, 1979.".hiw document contained an Appendix (uchedule) outlining specific points requiring action with NRC approval (Hold Points)
prior to proceeding to the next step. This document is shown as Attachment B to this report.
4.
QA Program Considerations At each point in the schedule identified as an NRC hold point, NRC was to conduct a special inspection or series of inspections
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to review-the appropriate procedures and practices for the:
particular operation.
If the NRC determined that the licensee had met satisfactorily all the necessary requirements, a letter of approval was to be written by the Directo of the Office of Inspection and Enforcement (IE) to the licensee to state that-3-i
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the matter had been resolved satisfactorily and to confirm the types of activities which could be restarted. The schedule provided for a revised QA program and hold point as follows.
a.
Revised QA Program Public Service of Indiana (PSI) will accomplish the following actions before any new safety related construction can occur:
(1) Respond to the specific concerns expressed in the Office of Nuclear Reactor Regulation's April 1, 1980 and April 28, 1980 questions relative to the upgrading of the quality assurance program and provide a Consolidated Quality Assurance Program description that includes the licensee's responses '.
(2) Develop a Project Quality Assurance Manual (PQAM).
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(3) Develop an American Society of Mechanical Engineers (ASME) Quality Assurance Manual (AQAM).
(4)
Increase project staff experience levels in accordance with the licensee's submittal dated February 28, 1980.
b.
NRC HOLD POINT: NRC will review the adequacy of Items (2),
(3) and (4) above, and if the adequacy is confirmed, the Director of IE will issue a written statement to that effect to PSI.
5, Licensee's Actions The following addresses the historical and current status of each point by corresponding letter / number designator:
a.
Revised QA Program (1) On April 28, 1980 PSI submitted the revised Chapter 17 to the Preliminary Safety Analysis Report (PSAR) entitled the " Consolidated Description of the Harble Hill Quality Assurance Program" to the NRC (letter S. W. Shields to H. R. Denton dated April 28, 1980).
The NRC approved this document by letter B. J. Youngblood to S. W. Shields dated May 23, 1980. This acceptance is also attested to in NRC Reports No. 50-546/80-24 and No. 50-547/80-24. Since that approval, two changes have taken place affecting organization. NRC notifica-tion was via letters to H. R. Denton from S. W. Shields (PSI) dated February 27, 1981 and August 21, 1981. NRC approval was denoted in letter B. J. Youngblood to S. W. Shields dated May 6, 1981 and the more recent notification is currently under evaluation (NRR advised Region III that these changes are acceptable and that they are in the process of responding to PSI).
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(2) A Project Quality Assurance Manual (PQAM) was developed in early 1980, reviewed by the NRC staff as statused in NRC Reports No. 50-546/80-17; 50-547/80-17 and 50-546/80-22; 50-547/80-22. Final acceptance by NRC is documented in Reports No. 50-546/80-24; 50-547/80-24.
Further acknowledgment attesting to satisfactorily meeting this requirement was also provided by V. Stello letter to S. W. Shields dated July 7, 1980. Four sub-sequent revisions to this program have been required due to reorganization and modification to implementing requirements. Each of.these revisions was reviewed and accepted by the NRC as documented in NRC Reports No. 50-546/80-37; 50-547/80-37, 50-546/80-43; 50-547/80-43; 50-546/81-04; 50-547/81-04, and 50-546/81-16; 50-547/81-16.
(3) An ASME (American Society of Mechanical Engineers)
Quality Assurance Manual (AQAM) was developed in late 1979. This manual was reviewed by an ASME survey team (NRC participated) and found acceptable in December, 1979. Following the survey an ASME Interim-Letter was issued endorsing QA Program approval. The NRC also -
reviewed the AQAM for content and compatability with the PQAM, this was documented in NRC Reports No. 50-546/80-24; 50-547/80-24. An ASME survey team
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(NRC participated, Reports No. 50-546/80-43; 50-547/80-43)
performed an AQAM review and an implementation survey on November 10-12, 1980. The survey results were positive and PSI was awarded their "N" Certificates on January 13, 1981. Since the certificate issuance the AQAM has been revised three times (January 27, March 11,
.and August 10, 1981), each revision was reviewed and approved by the Authorized Inspection Agency. The NRC has also beta performing inspection of ongoing code activities at the site.
(4) PSI has reorganized the project considerably, and effectively. This includes:
(1) Moving the entire Nuclear Division to the Marble Hill Site; (2) re-structuring the organization to manage by contracts; (3) building a team concept of responsibility and performance; (4) increasing staff by numbers, experience and education, and nuclear experience.
Initial staffing was accomplished utilizing contracted personnel (40% of total staff).
Currently, approximately 19% of total staff are con-tracted personnel. This percentage of contracted personnel will probably remain at this level until the job is complete. Most key management' positions have been filled with permanent PSI personnel. The contracted people remaining in these positions (five)
are expected to continue until completion of construc-tion. PSI and its contractors verified backgrounds of
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all personnel (education and experience), this was also verified by the NRC and documented in Reports No. 50-546/80-17; 50-547/80-17 and 50-546/80-24;
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50-547/80-24.
The following tabulation compares the present site staff-
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It should be noted that there has'been a very significant improvement in the ratio of QA/QC to others, the average. experience level and the number of talented personnel presently onsite.
Personnel Data Present Prior to Order Total 2300 1650 PSI 711
PSI-Technical 400
- Cra f t 1200'
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QA/QC PSI 126 40 (18 onsite)
QA/QC Contractors 130
QA/QC Total 256 81 (59.onsite)
Ratio-QA/QC to. total 1:9 1:28 Experience Levels (in years)
Present Prior to Order PSI Div. Mgt.
84 (21 avg.)
(4 Professional Personnel)
PSI Proj. Hgt.
1369 (10.9 avg.)-
-143.(3.8 avg.)-
& Staff (125 Professional-Personnel)
(37 Professional Personnel)
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i PSI QA/QC 949 (9.3 avg.)
168.5 (4.2 avg.).
(102 Professional Personnel)
(40. Professional-Personnel)
6.
Quality Assurance Implementation The overall implementation of the quality program at Marble Hill has been adequate to date. PSI and their contractors not only have completely rewritten, retrained, and adopted a new philosophy in the quality program areas, but have successfully utilized this program to correct old problems and to control' ongoing activities.
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This program has not been free of problems, but tr e problems have -
been properly identified.and' corrected. This corrective action-6-
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has been comprehensive enough to identify the problem, provide proper disposition, and establish measures to prevent recurrence.
The mechanism for documenting these problems has been through the use of the nonconformance, corrective action and audit programs.
The basic program has required some revision as previously noted.
These changes were necessary to remove program inconsistencies and to improve implementation. These changes were made without com-promising program integrity. The NRC reviewed and approved these changes.
The program's further success is exemplified by the quality of work being accomplished in the construction areas. That is, quality awareness has become a vital work controlling element.
A good example of this is demonstrated in the concrete placed
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since the resumption of construction in the civil areas. This concrete has been of high quality, free-of voids and unsound material, with an excellent surface finish. Any problems that were encountered during this activity (preplacement, placement, and postplacement) were identified in process in accordance with the estabiished program. This enabled the goal of a high quality end product. Also, orientation and retraining of personnel has re-established a sense of pride and regular use of good workmanship.
PSI management has been fully supportive of the Quality Program.
This is evidenced by their involvement in meetings being conducted on 2 routine and scheduled basis, prompt resolution of differences, and emphasis on training. This dedication is further exemplified by massive restaffing with qualified (education and related experience)
individuals. And also, in addition to the planned management audits, a number of additional audits by outside firms have been conducted to identify program deficiencies.
Numerous NRC inspection reports issued prior to and during this verification period and following the release for construction activities attest to the program success.
(See referenced reports in Attachment A to this report.)
7.
Civil / Structural a.
Public Service of Indiana was authorized on March 27, 1981, by the Director of IE, to allow Newberg Construction Company to resume civil / structural construction activities. These construction activities were conducted under the August 15, 1979 NRC Order and were principally confined to chipping out and examining existing concrete patches and repair areas and restoration of these items.
Considerable inspection effort has been expended by the Region III office to monitor the restart of the civil /
structural construction activities. The inspection focused on those areas where deficiencies were identified prior to August 15, 1979; namely, the placement of new concrete and-7-
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repair of existing concrete. The results of these inspec-tions are documented in IE Report Nos. 81-06 and 81-12.
The licensee's performance in each area was concluded to be sa tis facto ry.
This construction activity was also subjected to the daily surveillance of the resident inspector.
Additionally, the licensee's Construction and Material Ver-ification Program activities have been extensively monitored.
The specific civil / structural verification program procedures which were inspected are SPP-2, SPP-3, SPP-5, SPP-6, SPP-10, and SPP-13. The results of the final acceptance of each of these SPP's are documented in IE Report Nos. 80-39, 80-34, 80-30, 80-44, 80-44, and 80-36 respectively. Additional review of each SPP is documented in inspection reports listed in At achment A.
Based on these inspections, it was concluded that the licensee had met Verification Program commitments as they relate to the civil / structural program.
As stated in the foregoing paragraphs, the licensee has successfully upgraded its construction and QA/QC Programs, personnel qualifications and number. The current staff and organizations are fully capable of successful civil con-struction activities.
b.
Indepeadent Evaluation of Concrete at Marble Hill On March 25, 1980, NRC committed to provide for an evaluation of the existing concrete structures at Marble Hill Nuclear Generating Station by agents independent of the NRC. To this end, Hamm Engineers, Inc., in conjunction with agents from a local public interest group "Save the Valley", performed an extensive evaluation of the safety related concrete structures at the site.
The interim report of this evaiuation documented on March 10, 1981, concluded in summary that "...the concrete quality of internal concrete in the structures is acceptable."
The final report entitled " Review of the Evaluation of Concrete at Marble Hill Nuclear Generating Station Units 1 and 2, Report No. IE-124," was dated and issued on June 25, 1981.
This final report agreed in summary with the interim report, that the internal concrete quality was acceptable; however, concrete placement failed in numerous instances to meet requirements as exhibited by the external condition of the concrete, neces-sitating significant amounts of repair.
(Note: The subject Independent Agents report is presently in the appropriate Public Document rooms.)
Subsequent to the issuance of the subject report major new concrete placement was initiated under the surveillance of Region III inspectors. As stated above, this activity has met all requirements of the construction management and QA programs.
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8.
Marble Hill - American Society of Mechanical Engineers (ASME) Issues As previously reported, numerous nonconformances to the requirements of the ASME Code were identified at the site as initially reported in National Board of Boiler and Pressure Vessel Inspector's' findings documented in their report dated July 10, 1979. As a result of an enormous effort on the part of the licensee under the regulation of the State of Indiana Boiler and Pressure Vessel Board and the NRC, all of the previously identified nonconformances (programmatic and material) have been successfully and appropriately resolved.
During this inspection, the NRC inspectors interviewed the third party (Authorized Nuclear Inspector - ANI) at the site.
He reported in summary, that the licensee is currently in full com-pliance with the code and that the code related functions at the site are proceeding normally.
The ANI is contracted from the Hartford-Steam Boiler Company. The licensee is presently maintaining a valid N stamp as reported in Paragraph 5.a.(3) above.
(See Attachment "A" for historical reports on this matter.)
9.
Final Review - Construction and Material Verification Program By way of summary the inspectors reviewed the current status of the subject program in terms of the success of the ongoing corrective action. No unaddressed problems or issues were disclosed or reported.
The specific areas of the program addressed were:
a.
SPP-2 - Category I Reinforcing Steel (see Attachment "A" Reference Report No's. 81-08, 80-09, 80-11, 80-13, 80-16, 80-20, 80-22, 80-25, and 80-39).
b.
SPP-3 - Category I Structural Steel (see Attachment
"A" Reference Report No's. 80-08, 80-15, 80-17, 80-20, 80-22, 80-25, and do-34).
c.
SPP-4 - In-Place Category I Piping and Hangers (see Attach-ment "A" Reference Report No's. 80-15, 80-18,.80-2(, 80-22, 80-23, 80-25, 80-28, and 80-35).
d.
SPP-5 - Category I Concrete Surface Irregularities (see Attachment "A" Reference Report No's. 80-06, 80-08, 80-09, 80-11, 80-13, 80-20, 80-28, and 80-30).
SPP-6 - Mechanical (Cadweld) Splices (see Attachment "A" c.
Reference Report No's. 80-16, 80-21, 80-22, 80-25, 80-28, 80-30, and 80-44).
f.
SPP-7 - Procedure for Physical Inspection and Verification of Previously Accepted Purchased Items-(see Attachment "A" Reference Report No's. 80-17, 80-22, 80-23, 80-24, 80-25, 80-28, 80-31, and 80-40).
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SPP-8 - In-Place Category I Buried and Embedded Piping (see Attachment "A" Reference Report No's. 80-15, 80-23, and 80-35).
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SPP-10 - Checking of Category I Backfill Data (see Attachment "A" Reference Report No's. 80-06, 80-16, and 80-44).
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SPP-11 - Document verification for containment liners, fuel and refueling pool liners and miscellaneous field erected tanks (see Attachment "A" Reference Report No's. 80-26 and 80-35).
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SPP-12 - Document Verification Procedure for ASME Section III Piping, Hangers and Materials (see Attachment "A" Reference Report No's. 80-23, 80-26, 80-28, and 80-35).
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SPP-13 - Category I Concrete Pour Package, Concrete Constituent Materials and Embedded Metals Records Review (see Attachment "A" Reference Report No's 80-21 and 80-36).
The subject verification program is fully complete and the ongoing corrective actions were found to be adequately supported by the construction and quality organizations.
Revision to the Construction and Material Verification Program Final Report, issued May 15, 1981, were found to be acceptable as documented in IE Report No. 81-12.
Notes: SPP is an acronym for Special Process Procedure. The references in Attachment "A" provide the previous report iden-tification, wherein more details are provided.
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10.
Sustained Acceptable Construction Performance The first safety related activity authorized by NRC was Receipt inspection on July 7, 1980. Receipt inspection activity has continued in conformance with the requirements since that time.
On March 27, 1981, PSI was authorized to resume safety related
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concrete construction and in April 1981, placement of major safety related concrete was initiated. Region III has determined through inspection that all restart activities authorized by the Director, l
I&E, have been initiated and sustained in substantial conformance to the requirements; and subsequent construction has been accept-able.
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11.
Summary of Interviews with Principal Site Management During this inspection the Region III Inspection Program managers
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conducted indepth interrogation of principal PSI site managers
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regarding their role in the management of their respective site organizations, their relationships with other site organizations, their plans and expectations regarding their program respon-sibilities, their opinions regarding the effectiveness of the site orgar.ization as a whole, and the issues they considered to be currently the most critical relative to ongoing success in their work.
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The interviewees were very candid and forthright in their response and indicated that they were encouraged to be so by all seuior management officials.
In summary it is the conclusion of the Region III representatives that the site managers have a thoroughly comprehensive cammitment
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to quality construction and engineering, and it is their' clear understanding that seaior management fully supports this con-
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sideration. Moreover each of the principal managers demonstrated exceptional personal qualifications for their assigned-task and a clear understanding as to their relationship to the whole i
construction effort. Further, each had clearly identified
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responsibilities, goals and plans to effectively achieve th'em.
A salient understanding of the past problems and t.he current and future issues was demcastrated by each of the interviewees.
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The following site managers were individually and privately
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interviewed:
a.
W. S. Shields, Senior Vice President, Nuclear Division b.
L. Ramsett, Executive Director, Nuclear Quality Assurance c.
W. Petro, Executive Director, Nuclear Project Management d.
W. Boshear, Executive Director, Personnel 12.
Summary Findings of This Special Inspection c
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As a result of this inspection and the extensive inspection y_
(previously documented - see Attachment "A") of the Marble Hill'^
Construction Site, it is Region III's conclusion that PSI nas adequately implemented its commitments made in response to th'ei
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August 15, 1979 Order Confirming Suspension of Construction and
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the related conventions and agreements in accorda ce with the NRC document entitled " Graduated Recission of Order dated August 15, 1979.
13.
Exit Interview The NRC inspection staff met with the licensee representatives (denoted in Persons Contacted paragraph) during and at the con-clusion of the inspection. The inspectors summarized the scope and conclusions of the inspection.
During the exit interview the NRC spokesman recounted to the PSI Chief Executive Officer, Mr. A. Barker, the significant degree that PSI Corporate policy contributed to the problems that led to the issuance of the August 15, 1979 Crder.
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regard, Mr. Barker was questioned about changes in genera 1
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corporate policy to provide continuing support of their n,uclear
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power commitments.
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In summary, Mr. Barker responded that his organization is now appropriately sensitive to the needs of their nuclear power
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objectives as demonstrated by the reorganization, restaffing,
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and relocatic,n.of' principal personnel to the construction site.
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Further, he submitted that within the bounds of responsible
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management,;the corporate policy and procedures impacting
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IE Inspection Repcrt No. 50-546/81-18 and 50-547/81-18 ATTACHMENT "A" PEPORT SUMMARY OF ACTIVITIES WITH REGARD TO AUGUST 15, 1979 ORDER, NO.
AND MAY 15, 1980 GRADUATED RESCISSION TO THE ORDER.
79-11 Provide basis for the order.
79-12 Observation of compliance with stop work order issued by PSI.
79-13 Observation of work activities regarding compliance with the order.
79-14 Meeting to discuss centent of the ORDER.
79-15 Observation of work activities regarding compliance with the order, and concrete patch removal and testing.
79-16 Review of U. S. Testing Laboratory and field testing procedures, and allegations received through Congressman Deckard of Indiana.
79-17 Observation of work activities regarding compliance with the order.
79-18 Followup on items identified in Report No. 79-16.
79-19 Observations of concrete coring work, and issues identified by
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the National Board of Boiler and Pressure Vessel Inspectors.
79-20 Activities with regard to off-loading the Unit 2 reactor pressure vessel.
79-21 Observation of work activities regarding compliance with the order.
79-22 Observation of work activities regarding compliance with the order.
79-23 Observation of work activities regarding compliance with the order.
Review of licensee actions relative to the control of IE Bulletins and IE Circulars.
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79-24 Meeting to discuss the development of the licensee's response to
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the order and the revised Marble Hill project organization.
79-25 Observation of work activities regarding compliance with the order.
Review of adequacy of storage and maintenance of material and equipment.
79-26 Review af civil QA implementing procedure relative to defective concrete repair.
79-27 Observation of work activities reg'arding compliance with the order.
Rcview of storage and maintenance activities.
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79-28 Meeting to discuss Construction Verification Program, and a concern raised by Congressman Moffett.
79-29 Seminar concerning past problems encountered at other sites in the
. electrical, instrumentation, and related QA areas.
80-01 Observation of work activities regarding compliance with the order.
Followup and closeout of a concern raised by Congressman Moffett and referenced in report No. 79-28.
80-02 Review of licensee report in response'to Item 1 of 06-27-79 IAL and observation of preliminary waterproofing work in the Auxiliary Building.
80-03 Observation of work activities regarding compliance with the order.
Review of storage and preservation activities for material and equipment.
80-04 Investigation into allegations of improper practices and falsification of records by site concrete testing laboratory.
80-05 Meeting to discuss the development of the Construction Verification Program.
80-06 Review of activities with regard to SPP-5 and SPP-10.
80-07 Meeting to discuss preliminary response to the nine issues identified in the Order.
80-08 Review of activities with regard to SPP-2, SPP-3, and SPP-5.
80-09 Observation of work activities regar'ing compliance with the order.
d Review of storage and maintenance activities. Observation of activitiea with regard to SPP-2 and SPP-5.
80-10 Review of electrical installation activities performed prior to the order.
80-11 Observation of activities with regard to SPP-2 and SPP-5.
80-12 Meeting to discuss the licensee's proposed restart program and the proposed method for resumption of receipt inspection.
80-13 Observation of work activities regarding compliance with the order.
Review of storage and maintenance activities. Observation-of activities with regard to Siv-2 and SPP-5.
80-14 Review of installed safety related piping.
80-15 Observation of activities with regard to SPP-3, SPP-4, and SPP-8.
80-16 Observation of activities with regard to SPP-2, SPP-6, and SPP-10.
80-17 Review of Project Quality Assurance Manual (PQAM), personnel qualifications, and activities with regard to SPP-3 and SPP-7.
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80-18 Observation of activities with regard to SPP-4.
80-19 Review of envirr amental monitoring program.
80-20 Observation of work activities regarding compliance with the order.
Review of storage and maintenance activities. Observation of activities with regard to SPP-2, SPP-3, SPP-4, and SPP-5.
80-21 Follow-up on June 27 and July 23, 1979 Immediate Action Letters.
Obsecvation of activities with regard to SPP-6 and SPP-13.
80-22 Observation of work activities regarding compliance with the order.
Observation cf storage and maintenance activities. Observation of activities with regard to SPP-2, SPP-3, SPP-4, SPP-6, and SPP-7.
Review of the Project Quality Assurance Manual.
80-23 Observation of activities with regard to SPP-4, SPP-7, SPP-8, SPP-11'
and SPP-12.
80-24 Review of Project Quality Assurance Manual and its implementation, QA/QC inspection personnel qualifications, and Project Management Procedures to support receipt inspection.
80-25 Observttion of work activities regarding compliance with the order.
Observation of storage and maintenance activities. Observation of activities with regard to SPP-2, SPP-3, SPP-4, SPP-6, and SPP-7.
80-26 Observation of activities with regard to SPP-11 and SPP-12.
80-27 Meetings with independent concrete consultant team.
80-28 Observation of work activities regarding compliance with the order.
Cbsecvation of storage, naintenance, and receipt inspection activities. Observation of activities with regard to SPP-4, SPP-5, SPP-6, SPP-7, and SPP-12.
80-29 Observation of nondestructive examination activities.
80-30 Observation of activities with regard to SPP-5 and SPP-6. Meeting with independent concrete consultant team.
80-31 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities. Observations of activities with regard to SPP-7.
80-32 Observation of work activities regarding compliance with the order.
80.-33 Observation of activities with regard to electrical contractor.
80-34 Observation of activities with regard to SPP-3.'
80-35 Observation of activities with regard to SPP-4, SPP-8, SPP-11, and SPP-12.
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80-36 Observation of activities with regsrd to SPP-13.
80-37 Cbservation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities.
80-38 Observation and review of the revised document control system.
80-39 Observation of activities with regard to SPP-2, the civil inspection and testing services laboratory, and the electrical contractor.
80-40 Observation ot' activities with regard to SPP-7. Management meeting to discuss the following: Material and Construction Verification Program; the independent concrete consultant team assessment; and the ASME Code Survey.
80-41 Observation of work activities regardir.g compliance with the order.
Observation of storage, maintenance, and receipt inspection activities.
80-42 Review of the QA Program for the Piping / Mechanical Contractor.
80-43 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities.
Review of revisions to the Project Quality Assurance Manual.
80-44 Observations of activities with regard to SPP-6 and SPP-10. Review of Newberg-Marble Hill QA Manual, procedures, and program implementation.
80-45 Management meeting with regard to the Systematic Assessment of Licensee' Performance (SALP).
80-46 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities.
81-01 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt intpection activities, and construction activities by the piping, mechanical and electrical contractors.
81-02 Resolution of NRC questions with regard to the adequacy of inplace concrete.
81-03 Observation of work activities regarding compliance with the ccder.
Observation of storage, maintenance, and receipt inspection activities, and construction activities by the piping, mechanical and electrical contractors.
81-04 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities, and construction activities by the piping, mechanica1'and electrical contractors. Review of revisions to the Project Quality Assurance Manual.
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81-05 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, &nd receipt inspection activities, and construction activities by the piping, mechanical, electrical and civil contractors.
81-06 Observation of activities with regard to the resumption of safety-related concrete placement and concrete repair.
81-07 Followup on items reported per 10 CFR 50.55(e) requirements.
81-08 Followup on items reported per 10 CFR 50.05(e) requirements.
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81-09 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities,
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and construction activities by the piping, mechanical, electrical and civil contractors.
81-10 Observation of work related to the corrective actions for SPP-6, and inprocess concrete repair activities.
Investigation of allegations of improper waterproofing activit ies.
81-11 Observation of work activities regarding compliance with the order.
Observatica of storage, maintenance, and receipt inspection activities, and construction activities by the piping, mechanical, electrical and civil contractors.
81-12 Observation of concre te repair activities. Review of the revised Constraction and Katerial Verification Program, Final Report.
81-13 Observation of work activities regarding compliance with the order.
Ob :ervation of storage, maintenance, and receipt inspection activities, and construct * n activities by the piping, mechanical, electrical and civil contractors. Followup on items reported per 10 CFR 50.55(e) requirements.
81-14 Observation of electrical activities.
81-15 Followup on items reported per 10 CFR 50.55(e) requirements and licensee actions with regard to IE Bulletins and IE Circulars.
81-16 Observation of wcrh activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities, and construction activities by the piping, mechanical, electrical and civil contractors. Review of r(visions to the Project Quality Assurance Manual.
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IE Inspection Report No. 50-546/81-18 and 50-547/81-18 ATTACHMENT "B"
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION j.
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&!AY 1 5 1980
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Docket Nos.
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Public service Company of Indiana ATsN: Mr. S. W. Shields Vice President - Electric System 1000 East Main Street Plainfield, India w 46168 Gentleoen:
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Plea'se find enclosed a document entitled Graduated Rescission of Order Dated August 15, 3S79, which prescribes a graduated rescission process for implemen-tation at the Marble Hill Nuclear Generating Station, Units 1 and 2.
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Sincerely,
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Victor Stdllo,
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Director
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Office of Inspection and Enforcement
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Enclosure:
Graduated Rescission of 7.j o g ; O g k_
G'j Order S
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J CERTIFIED MAIL RETURN RECEIPT REQUESTED _
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UNITED STATES OF AMERICA
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!iUCLEAR REGULATORY COMMISSION In the Matter of
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DockEtNos.
50-546
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PUBLIC SERVICE COMPANY OF INDIANA
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50-547 (Marble Hill Nuclear Generating
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Station,' Units 1 and 2
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l GRADUATED RESCISSION OF ORDER DATED AUGUST 15, 1979
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The Public Service Company of Indiana (PSI or licensee) is the holder of
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Construction Permit Nos.
CPPR-170 and CPPR-171 issued on April 4, 1978.
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These permits authorize in accordance with their provisions construction of the Marble Hill Nuclear Generating Station, Units 1 and 2.
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NRC inspection findings during the spring and summer of 1979, which were based in part on allegations by construction workers at the site and the results of inspections by the National Board of Boiler and Pressure Vessel Inspectors, raised 'significant questions as to the adequacy of the ifcensee's quality assurance program at the Marble tiill facility.,As a result of these findings, the licensee stopped work August 7,1979, on all safety related construction at p
This action was confirmed by an Order Confinning Suspension of the site.
s Construction issued by t.he NRC on August 15, 1979.
The Order provided that the licensee shall not resume' safety related construction activities on the Marble
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Hill Units 1 and 2 nuclear power station until such time as (1) the licensee submits in writing under oath to the Director, Office of Inspection 'and C
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O Enforcement, a description of a revised quality assurance program and of
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the steps taken to assure that safety related construction will be conducted in accordance with Appendix B of 10 CFR Part 50 of the Commission's regulations cnd (2) the Director has confirmed in writing that reasonable assurance. exists
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that safety related construction activities will be conducted in accordance with such requirements.
Such confirmation may extend in whole or in part to the suspended construction activities.
Nine different areas were identified as matters to be considered by the Director in reaching a determination concerning the licensee's proposed corrective actions.
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Since the issuance of the Order, numerous meetings and discussions,have been (
f held between the licensee *s management and the NRC staff regarding the licensee's planned corrective action.
A public meeting concerning the licensee's proposed corrective actions was held in Madison. Indiana on March 25, 1980.
The licensee l
l formally replied to the Order with a report entitled " Description of Liceruee Actions Addressing Order confirming Suspension of Construction" dated February 28, 1980. This report addresses the appropriate matters identified in the Order of August 15, 1979.' The staff has concluded that th'e report properly addresses the matters identified in the Order, and that it provides an adequate basis for partial resumption of the construction program.
To assure that the licensee's
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corrective. actions are implemented and effective, it is appropriate that construction activities gt the Marble Hill site resume in a graduated, step-wise fashion with, review by the NRC at appropriate stages.
Accordingly, the
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attached schedule (Appendix) provides for the completion to the satisfaction of the Director, Office of Inspection and Enfo'rceme'nt, of a numb'e'r of items before construction may resume in its entirety at the Marble Hill site.
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In view of the foregoing, and pursuant to the provisions of my Order of
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t'his is to confirm that the graduated rescission process August 15, 1979, prescribed in the Appendix hereto affords reasonable assurance that safety related construction activities will be conducted in accordance with requirements. -
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FOR THE NUCLEAR REGULATORY COMMISSION
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Victor Stelit, J
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Director Office of Inspection and Enforcement Effective date: MAY 15 1980
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Enclosure:
Appendix
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APPENDIX
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RESTART PROGRAM FOR MARBLE HILL UNITS 1&2
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WITH NRC HOLD P0lN15
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V At each point in this schedule identified as an NRC hold point, NRC Gill conduct a special inspection or series of inspections to review the ap-propriate procedures and practices for the particular operation. ~ If the NRC determines that the licensee has met satisfactorily all the nei:essary requirements, a letter of approval will be written by the Director of the Office of Inspection and Enforcement (IE) to the licensee to state that the matter has been resolved satisfactorily and to confirm the types of activities which may be restarted.
A.
Revised QA Program
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Public Service of Indiana (PSI) will accomplish the followin
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actions before any new safety related construction can occur:g
(a) Respond to the specific concerns expressed in the Office of Nuclear Reactor Regulation's April 1,1980 and April 28, 1980 questions relative to the upgrading of the quality assurance program and p ovide a Consolidated Quality Assurance Program desetiption that includes the licensee's
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responses.
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(b) Develop a Project Qua'lity Assurance Manual (PQAM).
(c) Develop an ASME Quality Assurance Manual (AQAM).
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(d) Increase project staff experience levels in accordance with the licensee's submittal dated February 28, 1980.
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NRC HOLD POINT:
NRC will review the adequacy of items b', c and d above, and if the adequacy is confirmed, the Director of IE will issue a written statement to that effect to PSI.
B.
Receipt Inspection
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PSI will develop project management and other related procedures
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and will qualify its staff for receipt inspection.
2.
NRC HOLD POINT:
NRC will review PSI's girogram, procedures, and staffing for receipt inspection.
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If the results of the NRC's review are satisfactory, PSI may resume receipt inspe::tlon upon written notification from the Director of IE.
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PSI will start receipt inspection and retain administrative
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custody of the equipment and materials.
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I Each contractor will make adjustments as necessary to its QA program, precedures, and staff-ing for receipt inspection 5.
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PSI managament will review and approve the above adjustm
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d receipt inspection for each contractor as requi 6.
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of the adjustments.
l NRC will review the adeouacy of the adjustments NRC HOLD POINT:
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noted in item B.S and B.6.
If the r,esults of the NRC's review are satisfactory, contractors i
and within the subject discipline may start receipt inspect on,
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storage and maintenance of PSI equipment and materials upon The four main written notification from the Director of IE.
Civil / Structural; Mechanical; Electrical; and disciplines are:
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Piping.
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Material Verification Program - Currently in progress and may
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accor-plished in parallel with Receipt Inspection.
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PSI will complete appropriate project management and spec Program process procedures and conduct a Material Verification 1.
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for all disciplines.
PSI management will review and approve the Material Verifi i
Ill tion Program results and inform the Director of NRC Reg on
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in writing of the tcsults.
NRC will review the material verification y
in each NRC HOLD POINT:
efforts of PSI and confirm adequacy of the program 3.
discipline.
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Construction Verification Program - Currently in progress an
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accomplished in parallel with Receipt Inspection.
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es, PSI wil'1 complete appropriate pro' ject mana
.ifica-1.
-f tion Ptogram.
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fi-PSI canagement will review and approv
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III in writing of the results.
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HRC HOLD POINT:
The NRC will review the construction verification efforts of PSI and confirm the adequacy of the pro 3 ram in each discipline.
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NRC HOLD POINT:
NRC will review PSI's program and its implementation as discussed in B, C, and D above for all disciplines.
If the adequacy is confirmed, the Director of IE will issue written notifica-tion to proceed as described in Item 2 below.
2.
Contractors' Program Adjustments Each contractor will adjust its QA program, procedures, and a.
staffing to be consistent with PQAM, AQAM, and other PSI pro-
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gra,e requirements for each discipline.
a Ps1 management will review and approve the above adjustments b.
for each discipline and inform the Director of,NRC Region III in writing of the adjustments.
3.
HRC HOLD POINT:
The NRC will review the program adjustments for a particular discipline and the Director of IE will provide written notification that construction activities in a particular discipline may proceed in whole or in part if the adjustments are acceptable.
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