ML17053D113
| ML17053D113 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/01/1982 |
| From: | Chaudhary S, Ebneter S, Paolino R, Reynolds S, Schulz R, Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17053D110 | List: |
| References | |
| 50-410-81-13, NUDOCS 8204200492 | |
| Download: ML17053D113 (80) | |
See also: IR 05000410/1981013
Text
I
y
I
U.S.
NUCLEAR REGULATORY COMMISSIlt',"
OFFICE OF INSPECTION AND ENFORCE>'
I
Region I
Report
No.
50-410/81-13
Docket No.
50-410
License
No.
CPPR-112
Priority
Category
A
Licensee:
Nia ara
Mohawk Power Cor oration
300 Erie Blvd.
Nest
S racuse
13202
Facility Name:
Nine Mile Point Station
Unit 2
Inspection at:
Scriba
and Syracuse,
Inspection
conducted:
November
30 - December
11
V
Inspectors:
~
. tl ~,6 cu.< o
S.
K. Chaudhary,
Reacto
Inspector
Pa lino,
eactor Inspector
- December
17,
18,
1981
da
e signed
W /9 g~
te
igned
.
D.
Re
olds, Jr.,
Reactor
In pector
da
e signed
~
r'
Chief,
M&PS, EIB
date
signed
Schul
Resident
Inspector
date
signed
Approved by:
S.
D. Ebneter,
Chief, Engineering
Inspection
Branch
a
e signed
Ins ection
Summar
Ins ection
on November
30
December
11
and December
17-18
1981.
Re ort Number 50-410/81-13
Areas Ins ected:
Announced
team inspection
conducted at the Nine Mile Point,
Unit 2 site
and
NMPC Corporate offices by four regional-based
and
one resident
inspector of quality assurance;
design controls; project management;
procurement
control
and construction controls in the electrical,
mechanical
and
NDE areas.
The inspection
involved 394 inspector-hours
onsite
and
128 inspector-hours
in
the office.
Results:
Of the five major areas
inspected,
no items of noncompliance
were
identified in two areas;
three
items of noncompliance
were identified in three
areas
(Severity Level IV - Inappropriate
and ineffectively executed quality
assurance
program,
Sections 2.2.1, 2.2.2, 2.2.4, 2.2.5, 2.2.8,
and 4.1.1; Severity
Level IV Inadequate
review of design
change
and specifica-
tion, Sections 3.1.2.4
and 5.1.7;
and Severity Level
V Nonconformance with
procurement specification,
Section 5.1.4)
8204200492
8203i7
PDR AoaCX QSQQQOio
9
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I f
) V
TABLE OF CONTENTS
Persons
Contacted
1.2
1
~ 3
2.0
Niagara
Mohawk Power Corporation
Stone
and Webster Engineering
Corporation
Other
- "'"""
2.1
2.2
Site Organization
Areas Inspected
2.2.1
2.2.2
2.2.3
2.2.4
2.2.5
2.2.6
2.2.7)
2.2.8
2.3
3.0
Quality Assurance/Quality
Control Implementation
Training
Document Control
Control of Material
Nonconformances
and Corrective Action
Record Control
Audits
Management
Involvement
Documents
Reviewed
ODiD
C
3.1
3.1.1
3.1.2
3.1.3
3.1.4
3.2
4.0
Areas Inspected
Program
Program Implementation
Management
Involvement
Availability and Traceabi lity of Records
Documents
Reviewed
Project
Mana ement
4.1
Areas Inspected
a
4.1.1
4.1.2
4.2
5.0
Program
Implementation
Documents
Reviewed
Procurement
Control
5,1
5.1.1
5.1
~ 2
5.1.3
5.1.4
5.1
~ 5
5.1.6
Areas Inspected
Procurement
Documents
Document Control
Conformance with Procurement
Documents
Specification
Changes
gualification of Suppliers
Specification
Review
5.1.7
Detection of Reactor Coolant
Leakage
5.1.8
6.0
6.1
6.1.1
6.1.2
6.1.3
7.0
Cable Tray Spacing
Electrical
Areas Inspected
Equipment Storage
In-Place
Receiving
and Storage
Documentation
Storage Facility
Mechanical
and
7.1
7.1.1
Previous
Open Items
Licensee Actions on Previous
Inspection
Findings
7.2
7.2.1
7.2.2
7.3
8.0
9.0
Areas Inspected
Visual Observation of Welding
Welding Material Control
Documents
Reviewed
Unresolved
Items
Exit Interview
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DETAILS
Persons
Contacted
Nia ara
Mohawk Power Cor oration
J. Arkerson, .Lead Administrative Engineer-Project
Manual
and Methods
(3)
J. Bartlett, Executive Vice President
(2)
J. Belko, Manager,
Project Quality
R. Bonzagni, Project Control Engineer-Cost
(2)
M. Bryant, Manager,
Corporate Quality Assurance
(2)
R. Clancy, Senior Vice President
(1)
R. Dahlin,
Lead Mechanical
Construction
Engineer
(2)
J. Dillon, Lead Site
QA Engineer
(1)
G. Doyle, Asst.
QA Technician
(Group Leader,
IKC
Bldg. Serv./Programs
Group)
( 1)
M. Dunlop,
QA Technician
(under contract
from
Universal Testing Laboratories)
(2)
L. Fenton,
Assoc.
Sr.
QA Technician
P. Francisco,
Lead Licensing Engineer
Y. Goyal, Assistant
Manager,
Project Control-Cost
C. Jasinski,
Project Control Engineer-Scheduling
C. Kolarz,
Lead Construction
Planning
Engineer
B. Lamers,
Mechanical
Construction
Engineer
L. Lessard,
Manager,
Operations Analysis
(2)
E. Manning,
QA Technician
(Group Leader,
Mechanical
& Concrete
Group)
(3)
S.
Manno, Project Manager
(1)
H. Mastin,
Lead Electrical Construction
Engineer
(1)
D. Maxwell, Records
Management
Supervisor
v
(1)
C. Millian,
Lead Quality Engineer-Construction
(2)
R.
Norman, Supervisor,
Quality Assurance,
NMP ¹2
F. Osypiewski,
QA Engineer
(Group Leader, Electrical 5
Steel
Group)
(1)
D. Palmer,
Supervisor,
Quality Assurance,
NMP ¹1
D. Pracht,
Lead Mechanical
Engineer
(1)
J. Ptak,
Manager of Construction
(2)
G.
Rhode,
Vice President-System
Project
Management
(1)
W. Rumberger,
Assistant Project Manager,
Operations
D. Sandwick,
Lead Quality Engineer-Headquarters
J.
Saurina,
Lead Civil Construction
Engineer
R. Smith, Jr.,
Mechanical
Construction
Engineer
J.
Swenszkowski,
Assoc.
QA Technician
(Group Leader,
Piping/NSSS
Group)
(2)
C. Terry, Manager,
Project Engineering
Stone
and Webster
En ineerin
Cor oration
SEW
L. Alley, Senior Construction Supervisor
L. Barsuck, Office Supervisor
(1)
R. Barnard,
Fi el d Qual ity Control
(FQC),
Boston Office
J.
Burgess,
QA Supervisor
(1)
K. Conkad,
Construction
Completion Control
Program
(CCCP)
Administrator
C. Corso, Electrical
Engineer
S.
Crowe, Assistant Supt.,
FQC
L. Dalhaus,
Lead Electrical
QC Engineer
(1)
C.
Deban,
Senior
Records Supervisor
D, Boe,
Lead pater'ills Engineet,
Cherry Hi'll
I
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1
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i rg
(1)
E. Eichen, Asst. Supt. of Engineering
J. Ellis, Chief Construction Supt.,
Welding
(4)
T. Farrell, Principle Structural
Engineer
D. Friedrich, Chief Construction
Engineer
K. Goodness,
Material Controller
T. Giler,
CCCP Administrator
(4)
A. Grual, Principle Electrical
Engineer
R.; Hardison,
QC Engineer
(4)
M. Hazzan,
Power Engineer
J. Hinton, Calibration Inspector
(4)
E. Hubner,
Lead Controls Engineer
R.
Huggon,
QC Engineer
(1)
J.
Huston, Asst. Project Manager,
Operations
(1)
R. Kelly, Vice President
5 Manager,
Corporate
R. Kebien,
Senior
QC Engineer
H. Kenyon, Senior
FQC Inspector
S.
Lazarek, Structural
Engineer
J.
Logewski, Calibration Inspector
E.
Magi lley, Asst.
Supt. of
FQC
R. Nagel, Training Coordinator
B. Niyogi, Mechanical
Engineer (seismic)
(1)
M. Oleson, Asst.
Supt. of Engineering
P.
Osborn, Office Engineer
(1)
G.
Pace,
Manager,
Project Quality Assurance
N. Palmer,
Senior Welding Supervisor
a'
C. Patrick, Construction Welding Supervisor
G. Philippi, Lead Structural-Mechanical
Engineer
B. Pierce,
Training Specialist
(1)
G. Pierce,
Site
QA Supervisor
h
H. Pierce,
Chief Office Engineer
R. Plant,
Manager,
FQC
(4)
J.
Posusney,
Principle Structural
Engineer
B.. Poythress,
Materials Manager
N. Sedgley,
Asst.
Supt. of Construction
(1)
L. Shea,
Supt. of Engineering,
Site Engineering
Group
(1)
F. Sheldon,
Supt. of Construction
(4)
M. Stocknoff, Radiation Protection
Engineer
C. Sperling,
Senior Material Controller
(4)
L. Theriault, Principle Piping Engineer
(1)
J.
Thompson,
Supt. of 'FQC
(4)
S. Tsombaris,
Electrical Engineer
(1)
R. Wagner,
Resident
Manager
& Senior Site Representative
,R. Wisecarver,
Concrete Construction Supervisor
(1)
C. Zappile, Project Engineer
Other
J.
Conlon, Chief Field Engineer,
Walsh Construction
Company
J.
Flannery, Material Control Coordinator,
L.K. Comstock
& Co.
D. Giguere,
QC Manager,
ITT Grinnell
P.
Lockwood, Senior
Document Control Engineer,
L.K. Comstock
&
Co.
I
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B. Pion, Mechanical
Engineer,
ITT Grinnell
K. Williams, Asst. Field Administrator, Cives Steel
Corporation
(1)
Denotes
those present at the 12/ll/81 site exit meeting
(2)
Denotes
those present at the 12/18/81 exit meeting at Syracuse
(3)
Denotes
those present at the 12/ll/81 and 12/18/81 exit meetings.
(4)
Contacted via telephone
at the
S8W Cherry Hills Office.
In addition to those listed above,
the inspectors
contacted
other representatives
and/or employees
of the above organizations
during the course of this inspection.
2.0
ualit
Assurance
The
QA inspection effort covered licensed activities in selected
functional areas.
In each of the functional areas
the inspector
reviewed written policies,
procedures,
and instructions;
interviewed
selected
personnel;
and reviewed selected
documents
to determine
whether:
The licensee
had written policies,
procedures,
or instructions
to provide management
controls in the subject areas;
The policies,
procedures,
and instructions
as
implemented,
were adequate
to assure
compliance with the regulatory
requirements.
The program provided indoctrination
and training of personnel
performing activities affecting quality as necessary
to
assure that suitable proficiency was achieved
and maintained.
2.1
Site Or anization
Ultimate responsibility for quality assurance
at the Nine Mile
Point, Unit 2 Power Station rests with Niagara
Mohawk Power
Corporation.
Niagara
Mohawk has contracted with Stone
& Webster
Engineering Corporation to maintain
and implement separate
but
subsidiary Quality Assurance
Programs
for Nine Mile Point, Unit
2, responsive
to and designed
to satisfy the intent of the
Quality Assurance Criteria of Appendix B.
Stone
& Webster,
in
carrying out this function,
has
some contractors
complying with
Stone
& Webster'
QA Program, while other s have their own
Programs,
which have
been
approved
by Stone
& Webster.
For
example,
L.K. Comstock
and
Company
(permanent plant electrical
contractor),
Walsh Construction
Company (civil contractor),
and
t
I
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Cives Steel
Corporation (structural
steel contractor)
operate
under Stone
& Webster's
QA Program.
ITT Grinnell (piping
contractor)
and Chicago Bridge.& Iron (liner and biological
shield wall) operate
under their own
QA Programs.
This
situation is somewhat
unique
and appears
to have contributed to
noncompliance
examples
as discussed
in Sections
2.2.1
and 2.2.2
of this report. Niagara'ohawk regularly conducts
scheduled
audits
and performs'continuous
survei llances of Stone
& Webster
and contractors
at the site.
The quality control inspection
efforts are carried out by Stone
& Webster
and contractor
personnel.
2 '
Areas Ins ected
The inspection
has
been divided into the following areas:
quality assurance/quality
control implementation, training,
document control, control of materials,
nonconformances
and
corrective action,
records,
and audits.
2.2.1
ualit
Assurance/ ualit
Control
Im lementation
In general,
the overall quality assurance
program
and the
QA/QC
organizations
of Niagara
Mohawk and Stone
& Webster
have the
essential
elements
to control construction activities;
however,
specific practices
were observed that appear
to be
a departure
from industry standards
such
as
ANSI QA standards
and/or
practices
designed
to ensure effective quality control.
Stone
and Webster Engineering Corporation
has
been
overdependent
on contractor construction
personnel
to identify
quality related
problems
and monitor quality related
activities, especially
dependent
on those contractors without
their own
QA Programs,
who are required to comply with Stone
&
Webster's
QA Program.
This reliance
was identified in the
structural
steel
inspection
program,
concrete
inspection
program, material
release,
and control of measuring
and test
equipment
as discussed
below.
It is an example of
noncompliance with 10 CFR 50, Appendix B, Criterion I
(410/81-13-01).
2.2.1.1
Stone
& Webster
was relying on Cives contractor construction
personnel
to verify numerous
weld preparations
and joint fit-ups
for structural
steel
welding.
Stone
& Webster's
QA Program
required only random inspections
by quality control personnel
of weld preps
and fit-ups to verify compliance with AWS Dl.l
and ANSI N45 2.5,
1974.
The sampling
(random)
procedure
was
not based
on recognized
standard
practices
per ANSI N45.2.
1
~
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Stone
& Webster
was relying on Walsh contractor construction
personnel
to verify that numerous
concrete
placements
were
cured in accordance
with Stone
& Webster Specification
NMP2-S203C,
Revision 6,
and ANSI N45 2.5,
1974.
Stone
& Webster's
gA
Program only required,
as
a minimum, the following curing
checks:
ADT
. Number of Ins ections
Per Week
Bel ow 40
Above 40
As discussed
in Inspection
Report 410/81-12,
several
of these
inspections
were not performed resulting in a series
of'oncompliances.
In addition,
from July 27,
1981, to October 29,
1981 there
were
thirty nonconformances
written by Stone
& Webster resulting
from missing or mislocated
dowels in concrete
pours.
The
missing dowels were identified by Walsh contractor construction
personnel,
after Stone
& Webster field quality control personnel
had inspected
and failed to identify the missing
Stone
& Webster
was relying on Cives contractor construction
personnel
to control
and issue material,
as discussed
in Section
2.2.4 of this report, contrary to Stone
& Webster Construction
Methods Procedures.
Stone
& Webster
was relying on contractor construction
personnel
to properly handle
and store calibrated
measuring
and
test equipment,
without documented
survei llances
or audits of
storage
and handling activities.'n addition, training was not
being given to contractor
personnel
on proper handling
and
storage.
Stone
& Webster's
gA Program addressed
the singular
aspect, of calibration control
on
a time interval basis
such
as
6 months or 12 months,
as applicable,
but failed to address
control
between
required calibration intervals.
Calibrated
measuring
and test equipment
was issued to construction
personnel,
and
need not be returned to Stone
& Webster until the item
needed re-calibration,
in accordance
with the pre-established
calibration interval.
An item was to be returned to Stone
&
Webster, if found damaged,
prior to the elapsed calibration
interval, but controls
had not been
implemented to reduce the
possibility of damage
and maintain calibrated
instruments
during the calibration period.
Niagara
Mohawk auditors identified
this lack of control in Nonconformance
Report ¹314, dated
July 13,
1981, which stated
in part that calibrated
equipment
was
handed
from one construction
personnel
user to another.
~Trainin
Stone
& Webster's training and qualification program for
guality Control personnel
responsible
for inspections
was
evaluated
against
ANSI N45 2.6,
1978 and the alternatives
specified in the September
14,
1981
NMPC letter to the Office
of Nuclear Reactor Regulation.
The inspector also reviewed qualification records for Niagara
Mohawk guality Assurance
personnel
to see that their experience
and training was commensurate
with the scope,
complexity or
special
nature of the activities to be audited.
No items of noncompliance
or significant observations
were
identified.
Stone
& Webster's training program for contractor personnel,
who are required to comply with Stone
& Webster's
gA Program,
was reviewed to ascertain
that the program provided indoctrination
and training of personnel
performing activities affecting
quality as necessary
to assure that suitable proficiency is
achieved
and maintained.
The inspector
found that there
was
a significant lack of training
given to contractor personnel,
especially
in regards
to procedures,
hold points,
and inspection
requirements.
The majority of the
training was in safety programs,
rather than Stone
& Webster'
gA Program,
which contractor
personnel
were required to follow.
The inspector
identified nineteen
nonconformances
which were
written by Stone
& Webster in a period from February
11,
1981
to November
16,
1981, resulting from contractor personnel
not
being aware of the Stone
& Webster
(}A Program in regards
to
procedures,
hold points,
and inspection
requirements.
The
applicable contractor
and nonconformance
and disposition reports
are listed below.
Walsh
Cives
L.K. Comstock
2016
2047
2085
2103
2111
2198
2375
2508
2142
2160
2455
2468
2511
2592
2187
2275
2332
2649
In addition,
Niagara
Mohawk stated
on July 28,
1981 in Nonconformance
Report ¹315,
"Of the
19 contractors
on site,
less
than half
have participated
in any structured
form of training."
As discussed
above in Section 2.2.1,
there is an overdependence
on contractor personnel
to identify quality related
problems.
~
g
0
10
This is further compounded
by a lack of gA training for contractor
personnel.
This is a further
example of noncompliance with 10 CFR 50, Appendix B, Criterion I (410/81-13-01).
Document Control
The document control
program
was reviewed for conformance to
regulatory requirements,
equality Assurance
Program Requirements,
and applicable industry guidance
and standards.
Drawings and
procedures
were reviewed for current revisions, distribution
lists,
and assigned
responsbi lities.
E&DCR'
were checked for
issuance
and affected drawing control.
No items of noncompliance
or significant observations
were
identified.
Control of Material
Receipt
and storage of equipment
and material
was reviewed to
ascertain
whether the licensee
was implementing
a gA program
that was in conformance with regualtory requirements
and commitments
in the guality Assurance
Program,
implementing procedures,
and
in accordance
with ANSI N45 2.2,
1972.
The inspector verified
that responsibilities
were assigned
for receipt,
acceptance,
storage,
and release.
Nonconforming items were reviewed for
identification, segregation,
control,
and release.
Receipt
inspection reports
were examined for applicable
signatures,
justification for use,
damage
recorded,
and stipulated inspection
criteria.
Procedures
were reviewed for levels of storage
and
appropriate
environmental
conditions.
Cives Steel
Corporation
was not in compliance with the procedures
Stone
& Webster
had written to control the issuance
of material
to the field.
Cives was neither placing received material
in a
hold area
as required
by
CMP No. 1.2-11.81
Receiving Material
and Equipment,
Section 2.7.1,
nor writing stores requisitions
to withdraw items from storage
as required
by
CMP No.
1.3-2.79 - Material/Equipment Storage,
Section 5.10.5.
This is
contrary to
10 CFR 50, Appendix B, Criteria I and VIII.
Stone
& Webster personnel
were not involved in the issuance
of
material
as required
by their program, but were relying on
Cives construction
personnel
to control issuance.
The inspector
noted that two Noncompliance
and Di'sposition Reports
had resulted
from Cives bypassing
the material
release
control
system,
installing rejected material delineated
on
N&DR ¹2592,
dated
October
15,
1981
and installing uninspected
material delineated
on
N&DR ¹2160,
dated
November ll, 1980.
If an item was
on hold
or in reject status,
construction
personnel
were relied upon"
not to take
an item for erection,
rather
than depending
on the
material requisition process
and field .quality control interfacing.
l
I
11
This is another
example of'oncompliance with 10 CFR 50,
Appendix B, Criterion I (410/81-13-01).
Nonconformances
and Corrective Action
The inspector
reviewed this area to verify that measures
have
been established
to identify and correct conditions adverse
to
quality such
as failures, malfunctions, deficiencies,
deviations,
defective material
and equipment.
Corrective action taken to
preclude repetition
was also examined.
The area of nonconformances
was reviewed for prompt identification and correction.
Nonconformances
were not analyzed
on
an individual basis at the
time they were written,
as to why the nonconformance
occurred
or what corrective action
needed to be taken.
Rather
they
were solely resolved
on the technical acceptability,
rework,
repair, or scrap disposition, without regard to the root cause
of the nonconformance.
Trend analysis
was done by Stone
&
Webster
on
a six month and one month basis.
The lack of prompt
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,
as in the
case of concrete
curing nonconformances
referenced
in Inspection
Report 410/81-12.
In addition,
one significant nonconformance
may require prompt corrective action
as stated
in
Appendix B,
Criterion XVI.
The 'analyzing of nonconformances
on
a individual basis
can also pinpoint program weaknesses.
This is another
example of noncompliance with 10 CFR 50,
Appendix B, Criterion I.
(410/81-13-01)
The inspector
observed that there
was
a significant
problem in the timeliness of corrective action in regards to
Niagara
Mohawk audit findings.
This problem was largely due to
the delay in getting Stone
& Webster to answer
Niagara
Mohawk
audit findings concerning
the Stone
& Webster Quality Assurance
Program
and the
inadequacy of Stone
& Webster
responses
on
numerous
occasions.
There appeared
to be
a light regard for
Niagara
Mohawk audit findings.
Stone
& Webster not only didn'
comply with requested
response
dates,
but even missed extension
dates
granted
by Niagara
Mohawk.
For example,
Niagara
Mohawk
identified in July of 1981,
Nonconformance
¹315,
a significant
training problem at the site
and requested
a reply by August
28,
1981.
As of December
8,
1981,
no response
had been given.
Examples of other audit findings and response
delays
were
seen
on Nonconformance
Report No's.
311 thru 314,
308,
309,
300,
298,
and 297.
Nonconformance
¹297,
dated 1/5/81,
was still
open.
Nonconformance
Reports
297 and
298 required additional-
responses
due to the nature of the first response.
Another
example of an inadequate
response
was verified concerning
a
Niagara
Mohawk storage finding, delineated
on Nonconformance
e'
J
I
12
Report //309, dated July 17,
1981.
The finding stated that
a
24" control valve for reactor recirculation
was not being
stored in a controlled atmosphere
as required
by the manufacturer
and that the present
containment building storage
area
was
a
high humidity area
and therefore,
preventive
maintenance
was
needed.
Stone
& Webster's
response
dated August 14,
1981
stated that the containment
was not a high humidity area
and
no
preventive
maintenance
was, being performed
because
none
was
required.
The inspector,
through inspections,
has verified that
the containment is frequently subject to high humidity conditions.
Various guality Assurance
Management
personnel
stated during
interviews that they were not at all satisfied with the type of
responses
from Stone
& Webster,
nor the time delays in obtaining
the responses.
Corrective action
on Niagara
Mohawk audit findings
is far from timely and requires
added attention.
The inspector
questioned
why top management
had not taken
steps
to correct
this situation.
This is another
example of noncompliance with
10 CFR 50, Appendix B, Criterion I.
(410/81-13-01)
Record Control
The records
program was reviewed to"ascertain
that the licensee
was implementing
a program relating to the control of records
that was in conformance with regulatory requirements,
guality
Assurance
Program,
and
ANSI N45 2.9-1974.
Record storage
controls were reviewed along with means of transferring
records
to the vault.
Various records
were reviewed for implementation
of the program
and personnel
were interviewed concerning
storage,
access,
and retrievability.
The record index was examined
and
the Stone
& Webster vault was checked against
the criteria of
'NSI N45 2.9-1974.
No items of noncompliance
or significant observations
were
identified.
Audits
The licensee's
audit program
was reviewed to ascertain
whether
the licensee
has developed
and implemented
a program that is in
conformance with regulatory requirements
and applicable industry
guides
and standards.
The inspection
included verification of
the following:
scope of the program is consistent with PSAR
requirements,
responsibilities
for overall
management
of the
program
has
been
assigned,
and auditors were qualified in
accordance
with the nature of the activities to be audited.
No items of noncompliance
or significant observations
were
identified.
I
~
'A
C
13
2.2.8
Mana ement
Involvement
2.2.8.1
Pro osed
Reor anization of ualit
Function
The requirements
of NRC dictate that the licensee
establish
a quality
assurance
program
such that the program's
appropriate
and effectively
executed.
To assess
the extent of the appropriateness
and effectiveness
of the
licensee's
present
and proposed quality assurance
program'he-.-
inspector
reviewed the organizational
struct,ure of the present
gA
organization
and the proposed organization of Project guality, the
staffing plan for the
new organization,
and the qualification of the
designated
staff members of the
new organization.
The inspector
also held discussions
with the cognizant
personnel
of both the
existing
and proposed .organization
to determine their perception of
the responsibility of each organization,
the understanding
of their
functions
and any potential interface
problems.
Based
on the review of documents
and discussions
with cognizant
personnel,
the inspector determined that there
appeared
to be
an
excessive
turnover in the present
gA organization
inasmuch
as there
were only three
members
who have
been in gA for over
a period of
three years,
and they were all stationed off-site in the
NMPC corporate
headquarters
in Syracuse,
New York. The inherent instability of gA
staff due to excessive
turnover did raise
a question
as to the
effectiveness
and capability of the gA organization
to identify and
resolve quality
issues'urthermore,
by review of the staffing structure,
and the
scope of
the responsibility
as perceived
by the management
of the newly
proposed
Project guality Organization,
the qualification of assigned
personnel,
and extensive discussion with the management,
the inspector
observed that the personnel
assigned
to the
new
PgO did not have
adequate
training and experience
to carry-out the functions of a gA
organization.
Moreover, the responsibility
as perceived
by the
management
of PgA was not consistent with the department's
functions
as described
in the submittal to NRC.
2.2.8.2
Mana ement
Su
ort
The
number
and nature of the findings in the
gA area
as described
previously in this report led to further examination of the degree
of NMPC Management
support received
by gA.
The inspector
found
through interviews that
some onsite
NMPC gA personnel
working on the
NMP-2 project were not treated
the
same
as other onsite
employees.
That is, in their efforts to increase
staffing levels
on the
NMP-2
project,
NMPC management
initiated
a policy in the Spring of 1981
wherein
NMPC employees with permanent
residences
more than
20 miles
from the site
who were transferred
to the
NMP-2 site received
a
10%
pay bonus
and
a commuting mileage allowance.
This had been
I
\\
retroactively applied to all
NMPC employees
commuting more than'0
th
NNP-N tt
pt
T
IIA
pt y
.
Th
~th
A
employees
onsite
who commute~ore
than 20 miles from their permanent
residences
and did not receive
such allowances.
In another situation,
a former QA engineer
applied for, and
received
a September,
1981 transfer
from QA to
a position as
a
discipline engineer
in the
NMPC project organization.
With his
transfer
from QA,
he
became eligible for, and
now receives
the
special
bonus
and commuting allowance.
Thus, onsite
QA personnel
are treated
in an inequitable
manner,
thereby leading to financial disincentives
to remain in QA.
This demonstrates
a lack of NMPC management
support for QA
and/or
an insensitiveness
on the part of management
to the
inequities that they have permitted.
It is perceived
by
personnel
to be
an indication of lack of corporate
management
support and/or lack of QA management
influence.
~Alla ation
On Oecember
11,
1981,
NRC received
anonymous allegations via
the
NMP-2 Resident Inspector's
phone relating to the Niagara
Mohawk Quality Assurance
Program.
These allegations
reinforced
most of the
NRC findings and concerns
in this area
up to that
point.
The alleger's
basic
concern
appeared
to be with the
attitude of the utility management
toward quality assurance.
Examples
given were; barring of certain
QA people
from the
site,
poor responses
to Quality Assurance
Audits and Quality
Control Inspection
Report findings,
and unfair treatment of QA
personnel,
alledgedly
because
they had generated
the findings.
He further stated that because
of this poor attitude,
there
had
been
a large turnover of QA personnel.
He also stated that
he
was concerned
about the
new Proposed
Quality Organization
in
that it might circumvent the existing
QA program.
Each of
these
items is discussed
below.
Barrin
of
A Peo le from the Site
In interviews subsequent
to the allegation,
the inspector
identified
a
who had effectively been
barred
from the site.
In discussing this situation with the
NMPC Manager of QA, it was disclosed that
he
had received
a
written directive from the Executive Vice President directing
him to not use that individual
on the
NMP-2 project.
He no
longer
had
a copy of that directive,
nor did the Executive Vice
President.
The inspector questioned
whether or not this individual
was actually being used
on
NMP-2 since the organization charts
indicated
such
an assignment.
By reviewing this individual's
time sheets for October
and November,
1981, it was finally
0
I
Nl
15
established
that
he
had
been
spending
most of his time on
NMP-2.
The Corporate
Manager of QA indicated that this individual's
involvement
on
NMP-2 had been limited to in-office activities.
Furthermore,
he expressed
concern that even that usage
on the
project was counter to the Executive Vice President's
wishes.
Pursuit of this matter with the
QA Manager's
immediate supervisor
(Vice President)
and the Executive Vice President
disclosed
that their understanding
and memory of this matter
was that the
Executive Vice President
had directed that the individual in
question
not be employed
as
a
QA supervisor,
but did not bar
him from working on the
NMP-2 project.
The individual in
question
was absent
and not available for interview.
The circumstances
surrounding
the above including the apparent
miscommunication
could be construed
as barring the
QA individual
in question
from the
NMP-2 site.
Poor
Res
onses
to
A Audits and
C Ins ection
Findincis
The inspectors
had already
made
a similar finding as discussed
in Section
2 '.5.2.
In further discussions
it was acknowledged that responsiveness
to
QA audit findings
was
somewhat
less
than desired.
It was indicated that this
lack of responsiveness
could be partially attributed to
preoccupation
by QA Department
Management with the proposed
reorganization
of the quality responsibilities for NMP-2 which
decreased
their efforts in pursuit of resolution of audit
findings.
Also, it was noted that there
appeared
to be
a
reluctance
on the part of QA Department
Management
personnel
to
utilize NMP-2 Project
Management
in exerting influence/pressure
in resolving audit findings.
Unfair Treatment of
A Personnel
As discussed
in Section 2.2.8.2,
the inspector
had previously
found that
NMP-2 QA personnel
with onsite assignments
were not
receiving the
same
pay and benefits
as other onsite
NMPC personnel.
No other instances
of unfair treatment of QA personnel
were
identified in subsequent
followup of this part of the allegation.
Lar
e Turnover of
A Personnel
The inspectors
had previously established
that high turnover
rates
had occurred
in QA (Section 2.2.8.1).
It was noted that
difficulties (delays)
had
been
encountered
in obtaining upper
management
authorizations
to replace
QA personnel
who had
previously been working on NMP-2, but had transferred
or quit.
The Executive Vice President attributed this delay to his
desire to wait and
see what
new staffing levels would be required
in
QA with the proposed
reorganization
of the
QA effort.
f
I
I
16
2.2.8.3.5
Possible
P 0 Circumvention of Existin
A Pro
ram
The inspectors
had previously voiced the
same
concern to
'anagement;
at the
end of this inspection, it remained
an item
to be resolved
between
NMPC and
NRC.
2 '.8.4
2.3
Conclusion
4
In summary, it was found that there
was
a lack of strong positive
management
support to
QA and attention to
QA personnel
matters.
Findings in this area
include
a high rate of turnover of QA
personnel,
inadequate
prior QA/QC experience
of several staff
members
assigned
to the Project Quality Organization
(PQO),
significant differences
in the perceived charter for the proposed
PQO as expressed
by the Quality Assurance
Department,
Project
Management
and the Manager of PQO, inequitable
pay and fringe
benefits for some onsite personnel
and management
actions which
have in effect barred
a
QA person
from the site.
These findings
taken together with other findings of this inspection
show
a
lack of management
effectiveness
in executing
the quality
assurance
program.
This lack of effectiveness
can
be partially
attributed to lack of management
support to the
QA Department
as evidenced
by .inadequate
attention
and/or actions
on personnel
matters.
This~has
had!an
adverse
impact
on the capability and
effectiveness
of the quality assurance
effort.
This is
a
further example of noncompliance with Criterion I of 10 CFR 50,
Appendix
B which requires that quality assurance
functions
be
effectively executed
(410/81-13-01).
Documents
Reviewed
The inspector
reviewed the documents
of Niagara
Mohawk and
Stone
& Webster
as detailed below:
k
Quality Assurance
Manual
Stone
5 Webster
Quality Assurance
Program
Manuals
Quality Assurance
Procedures
Degree of Compliance With
Regulatory Guides
Quality Standards
Quality Assurance
Directives
MNP 2, Project Manual,
Volume II
Quality Control Instructions
Construction
Methods
Procedures
1.2-11.81,
1.3-2.79,
and 11.1-4.81
Project Specification ¹16
I
'I
17
3.0
Desi
n Controls
The purpose of this part of the inspection
was to determine if
the site design interfaces
were effective, the design controls
applied to on-site design activities were commensurate
with
those applied at the corporate offices,
and that on-site design
documents
were. current.
3.1
Areas Ins ected
3.1.1
~Pro
ram
The responsibility for design
and design control
has
been
~
delegated
by
NMPC to the principal contractor,
Stone
& Webster
Engineering Corporation
(S&W).
The Licensee's direct participation
in design
and its control
was found to primarily consist of
review and approval of selected
design
packages,
and audit of
design activities.
Stone
& Webster Engineering Corporation,
however,
had
a comprehensive
system of design controls applied
at all facets of design effort in its Cherry Hill Operations
Center.
These controls were adequately
proceduralized
in S&W's
Engineering
Assurance
Procedures
Mannual
(EAPs).
3.1.1.1
On-Site
Desi
n b
Site
En ineerin
Office
3.1.1.2
The inspector held discussions
with S&W engineers
assigned
to
SEO to determine
the extent of SEO involvement in on-site
design
and approval of design
changes
originated in the field.
The inspector also reviewed documents
maintained
in
SEO for
controlling design
and design
changes.
The inspector determined
that there
was
no significant design activity performed at site
by SEO; therefore,
there
were
no site specific procedures
required and/or available
at site to control original design.
The design
change activities were controlled by the
E&DCR
system,
which was
a company wide procedure 'followed by most
S&W
nuclear projects.
Desi
n Interfaces
The inspector determined that all design interfaces
were controlled
by EAPs,
however,
since there
was
no significant design activity
on-site,
no significant design interfaces
existed and/or were
required on-site. All the required interfaces
were controlled
and executed
at
CHOC of S&W.
3.1.2.1
Desi
n Chan
e Control
E&DCRs
The inspector
reviewed. S&W procedure
EAP.6.5, which controlled
the initiation, problem resolution,
and distribution of Engineering
I
18
and Design Coordination
Reports.
The
E&DCRs were found to be
the primary vehicle to initiate, resolve and/or
implement
changes
to an approved
design
document
such
as specifications,
drawings, etc.
The inspector
noted that the procedure,
EAP 6.5
also allowed the
use of E&DCRs system for documenting interpretations
and/or clarifications of design
requirements,
and site-project
technical
communications.
The inspector considered
the procedure
adequate
to control design
changes.
Pro
ram
Im lementation
Desi
n Document Control
The inspector
reviewed the status of several
drawings,
specifications,
and design
changes
to assure
the effectiveness
of measures
established
for their adequacy,
approvali
currenCy,'f
revisions,
and/or posting of changes.
The major portions of
this audit were carried out in conjunction with the documents
reviewed for the design control audit.
No items of noncompliance
were identified.
S ecification/Drawin
Station Control
The inspector
reviewed the drawings
and
E&DCRs located at the
drawing station at S&W's engineering
area
in the construction
offices,
and specifications
and specification
changes
to purchase
specifications
in the warehouse offices to assure
the currency
of drawings
and specifications,
completeness
of information,
posting of changes,
and conformance
to procedural
controls.
The inspector determined that the drawings
and specifications
were current.
The changes
had
been
posted
and procedural
control
was adequately
applied to assure
completeness
and
currency of design information.
No items of noncompliance
were identified in this area.
Im lementation of E&DCR S stem
The inspector
reviewed
a random selection of Engineering
and
Design Coordination
Reports for conformance
to the requirements
of project procedures,
completeness,
and validity and basis of
the changes
approved
through the
E&DCR 'system.
The inspector
also held discussions
with licensee
and A/E personnel
regarding
control, distribution and implementation of such changes.
The inspector determined that the
E&DCRs generally complied
with the procedural
requirements with respect to format,
adequate
problem description
and resolution,
and proper approvals.
The
inspector
did note that due to the
E&DCR systems'pplicability
to other areas,
i.e. interpretations/clarifications
and technical
communications,
there is an over use of the
E&DCR form.
0
1
l
~
~~'
19
Rebar
Desi
n Chan
e
In addition to the above general
observations,
the inspector
specifically noticed that in the month of November,
1979,
E&DCR
¹P00692
was initiated by Project engineering
to modify the
rebar purchase
specification,
S203E.
The structural
reinforced
concrete
design of NMP2 was based
on grade
40 rebars,
and the
rebar purchase. specification specified the correct grade of
rebar
(ASTH 615,
grade
40) to be supplied to site to fulfill
the design basis.
By modifying the purchase
specification to
allow a different grade of rebar to be supplied for use in the
construction,
the reinforced concrete
structures,
however, did
not meet the basic design
assumptions,
and the rebar detailing
based
on
such design.
The inspector pointed out to the licensee
his commitment to Uniform Building Code, ACI-318-71, which
limits the amount of rebar to 75% of the amount required for
balanced ratios of concrete
and steel
(ACI-318, Section
10.3)
in certain structural
members.
The inspector
stated that in
view of substituting
grade
60 rebar for grade
40 rebars
on
a
one to one basis,
the inspector
expected
to see objective
evidence of evaluation
and/or
an analysis
documenting
the
justification for this change.
The licensee
indicated that the
substitution of rebar
was based
on engineering
judgment,
and
there
was
no documented
evaluation or analysis
to support the
change.
The licensee,
therefore,
could not provide any objective
evidence
to the inspector to justify the design
change of
substitution of rebars.
The regulations of 10 CFR 50, Appendix
B, require that the changes
to the original design
be subjected
to the
same controls,
such
as verifying and checking the adequacy
of design,
as applied to the original design.
And, because
the
original structural
reinforced concrete
design
using grade
40
rebar
was not based
on engineering
judgement alone,
the change
in design permitting
a different grade of rebar to be used
one
for one without a documented
analysis
and/or evaluation
was
improper.
Based
on the
above observations,
the inspector
determined that:
There
was
no objective evidence to support that the appropriate
design input, i.e., ACI-318-71, was correctly translated
into the design
change,
nor that the impact of the change
on overall design
had been analysed.
There were
no engineering calculations to confirm the
adequacy of the design
change
nor was there
any objective
evidence of an independent
design verification.
This is an item of noncompliance
(410/81-13-02)
~
0
l
I
20
Desi
n and Installation of Cable Tra
Su
orts
threaded
welded studs
The inspector
reviewed the design
and analysis of cable tray
support ¹RC-240,
performed
a visual inspection of the installed
support;
held discussions
with cognizant licensee
and A/E
personnel
to determine
the technical
adequacy
of design
and
procedural
controls over the design/analysis
activities;
examined
evidence of independent
review of the design
as well as correctness
and completeness
of the design
requirements/data
transfer
to
construction/erection
documents;
and compared
the conformance
of the erected
support to the design
requirements.
No items of noncompliance
or deviations
were identified.
Mana ement Involvement
The inspector
held discussions
and reviewed documentation
to
assess
the extent of management
involvement in the evolution
and control of the design process.
Based
on the discussions,
and procedures
and records
furnished
by the licensee,
the inspector determined that the licensee
management
regularly reviewed the adequacy
of control procedures;
the licensees'ngineering
staff regularly reviewed
and
commented
on conceptual
design
packages
of selected
systems
in the plant;
and the Design Control Issue
(DCI) system
has
been recently
revised through
a
new contract negotiation with SKW to redefine
and establish
the extent of licensee
management
involvement in
the design
process.
No items of noncompliance
were identified.
Avai labilit
and Traceabi lit of Records
The inspector
reviewed the status
of design
and design
change
records
to assess
the availability of records,
and the
traceabi lity of information, data and/or the record itself for
retrieval, and review purposes.
This inspection
was performed
in conjunction with other parts of this inspection
and records
review.
The inspector determined that the records
and the data
contained
in those
records
were generally traceable
to source,
the documentation
was reasonably
retrievable,
and the records
management
program
as applied to design,
appeared
adequate
to
fulfill the project need.
No items of noncompliance
were identified.
)
t
e
3.2
Documents
Reviewed
21
The following is
a list of primary document
reviewed during the
course of this part of inspection.
3.2.1
Nia ara
Mohawk Power
Cor oration
~
.
Nine Mile. Point Unit 2 Project Manual,
Volumes I-V.
~
Niagara
Mohawk QA Manual.
~
Niagara
Mohawk QA Procedures
Manual.
~
Degree of Compliance with Regulatory Guide for Nine
Mile-2 Project.-
~
Project Guidelines
32 '
Project Guidelines
33.
~
Project Organization
Charts.
~
Various letters
and
memoranda
regarding
DCI package
reviews.
3 2.2
Stone
and Webster
En ineerin
Cor oration
Engineering
Assurance
Procedures
Manual.
Quality Standards
Manual.
SKW Specification
203E.
SLW Drawings EC-41A-2 and
EC-42C-S.
S5W, Catagory I, Cable Tray Support Analysis for Support
¹RC-240; Calculation
item ¹E340-TAB6,
pp.
112-118.
On-site
Rebar
Fabrication
Requests.
Material Receiving Reports for Rebar.
A random selection of E&DCRs.
A random selection of NKDs.
Various project Memoranda
regarding design
and interpretation
of requirements.
I
C
22
Project
Mana ement
The objective of this part of the inspection
was to determine
the effectiveness
of project management
by examining
management
support of project requirements
and commitments,
responsiveness
to project needs
and management
involvement in all aspects
of
the project.
Primary emphasis
was
on the
NMPC and
S8W organizations
and their support of the construction effort.
This portion of
the inspection
was directed towards verification that Project
Management
was exercising control in a manner that will assure
a quality product (plant).
Areas Ins ected
~Pro
ram
The inspector
examined organization charts,
lines of authority
and communication,
interface controls,
systems for management
reporting
and mechanisms
for change control.
Program procedures
applicable to these activities are primarily contained within
the joint NMPC-S&W Project Manual.
A project manual
was developed
early in the life of the
NMP-2 project.
In 1980,
a management
audit was performed which identified the
need to expand the
scope of the original manual to clarify and document the overall
management
philosophy
on the project.
This was accomplished
by
restructuring
the existing two-volume Project
Manual into five
volumes,
each serving
a specific project purpose.
The Project Manual
was found to contain project policy, objectives,
division of responsibilities,
and procedures/
guidelines that
expand
upon,
and implement the intent of the overall project
management
plans,
the
NMPC/SEW contract,
corporate policies
and
procedures
(both
NMPC and
SEW),
and licensing/regulatory
requirements
and commitments.
Most of the procedures
in the Project
Manual
have
been
issued within the past year with several
other project
procedures
currently being developed.
The Project
Manual
was
estimated
(by the inspector) to be more than
75% complete.
Most project, activities were found to be adequately
addressed,
with the following exception.
Sections
2.1
and 2.2 of Volume
2
of the Project
Manual
are to provide functional roles
and
position descriptions for the organizations
assigned
to the
NMP-2 Project
by
NMPC and
SAW respectively.
These
two sections
are to define the functional structures for each corporation's
Project organization,
describe
the Project functional
responsibilities
of each
group within the respective
organizations,
and identify the duties
and responsibilities of
key positions within each group.
These
sections of the project
Manual
had not yet been
issued.
Examination of draft copies of
these
sections
and discussion with personnel
responsible
for
coordination of Project
Manual development
indicated that these
23
sections of the manual
are intended to be quite specific
(definitive). This is expected
to include detailed position
descriptions for key personnel
and detailed definition of
duties
and responsibilities.
The difficulties in developing
these
sections of the Project
Manual
appear to be partially due
to differences
in opinion between
NMPC and -S&W with respect
to
how much detail
should
go into these
procedures.
Issuance
of
these
manual
sections
is currently projected for early 1982.
In the interim, the inspector
was unable to find any comparable
formal (written) descriptions
of organizational
and position
roles, duties
and responsibilities.
Furthermore,
interviews
with numerous
S&W personnel
disclosed that they had not seen
and were
not, aware of written position descriptions for their
jobs.
Their understanding
of their job duties, responsibilities,
interfaces,
etc.
were
based
almost entirely on verbal directions
and understandings
with their management.
NMPC personnel
were
found to have individual job descriptions,
but orgnizational
duties
and responsibilities
lacked written definition similar
to
S&W.
This lack of written definition of organizational
and
position duties
and responsibilities is identified as
a further
example of noncompliance with 10 CFR 50, Appendix B, Criterion
I.
(410/81-13-01).
4.1.2
Im lementation
4.1.2.1
~Plannin
Additional management
involvement,
reviews
and controls were
observed to be initiated when trouble spots
were identified.
Interfaces
between
NMPC/S&W and various contractors
are handled
in various ways with considerable
reliance
on regularly scheduled
meetings with each contractor
which are attended
by representatives
of all interfacing organizations.
Staffing/personnel
within the
NMPC and
S&W organizations
appeared
to be adequate
in terms of
numbers,
education
and experience
based
on inspector interviews
with personnel
at all levels within these organizations.
It
was noted that there
had been
more than
a doubling of the
staff assigned
to the
NMP-2 project within the past year.
This
appeared
to be primarily in response
to the recommendations
contained within a
NMPC requested
external
management
audit by
Black and Veatch
and
a
New York Public Service
Commission
directed
management
audit by Theodore Barry & Associates.
No noncompliances
or weaknesses
were identified in this area.
4.1.2.2
4.1.2.2.1
Construction Deficienc
Re orts
(CDR's)
The inspector
reviewed documentation
and held discussions
with
licensee's
cognizant
personnel
to determine
the policies and
l.
procedures
for identifying, evaluating,
and reporting of
construction deficiencies
to the
NRC as required
by section
55(e) of 10 CFR 50.
The inspector
determined that the existing
QA/QC program was
relied upon for the identification of any deficiency.
The
licensee,
however,
had established
a specific procedure
for
prompt evaluation
and reporting of such deficiencies
to
NRC.
The current project procedure controlling
CDRs required that
any identified deficiency must
be evaluated within five days to
determine its reportabi lity. If the evaluation
could not be
completed in the five working days,
then the deficiency must be
reported to
NRC as
a potential
problem and the final report
submitted to
NRC as
soon
as possible.
The inspector
reviewed
a
random selection of reports
submitted to NRC,
and found that
they conformed to the project requirements
regarding
the
identification, evaluation,
and prompt reporting to NRC.
No items of noncompliance
were identified.
Performance
Reviews
S&W was found to have
a comprehensive
system for verifying and
reviewing completion of construction
work by contractors
in
conformance with engineering
and contractual
requirements. It
is called the "Construction Control
& Completion Program"
(CCCP)
as covered
by Construction
Methods Procedure
(CMP) No.
1.11-8.79.
In this system,
a Construction
Completion Checklist
(CCC) form is completed
by
S&W construction
personnel
(Construction Supervisor)
monitoring contractor
performance
to
attest that work has
been
accomplished
in accordance
with
approved
drawings
and specifications.
These
CCC forms contain
various entries (attributes) that are to be evaluated,
witnessed
and/or verified as work is completed.
S&W Construction
Supervisors
are to record the results of such inspections
as "satisfactory"
or "unsatisfactory"
in the appropriate
blocks of the
CCC form.
For contractors for which
S&W has total quality responsibility
and
FQC performs all quality control inspections,
the system
functions in the following manner.
Completed units of work are
presented
by contractor
personnel
as ready for FQC inspection.
S&W Construction
Supervisors
inspect the work, and if satisfied,
actually request
the
FQC inspection.
S&W Construction Supervisors
can initiate "unsats"
on the
CCC forms for various situations
as defined in the
CMP including when the completed unit of work
has
been
presented
for S&W Construction
Supervisor
inspection
by the Contractor,
and the Supervisor finds an unsatisfactory
condition.
The
S&W CCCP Administrator also maintains
or compiles logs of
"unsats"
as indicated in
FQC Inspection
Reports (IR's) and
I
25
N&D's.
On
a monthly basis,
the
CCCP Administrator performs
an
analysis of the "unsats"
from all
CCC forms, IR's and N&D's for
each type of onsi te work in progress.
This analysis is further
subdivided to report
on the performance of each discipline and
contractor,
management
areas
and responsible
supervisors.
The
CCCP Administrator convenes
and chairs
a monthly quality
accountability meeting in which the analysis reports
are reviewed
wi,th the contractors
and corrective action requirements
for
recurring problems,
or of isolated
instances
of sufficient
magnitude to warrant special attention,
are discussed.
This
CCCP system
was found to be applied to major contractors
such
as Walsh,
L.K. Comstock
and ITT Grinnell
(embedments
only). It was first implemented
in late
1978 and continued
through
1979,
The anlysis of data
was di scontinued
throughout
1980
and for approximately the first half of 1981 dur'ing the
construction
slowdown.
Recent
CCCP analysis reports
and
accountability
meeting activities were 'inspected for L.K.
Comstock (for primarily September
1981 activities)
and September
and October,
1981 activities for Walsh. This inspection disclosed
areas
of weakness
with this program
as discussed
in the following
two paragraphs.
(410/81-13-03)
Contractors
develop
proposed
preventative
actions/commitments
which are discussed
and finalized as
a part of this process.
At
the time of this inspection,
however,
there
was
no formal
mechanism
or closure
loop for items identified,
as requiring
additional action.
The
CCCP Administrator had relied
on verbal
communication together with a lack of recurrence
as the method
of satisfying that preventative
action
had taken place.
In
response
to the inspector's
concern,
however,
a mechanism
was
implemented
before the
end of this inspection wherein objective
evidence of corrective/preventive
actions
must
be furnished the
CCCP Administrator before that item is closed.
Thus, this part
of the weakness
has
been satisfactorily
addressed.
In the
CCC analyses
examined
by the inspector,
more than
90% of
the "unsats"
had been
implemented
by FgC.
Further analysis
by
the
CCCP Administrator supported this approximate ratio (in one
case,
only 3 of 32 had been
implemented
by construction).
Since construction
performs final inspection before calling
FgC, these
numbers
suggest
several possibilities, i.e., inspection
by construction
to less stringent criteria than
FgC, construction
is not implementating
the
CMP in the intended
manner,
FgC
"unsats"
are subjective
in nature wherein construction
had
judged the
same condition to be "sat", etc.
Time did not
permit the inspector to examine this area
in enough detail to
determine
the source of these
apparent
discrepancies.
Regardless
of the cause,
the discrepancies/
inconsistancies
between
FgC
and construction indicate that the
CCCP system
used for
reviewing/monitoring contractor
performance is not working as
l
A
~
26
well as it should in that very few Construction
Supervisor
problems with contractors
are being
used in the evaluation of
contractor quality performance.
This part of the weakness
within the
CCCP system
had not yet been satisfactorily addressed
by the end of this inspection.
In addition to the weakness
discussed
above,
review of the data
for the accountability meeting for Walsh covering the period
August 31,
1981 to October 4,
1981 further supports
the finding
in Section 2.2.2.2 that contractor quality training is an
example of noncompliance
(410/81-13-01).
The proposed
preventative
action. for twenty-five "unsats" called for more
training with actual
numbers
as follows:
three called for
additional training of placement
personnel,
two applied to
concrete
curing crews,
four applied to carpenter
crews,
and
sixteen applied to ironworker foremen.
4.1.2.3
4.1.2.3.1
Mana ement Involvement
Mana ement
Re ortin
NMPC and
S&W jointly utilize an extensive
meeting
and reporting
system to keep project management
appraised
of the nature of
issues,
status
and progress,
assignment
of responsibilities for
followup, etc.
These
include monthly Project Progress
Reports,'anagement
Action Reports,
Executive
Summaries,
and Project
Meetings with subsequent
"Notes of Conference".
Monthly Management
Review Meetings are held with onsite contractors
to discuss
performance
data,
manpower utilization and any problem areas.
NMPC personnel
assigned
to NMP-2 project
have
a system of
weekly progress
reports which are
used to describe their weekly
activities, progress
and problems in their assigned
areas,
status of work, etc.
These
are
combined at each higher level
of management
resulting in at least monthly progress
reports
for each organizational
entity.
Review by the inspector of samples of reports
from each of the
above categories
indicated active
management
involvement at all
levels in these
management
meeting/reporting
systems.
No
noncompliances
or weaknesses
were observed
in this part of the
inspection.
4.1.2.3.2
~St.a ffi a
In addition to the inspector's
review of staffing levels discussed
in Section 4.1.2.1 staffing levels were discussed
with numerous
personnel
contacted at all levels within the
NMPC and
S&W
project organizations.
In no case did any staff member identify
any significant problem with any aspect of staffing including
approval of requested
staffing levels,
views of staff adequacy,
or maintaining adequate
staffing levels.
I
s
~
No noncompliances
or weaknesses
were identified,
Problems
As
a result of problems
encountered
at NMP-2 with the Biological
Shield Wall, a mechanism
was set
up for systematic
evaluation
of current
QA problem events
and to act as
a vehicle for providing
improved communications.
N&D's, E&DCR's, Problem Reports,
Inspection
Reports,
and
NRC,
NMPC, and
S&W audit findings are
reviewed to identify potential generic
problem areas
per procedure
PRS of the Project Manual.
In addition,
Event Analysis Reports
can
be initiated by anyone
who believes that
a subject
needs
further investigation or action to prevent the development of a
serious
problem.
Any of the above that represent
real
or
potential significant problems
are reviewed in monthly Potential
Problem
Review Meetings
(PPRM) attended
by key
S&W and
QA/QC and project personnel.
Assignments of action parties
and
completion dates
are
made
as required.
Interoffice memos,
an agenda,
a monthly summary report of
findings examined for quality trends or potential
problems,
and
the notes of a
PPRM meeting were inspected.
Functioning of this
group was discussed
with S&W QA and
NMPC project management
personnel.
No noncompliances
or weaknesses
were identified.
Mana ement
Reviews ...
Most management
reviews of performance
of individual departments
or sections
was found to be accomplished
informally (verbally).
NMPC does periodically (every six months)
and formally .review
S&W performance
in major areas
such
as quality assurance,
engineering
and construction with certain incentive
awards
based
on the results of these
reviews.
Similarly,
NMPG and
S&W
jointly review contractor
performance
on
a periodic basis with
any incentive
awards (for those with incentive clauses)
based
on the results of these
management
reviews.
At the time of
this inspection,
one of the major contracts
was in the process
of renogiation with significant additions
expected
in the area
of performance/incentive
clauses.
The inspector
found that
significant changes
in
S&W and contractor
management
personnel
assigned
to the
NMP-2 project
had been
made
as the result of
management
performance
reviews.
The most significant overall
mangement
reviews of the project
were
made
as
a part of a
NMPC directed
1980 Black & Veatch/Arthur
Anderson audit and
a
New York Public Service
Commission directed
audit, by Theodore Barry & Associates/Conaton,
Inc.
(TB&A)
completed in 1981.
Review of the
TH&A audit disclosed that the
objectives
and
scope
included control of the project (project
management),
engineering
and construction activities.
It'
charter
included to "provide an overall assessment
of the
k
-Cg
t
i
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I
28
quality assurance/quality
control efforts of'tone
and Webster
and Niagara
Mohawk."
Review of the
TB&A recommendations
showed
that they were primarily in the area of project management
and
did not directly pertain to gA.
Most of them involved
recommendations
of increased
involvement by
NMPC in project
control
and monitoring in the areas
of cost
and schedule.
Much
of the increased
NMPC project staffing within the past year
has
been in response
to these
recommendations.
Review of the mechanisms
for assigning
action responsibilities,
tracking status of commitments
and handling overall
responsiveness
to the recommendations
from both of these audits
showed
them to be effective in controlling follow-up activities.
4.1.2.3.5
No noncompliances
or unresolved
items were identified.
Other Information Channels
Neither
S&W or
NMPC has
a formal system for handling allegations,
suggestions
or worker complaints.
In numerous
interviews at
all levels,
however,
personnel
expressed
no reluctance
to go to
management
with any concerns
about workmanship or quality.
No
concerns
were expressed
about job protection in the event they
were to express
such concerns.
None of the interviewed manager'
could recall
having received
any information that they would
characterize
as
a formal allegation.
4.1.2.3.6
No noncompliances
or weaknesses
were identified.
Mana ement/Em lo ee Interface
Management's availability to employees,
interest
and dedication
to quality and support to employees
was explored in contacts
with all levels of personnel
in
NMPC and
S&W as well as onsite
contractor personnel.
All personnel
indicated that their
managers
were readily available
most of the time in the various
work areas.
All contacted
personnel
indicated
a perceived
emphasis
on quality at all organizational
levels with the
exception of some perceived
lack of support fo the
NMPC guality
Assurance
Department
as discussed
in Section 2.2.8.2.
4.2
No items of noncompliance
or weaknesses
were. identified.
Documents
Reviewed
The following is a list of the primary documents
reviewed
during the course of this part of the inspection.
l
p
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29
4.2.1
Nine Mile Point Unit 2 Project Manual,
Volumes I-V
Weekly and Monthly Progress
Reports (at various organizational
levels).
Meeting Minutes for Weekly Area and Task Force
Meetings
Project Status
Summary Report ("Executive
Summary" ).
Organization
Charts.
Various Internal
Correspondences
Status
Report (Draft) .for
NMPC Project Procedures
(PPNM)/Project
Memoranda
(PMNM).
4.2.2
SKW
CMP 1.11-8.79,
Construction Controls
and Completion
Program
CCCP Analysis and guality Accountability Meeting
Reports
Monthly Project Reports
Management Action Reports
Agenda for Management
Review Meetings
(and Minutes)
PPRM memos,
Agenda,
Monthly Summary Report
and
Meeting Minutes
4.2.3
Organization
Charts
Interoffice Memos
Other
Theodore Barry & Associates/Conatom,
Inc. Audit of
NM2 Project
5.0
Procurement
Control
The objective .of this part of the inspection
was to determine
whether the purchase
of components
and materials for systems
important to safety
was in conformance with the licensee's
approved quality assurance
program
and implementing procedures.
l
)
1
$
~
30
Areas Ins ected
Procurement
Documents
The inspector
examined
procurement
and specification
documents for the following materials
and components:
C041-D
, Resistance
Temperature
Detectors
C071-M
Electronic Transmitters
E021-P
Electrical Penetration
E023-C
600 Volt Power Cable
E024-A
1000 Volt Fire Resistant
Cable
E024-P
300 Volt Instrument
Cable
E024-T
Co-Axial Cable
E026-A
Cable Trays
P281-F
Category I & II Radiation Monitoring
Equipment
The inspector verified that the documents
used in the purchase
of components,
equipment or types of materials in systems
important to safety include proper approval, quality inspection
requirements,
and quality record requirements.
No items of noncompliance
were identified.
Document Control
In reviewing the above
documents,
the inspector
noted
a possible
problem area
in that the individuals receiving the control
level
1 documents
were making penciled notations
in the control
document.
The inspector specifically cited the
C071-M document
in the guality Assurance
and Engineering
group.
The document
assigned
to each
group was extensively
marked
and the information
transferred
from the accompanying
addendums
was in error.
The inspector
determined this to be
a problem in document
control that could res'ult in misinformation.
The licensee
took immediate action by issuing
a project
memorandum
requiring all such notations in control documents
be notarized
and dated
by authorized
personnel.
In addition, the licensee
has
agreed
to review this area
and determine
adequacy of the
control measures.
This item is considered
resolved.
l
1
<~
~
31
Conformance with Procurement
Documents
The inspector verified that documentary
evidence is available
onsite to support
conformance
to procurement
documents.
The
inspector
reviewed cable qualification data
from two suppliers
and found the data to be in conformance with the procurement
document.
C
No items of noncompliance
were identified.
S ecification
Chan
es
The inspector
examined the cable tray specification
document
E026-A to determine
whether
changes
made in the procurement
document
as
a result of the bid evaluations
or precontract
negotiations
were subjected
to review and that
such reviews
. include the determination of any additional or modified design
criteria imposed after preparation
of the initial procurement
document
as the result of subsequent
analysis of exceptions
made or requested
by the supplier.
The inspector determined that'the qualification tests
(Vendor
Report
No. 24781)
does not conform to the specification
requirements
of E026-A.
Examples of differences
between
the procurement
specification
and the vendor
supplied qualification results
were as follows:
line 291-294 of specification
E026A, states,
in part,
that:
"Except as specifically stated or otherwise inferred,
the cable tray shall
conform to the requirements
of NEMA
standard
VE-1 for cable trays."
Section
VE1-3.01 of the
NEMA document states,
in part,
that:
"The working (allowable)
load capacity represents
the ability of a cable tray to support the static weight
of cables.
It is equivalent to the destruction .load
capacity,
as determined
by testing in accordance
with
paragraph
VE1-4.01."
VE1-3.02 specifies
three working load categories
for cable
trays
as 50,
75 and
100 lbs. per linear foot.
The cable tray supplier
used
35 lbs. per foot as allowed
by an engineering
change
in the specification.
Engineering
justification, however, for deviating from the
NEMA document
was not
available'E1-4.01,
paragraph
B, states,
in part, that:
"test
spans
shall
be simple
beam
spans with free unrestrained ends....."
I
~
p
4
32
VE1-4.01, paragraph
0, states,
in part, that:
$"Each end
of the
specimen
shall
be supported
by a
1 1/8 inch wide by
3/4 inch high steel
bar(s) with a
120 degree
"Vee" notch
cut in its bottom to a depth of 3/16 inch.
The "Vee" notch
shall rest
on
a I inch solid round steel
bar which is
welded
~ ~ ..."
Sketch
No. 86, of the Test Report
No.
24781 illustrates
a
different test mounting configuration
used for the static
load test of the cable tray specimen.
The sketch
shows
two
illustrations of cable tray specimens,
one bolted and the
other clamped,
both in the horizontal position
on
an "H"
type unistrut frame.
Pg 2-2a of specification
E026-A, states
in part, that:
"...base
natural
frequency of cable tray shall
be determined.
Vertical fundamental
frequency shall
be above
20 cps,
verified by calculations
using the stiffness data obtained
during the performance
of vertical loading and horizontal
tests
specified.
~ ."
Since the tray specimen static load data
was obtained
from
tray specimens
that were bolted/clamped
in position,
the
stiffness data obtained is much higher than would have
been obtained if the test were performed
as specified,
thus affecting the calculation
used in verifying the >20
cps frequency requirements.
On page
C-10,
item (3) of the qualification test Report
No.'24781,
the supplier states,
in part, that:
"...we
will use only unspliced straight sections
for frequency
tests
since splice plate fittings give erroneous results."
Item (f), same
page of test Report
No. 24781.
The supplier
indicated that since past experience
has
shown that fittings
were weakest in the vertical direction, they intended only
to conduct the seismic tests
on the horizontal
elbow.
Item (h),
same
page of test Report
No.
24781 the supplier
states:
"...frequency tests
conducted without hold clamps
on trays."
The review document
(BK7801270015) of the suppliers technical
document
shows engineering
approval
as defined by the
specification.
It appears
that the supplier was unable to meet the original
requirements
and is performing tests
which do not meet
minimum
commercial
standards
as specified in
NEMA VE-l. In addition,
engineering justification for the less restrictive tests
was
not available.
~
f
4
33
The licensee
was informed that this is an item of noncompliance
and
an infraction of 10CFR50 Appendix B, Criterion VII, which
states,
in part, that:
"Measures
shall
be established
to
assure
that purchased
material,
equipment
and
services'
..
conform to the procurement
documents."
(410/81-13-04)
>
ualification of Su
liers
The inspector verified that the licensee
has established
procedures
for the selection of qualified suppliers of services,
materials
and components
and that the established
procedures
are being implemented.
S ecification Review
The inspector
reviewed specification
No.
P281F for Category I
and II Radiation Monitoring Equipment to determine whether the
procurement
document contains applicable technical
and
requirements
necessary
in meeting
NRC licensing requirements
and
SAR commitments.
The inspector questioned
the adequacy of
the Category
1 Radiation Monitoring Equipment in meeting the
sensitivity detection
requirements
and Regulatory
Guide 1.45.
It appears
that the Radiation
monitors containing
two or more channels
are of the series
type.
This implies that the
sample flow rate through the
systems
would be the
same.
Published data,
however,
indicates
that particulate
and gaseous
radiation monitors require
a high
flow rate (8-10 cfm) to meet sensitivity detection
requirements
and
a low flow rate (1-2 cfm), for iodine detection
due to
absorption charactistics
of the charcoal cartridge.
In addition,
criteria for installation of the Radiation Monitoring Equipment
were not defined.
Since the Radiation Monitoring function is
dependent
upon obtaining
a representative
sample, installation
of the
sample line should
be compatible with the equipment
being installed.
Discussions with the licensee
indicates
the
P281F specification
has
been withdrawn and that
a
new specification
is being drafted which addresses
the inspectors
concerns.
-The
inspector
had
no further questions
at this time.
Detection of Reactor Coolant
Leaka
e
The inspector
reviewed section 5.2.3.12 of the
PSAR on Primary
Containment
Leakage Monitor System
and section H.3.13 of Appendix
H on Containment
Atmosphere Monitoring.
Criterion 30 requires that means
be provided for detecting
reactor coolant leakage.
Regulatory Guide 1.45 provides the
minimum acceptable
method for detecting reactor coolant leakage.
The guide states
that one of two required
methods
shall
be by
Radiation Monitor of a sample.
No such provisions
have
been
made in the
NMP 2 design.
The licensee
has not taken
a position
on implementation of Regulatory Guide 1.45 or its equivalent.
4
h
~
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4
34
This is an unresolved
item in that
an acceptable
method of
meeting
10 CFR 50 Appendix
A requirements
has not been
implemented
to date.
(410/81-13-05)
5.1.8
Cable Tra
S acin
The inspector
noted that the licensee's
response
to
NRC question
R8.9, listed in section
8 of the
PSAR supplement
6 requires
some clarification.
Section 6.2.3,
paragraph
3 of the response
states,
in part:
"As a minimum, where vertical stacking of trays...at
least
12
inches will be maintained
between
top of tray below and the
bottom of tray above.
~ .."
Section 6.2.3 paragraph
6 of the
response
states,
in part:
"... In tray crossovers
at least
an
18 inch clear
space
shall
be maintained...."
Section 8.1.1 of the response
states,
in part:
"... In general,"
the minimum vertical
spacing for cable trays wi 11
be
17 inches,
measured
between
cable tray bottoms for trays with an inside
depth of 4 inches
and
16 inches for trays with an inside depth
of 3 inches."
Electrical Specification
E061A specifies
a
12 inch clearance
space
between trays.
6.0
The response
contains conflicting space
separation
requirements
for vertical stacking of trays.
The licensee
response
indicates that design control measures
have not been
implemented for verifying or checking the adequacy
and consistency
of design criteria.
Specified criteria were
not included in the erection specification.
This is an additional
example of noncompliance
with the
requirements
of 10 CFR 50, Appendix B, Criterion III
(410/81-13-02).
Electrical
The objective of this part of the inspection
was to observe
work performance, partially complete work and/or completed work
as appropriate,
associated
with the emergency
(standby) diesel
generator
and the motor control centers
to determine
whether
the requirements
of applicable specifications,
work procedures
and inspection
procedures
are being accomplished
in accordance
with NRC requirements
and licensee
commitments.
6.1
Areas Ins ected
4
EV
35
6.1.1
E ui ment Stora
e In-Place
The inspector
examined
the control of equipment stored-in-place
foi post-installation protective requirements,
physical protective
barriers,
protection
against
condensation
and surveillance
activity.
6.1
~ 2
No. items of noncompliance
were identified.
Receivin
and Stora
e Documentation
The inspector
reviewed receiving documentation,
certificate of
compliance,
documentary
evidence of tests
performed
and
surveillance
records of equipment identified above.
The inspector
found the documents
to be legible, easily retrievable
and
current.
6.1.-3.
No items of noncompliance
were identified.
Stora
e Faci lit
7.0
The inspector
examined
the level
A and level
B storage facility.
The records confirm that the equipment is stored
in the proper
area,
the inspection activity is performed
as required
and the
required protection
has
been provided.
No items of noncompliance
were identified.
Mechanical
and
7.1
Previous
0 en Items
7.1.1.1
Cl osed
Unreso 1 ved Items
80-04-01
and
80-04-02
These
unresolved
items concern clarification of the criteria to
be used for the disposition of ultrasonic indicat'ions reported
in tests
conducted
on inner wall, cover plate
and stiffener
welded junctions in the biological shield.
The metallurgical
studies
which were incomplete at the time of issuance
of 80-04-01
were reviewed by the
NRC inspector
and are
summarized
in
S8W
Report "Final Report
on Biological Shield Mall Nine Mile Point
Nuclear Station Unit 2" forwarded to
Detailed finite element
( FE) analyses
and linear elastic fracture
mechanics
(LEFM) analyses
were conducted
on each type of suspect
welded joint in the biological shield with results indicated in
the aforementioned
document.
The engineering disposition of
the ultrasonic indications
was based
on the calculated
FE and
LEFM acceptable
defect sizes.
Engineering evaluation of defect
sizes for acceptance
purposes
is an acceptable
practice for AMS
Dl.l structures.
These
items are considered
resolved.
J
<) ~
36
7.1.1.2
Closed
Unresol ved Item
81-09-01
This item concerned
the demonstration
of the adequacy
of a
complete
composite joint for safety related
attachment
made to the bioshield which includes
a weld overlay on the
bioshield wall.
The licensee
has committed
S&W to conduct
an
engineering
evaluation
weld mockup test assembly
as specified
in
E&DCR F10525.
S&W and
NMPC has committed to answer
concerns
raised in inspection report 50-410/81-09,
paragraph
8(b) concerning
inadequacies
in the
(B-U3-GF)/13640 by revision
to the
MPS.
The subject inspection report erroneously
reported that the
filler metal certification for the
where iq .fact. the test. was conducted with 100% C02.
This item
'is- considered
resolve~
b-sed- on the licensee's-
commitments.>>
7.1.1.3
Closed
50.55
e
Item
79-00-01
This item was previously discussed
in inspection reports
79-09,
81-09
and 81-12.
Inspection report 81-09 indicated resolution
of 7 of the
8 items (weld joint configurations).
The instrument
penetration-adaptor
to sleeve
welds could not be resolved
due
to the lack of availability of UT examination
records for the
sampling
UT tests
conducted.
Discussions with the licensee
and
review of documents
indicated that
no
UT records of the examination
were available
due to the generation
of spurious reflector
signals
caused
by the special
geometry including
a combination
of small diameter,
thin wall and dissimilar metal welds.
The
reflectors
negated
proper evaluation of the data
and full
compliance with ASME Code
UT inspection
requirements.
Engineering
review of the
ASME Code requirements
indicated that
UT was not
a code acceptance
requirement for the'configurations
welded.
The
NRC inspector
reviewed calculations
and the design requirements
for the joints.
This data indicated that,
in addition to the
code required safety factors,
the actual
weld size resulted
in
a multiplier factor of 2 or more for all but two joints (3.5"
diameter).
For the 3.5 inch weld joints, the additional
safety
factor multiplier is approximately 1.3.
These
two joints were
given
a verification
PT examination
as witnessed
by the
NRC
inspector
and reported in
S&M PIT00068 which showed
no indications.
No further response
is required.
This item is considered
to be
closed.
7.2
7.2.1
d~ld
Visual Observation
of Weldin
The following welds were visually inspected
by the
NRC inspector
including review of ISO drawings
and the welding documentation:
4'
) IP
~
P
(
,~~~.~P.k.CI 4-)V[()P V1 1379lil';,fl~)'~ "f
37
~Drawin
Material
Code
a.
ISO 25-13,
FW007
P8-P8
B31.1
CSH
10" x 0.365
b.
ISO 66-7,
FW003
Pl-Pl
III-2
12" x 0.375
c.
ISO 66-42,
FW014
Pl-Pl
III-2
6" x 0.280
The preparation for purge, joint fitup and the
SMAW portion of
weld a were observed.
During the
SMAW welding, the
NRC inspector
observed
a tong meter check of welding amperage.
This weld was
on the B31.1 side of the B31.1/ASME Class
2 breakline of
25-13-2-CSH-7-4-8.
7.2.2
b and
c were visually inspected
in the final
ground-for-RT condition.
Both of these
welds were rejected
on
RT.
The repair cycle has not been
implemented at the time of
the inspection.
The weld da'ta
sheets
for the original welds
were reviewed along with the filler metal requisition
forms.
The finished ground weld 'configuration 'for ISI inspection
was
a flush geometry rather
than
a flat top geometry.
No items of noncompliance
were identified.
Weldin
Material Control
The
NRC inspector
reviewed the
S&W filler metal control
specifically at the issue station.
The procedures
for purchasing,
receiving, storing
and distribution to the issue station
were
previously reviewed
and re-reviewed at this time.
The
identification, storage
and control in accordance
with procedures
was reviewed.
The procedures
for controlling moisture in
hydroscopic filler metals
were reviewed.
It was Inot~ed that,
with the exception of one can of filler metal held for turbine
pipe welding, the only carbon
on low alloy steel
SHAM filler
metal in the issue station
was
E7018.
7.3
No items of noncompliance
were identified.
Documents
Reviewed
Interoffice correspondence
G.
Phi lippi to C. Eri ksson
and
reply by Eriksson dated
December
4,
1981 regarding
clarification of "numerous indications"
as quoted in C.
Eriksson letter to P.
M. Mcguaid dated
September
10,
1981
on
UT evaluation
examination of penetrations.
S&W Project
Memo
(NMP 2)
PM70
Rev
1 dated
February
17,
1981.
D.
P.
Pope
Report to
S&W, "Horizontal Stiffener to Inner
Shell Wall," dated
February,
1980.
<<s
g A
38
D.
P.
Pope
Report to
SKW, "Horizontal Stiffener to Inner
Shell Wall," dated April, 1980.
Dr.
C.
Mel Adams letters to K. Ward dated
March 23,
1980 and
April 28,
1980.
SEW Metallurgical Report,
NMP2, Unit 2, "Biological Shield
Wall Base
Ring to Outer Shell Weld," dated January,
1980.
Teledyne
Engineering
Services
(Waltham, Mass.) Technical
Report TR-4250-1
dated
May 15,
1980,
"Cause,
Repair
and
Engineering
Assessment,
of Weld Failures in the Biological
Shield Wall for NMP 2."
C.
C. Zappi le to C.
D. Terry letter 9M2-1,453, dated
December
10,
1981,
Instrument Penetrations
NRC
IE Inspection
81-12
NMP Nuclear Station
Unit 2."
8.0
Unresolved
Items
Unresolved
items are matters
about which more information is required to
ascertain
whether they are acceptable
items,
items of noncompliance,
or
deviations.
An unresolved
item disclosed during the inspection is discussed
in Section 5.1.7.
9.0
Exit Interview
The inspectors
met with the licensee
representatives
(denoted
in Section
1)
at the conclusion of the inspection
on December
11,
1981
and December
18,
1981 at the Nine Mile Point Unit 2 construction site 'and Syrocuse
corporate
offices respectively.
The inspectors
summarized
the
scope of the inspection
and discussed
the inspection findings.
/
'I I