ML17053D112
| ML17053D112 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/17/1982 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17053D110 | List: |
| References | |
| 50-410-81-13, NUDOCS 8204200470 | |
| Download: ML17053D112 (10) | |
Text
APPENDIX A NOTICE OF VIOLATION Niagara Mohawk Power Corporation Nine Mile Point, Unit 2 Docket No.
50-410 License No.
CPPR-112 As a result of the inspection conducted on November 30-December 18,
- 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),
the following violations were identified:
l.
10 CFR 50, Appendix B, Criterion I, states in part:
"The applicant shall be responsible for the establishment and execution of the quality assurance program.
The applicant may delegate to others, such as contractors,
- agents, or consultants, the work of establishing and executing the quality assurance program, or any part thereof, but shall retain responsibility therefor" and "The quality assurance functions are those of (a) assuring that an appropriate quality assurance program is established and effectively executed and (b) verifying, such as by checking, auditing, and inspection, that activities affecting the safety-related functions have been correctly performed."
Contrary to the above, as of December 18,
- 1981, the Construction Assessment Team inspection identified quality assurance program deficiencies and/or weaknesses in several areas which considered collectively, constitute an inappropriate and ineffectively executed quality assurance program.
Examples include:
Cives Steel Corporation was not placing material in a hold area, nor were Stores Requisitions being written to withdraw items from storage.
Material was being withdrawn by Cives construction personnel without stores requisitions, and therefore without issue authority given by designated personnel.
b.
There is a significant lack of training given to contractor personnel, especially in regards to procedures, holdpoints, and inspection require-ments.
Stone
& Webster requires certain major contractors to comply with the S&W QA Program but does not have a formalized training program to ensure contractor personnel are aware of QA Program require-ments that directly interface and affect construction activities.
Numerous nonconformances have resulted from contractor personnel being unaware of QA Program controls.
C.
There is an overdependence on contractor construction personnel to monitor quality related activities.
This reliance was identified in the structural steel inspection
- program, concrete inspection
- program, material
- release, and control of measuring and test equipment.
Contractor construction personnel were relied upon to verify that weld preparations and fit-ups were in accordance with AWS 1.1, while Stone
& Webster's QA Program required only random inspections by the S&W quality control personnel of weld preps and fit-ups.
Numerous concrete
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Appendix A placements were checked by contractor construction personnel,
- only, for proper curing in accordance with Stone
& Webster Specification NMP2-S203C, Revision 6.
Cives Steel Corporation construction personnel were relied upon to issue material for erection, contrary to material control procedures.
The stor'age and handling of measuring and test equipment was the responsibility of construction crews, without training on proper handling and storage, and without documented monitoring, survei llances and/or audits to ensure proper controls.
d.
Nonconformances are not analyzed for cause at the time they are identi-fied, as to why the nonconformance occurred or what corrective action needs to be taken to prevent further recurrence.
- Rather, they are solely resolved on the technical acceptability, rework, repair, or scrap disposition, without regard to the basic cause of the noncon-formance.
The lack of identification and correction of the root cause of the nonconformance has led to numerous nonconformances being written in a short period of time involving the same functional area, such as the concrete curing nonconformances referenced in inspection report 410/81-12.
The lack of attention to the root cause can also be seen in nonconformances referenced in Sections 2.2.2.2 and 4.1.2.2.2 of the enclosed inspection report.
e.
There is a significant problem in the timeliness of corrective action resulting from Stone
& Webster responses to Niagara Mohawk audit findings.
Determination of corrective action to be taken is repeatedly delayed due to either belated answers by Stone
& Webster and/or inadequate responses by Stone
& Webster.
NMPC guality Assurance Management has been unable to correct the problem.
f.
Sections 2.1 and 2.2 of the Project Manual, which are to provide functional roles and position descriptions for NMPC and S&W, have not yet been issued.
In the interim, most S&W personnel have not seen and/or were not aware of the position descriptions for their jobs.
In many situations, responsibilities, authorities and interfaces were based upon verbal understandings with management.
Without these sections of the Project Manual, functional responsibilities of groups and duties and responsibilities of key positions within each group are not adequately covered by existing written policies and/or procedures.
Furthermore, Niagara Mohawk Power Corporation Management has contributed to the inappropriate and ineffectively executed quality assurance program through a lack of adequate management support for, and attention to, the quality assurance function.
Management policies and practices have resulted in inequitable pay and fringe benefits for cer tain onsite gA personnel; actions which have in effect banned a gA staff member from the site; acquiescing to a high turnover rate in the gA staff, thereby diminishing the capability of the assigned gA staff, due to a lack of continuity and project specific experience, to identify and resolve quality related problems; exercising ineffective management control over its agents and contractor to promptly initiate corrective actions for identified quality problems in OFFICIAL RECORD COPY
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Appendix A project management, engineering, and/or construction; and by not providing a clear and effective enumeration of policies regarding the proposed Project guality Organization to avoid confusion in the perceived responsibilities of existing and proposed gA organizations,
- hence, degrading the effectiveness of total quality assurance effort on the project.
This is a Severity Level IV Violation.
(Supplement II) 2.
10 CFR 50, Appendix B, Criterion III, states in part:
"Measures shall. be established to assure that applicable regulatory requirements and design basis
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- drawings, procedures and instructions."
and "The design control measures shall provide for verifying or checking the adequacy of design... performed by individuals or groups other than those who performed the original design,...
Design
- changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design..."
Stone and Webster Engineering Corporation Standard guality Assurance Program-SWSgAP, Section 3, Paragraph 1.5, states in part:
"Design control measures shall include review and use of accepted industrial standards and practices,
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- parts, equipment or processes that are essential to the functions of structures, systems or components,"
and Paragraph 1.6, states:
"Engineering drawings shall be reviewed by an individual other than originator, for adequacy of design."
- SWSgAP, Appendix III, Glossary, states in part:
"Verify - The act of proving that a function or requirement has been met by examining objective evidence..."
Contrary to the above, as of December ll, 1981:
a.
There was no objective evidence to show that the requirements of standard ACI-318-71 were objectively used as design inputs in the analysis of the effect of rebar substitution.
b.
There were no engineering calculations to confirm the adequacy 'of the design change nor was there any objective evidence of an independent design verifications 3
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c.
There was no objective evidence to show that an adequate engineering review was done to assure that consistent cable tray separation criteria were specified and translated into erection specifications.
This is a Severity Level IV Violation (Supplement II).
10 CFR 50, Appendix B, Criterion VII states, in part, that:
"Measures shall be established to assure that purchased
- material, equipment and
- services,
~ ~.conform to the procurement documents'
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Appendix A Line 291-294 of Specification E026-A states, in part, that:
j"Except as specifically stated or otherwise infer red, the cable tray shall conform to the requirements of NEMA Standard VE-l."
Contrary to the above, the cable tray qualification test report No.
24781 does not address the test requirements as specified in the procurement specification E026-A.
This is a Severity Level V Violation.
(Supplement II)
Pursuant to the provisions of 10 CFR 2.201, Niagara Mohawk Power Corporation is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as
- amended, this response shall be submitted under oath or affirmation.
Mhere good cause is shown, consideration will be given to extending your response time.
The responses directed by this Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Dated JgR g p ]gg~*
T. T. Martin, Director Division of Engineering and Technical Programs OFFICIAL RECORD COPY
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APPENDIX B
SIGNIFICANT OBSERVATIONS Niagara Mohawk Power Corporation Nine Mile Point, Unit 2 Docket No.
50-410 License No.
CPPR-112 As a result of the inspection conducted on November 30-December 18, 1981, the
'ollowing significant observation was identified in the implementation of your design and construction program.
1.
The Construction Control
& Completion Program (CCCP) used by S8W to monitor contractor performance is only partially effective for the following reasons:
a.
No formal mechanism existed for followup of proposed preventative actions to insure that such actions were actually accomplished sati s-factori ly.
b.
The applicable procedure (CMP 1.11) indicates that both S8W Construction and Field Quality Control (FQC) personnel can identify unsatisfactory conditions which are used as a part of the CCCP monthly analysis of contractor performance. If CMP 1.11 was implemented in a consistent manner by both Construction and FQC personnel, Construction personnel would be expected to identify more than one-half of the total unsatis-factory conditions since they inspect completed work before FQC is requested to perform their inspection activities,
- however, a review of a sample of unsatisfactory conditions disclosed that approximately 90%
had been identified by FQC.
These problems with the CCCP system appear to be attributable to inconsistent criteria being used by FQC and Construction and/or improper implementation of CMP 1.11.
The above weakness in the CCCP systems decreases its effectiveness as a tool to monitor contractor performance.
Part a.
was addressed prior to the end of the inspection by initiation of a formal followup/closeout mechanism reviewed by the inspector, therefore, it need not be addressed further in the Niagara, Mohawk response.
(Reference Section 4.1.2.2.2 of Report 410/81-13).
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