Text

SALP Rept 50-410/85-99 for Oct 1983 - Jan 1985.Util Must Implement Measures to Offset High Levels of Personnel Turnover.Deficiencies Detected Re Primarily Electrical Equipment Supplied by Numerous Vendors
	ML17054B564
Person / Time
Site:	Nine Mile Point
Issue date:	04/17/1985
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
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ML17054B565	List: ML17054B564;
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	50-410-85-99, NUDOCS 8504190357
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U.S.

NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT

OF LICENSEE

PERFORMANCE

INSPECTION

REPORT 50-410/85-99

NIAGARA MOHAWK POSER

CORPORA1 IOH

NINE MILE POINT, UNIT 2

ASSESSMENT

PERIOO:

OCTOBER 1,

1983 - JANUARY 31,

1985

BOARO MEETING OATE:

MARCH 28,

1985

IIt1[419I357

850g4

7

PDR

TABLE OF CONTENTS

~Pa

e

I-

INTRODUCTION................;........'.......................

I.

B.

C.

Purpose

and Overvfev..........................

SALP Board Members............................

Background....................................

I. CRITERIA.............................

I

III. SUMMARY OF RESULTS..........................................

IV.

A.

B.

Overall Facility Evaluation...................

Facility Performance..........................

PERFORMANCE ANALYSIS...............................

7

9

10

A.

B.

C.

0.

E.

F.

G.

H.I.

J.

Containment

and other Safety Related Struc

Piping Systems

and Supports...............

Safety Related Components-Mechanical......

Support Systems............'...............

Electrical

Equfpment

and Cables.....

Instrumentation

and Control Systems.......

Lfcensfng Actfvftfes......................

Prospect Management/quality Assurance......

Nondestructive Examfnatfon................

Engfneering...............................

ture5

~ ~ ~

~

~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~

~

~ ~ ~ ~ ~ ~ ~ ~ ~

~

~ ~

~ ~ ~ ~ ~ ~ ~

~ ~

~

10

12

15

17

18

20,

22

25

28

31

V.

SUPPORTING

DATA AND SUMMARIES.................,...........,.

A.

B.

C.

0.

TABLES

Investigations

and Allegatfons Revfev...

Escalated

Enforcement Actions...........

Management Conferences..................

Construction Deficiency Reports

(CORs)..

34

35

36

TABLE 1 - CONSTRUCTION DEFICIENCY REPORTS........

TABLE 2 " INSPECTION

HOURS SUMMARY.......,...,.....

TABLE 3

ENFORCEMENT DATA........................

TABLE 4 " INSPECTION

REPORT ACTIVITIES............

TABLE 5 - NRR SUPPORTING DATA......................

37'8

39

43

46

l '

I.

INTROOUCTION

A.

Pur ose

and Overview

The Systematic

Assessment

of Licensee

Performance

{SALP) is an inte-

grated

NRC staff effort to collect the available

observations

and

data

on

a periodic basis

and to evaluate

licensee

performance

based

upon this

information.

SALP is

supplemental

to

normal

regulatory

processes

used

to ensure

compliance

to

NRC rules

and

regulations.

SALP is intended

to be sufficiently diagnostic to provide- a rational

basis for allocating

NRC resources

and to provide meaningful

guidance

to the licensee's

management

to promote quality and safety of plant

construction

and operation.

A NRC

SALP Board,

composed of the staff members listed below,

met on

Harch

28,

1985 to review the collection of performance

observations

and data to assess

the licensee

performance

in accordance

with the

guidance in NRC Hanual Chapter

0516, "Systematic

Assessment

of Licen-

see Performance."

A summary of the guidance

and evaluation criteria

is provided in Section II of this repor't.

B.

SALP Board

Board Chairman

R.

V.

Starostecki,

Director,

Oivision

of

Reactor

Projects

(ORP)

Members

S. J. Collins, Chief, Projects

Branch No. 2,

ORP

J. P. Ourr, Chief, Engineering Branch, Oivision of Reactor Safety

(ORS)

R. A. Gramm, Senior Resident Inspector,

Nine Hile Point Unit 2

J. Linville, Chief, Projects

Section

No.

2C,

ORP

A. Schwencer,

Chief, Licensing

Branch

2, Office of Nuclear

Reactor

Regulation

C.

~Back round

1.

Licensee Activitives

The licensee

has

stated

the project is 85~ complete.

Construc-

tion installation activities

have

included

small

and

large

bore

piping

and

supports;

raceway

installation,

cable

pul1ing,

and

cable

terminations;

and

instrumentation

tubing

and

supports.

The installation of concrete

and structural

steel

is essentially

complete.

Equipment

has

been

released

to the Startup

and

Test

organization

to support

the pre-operational

test

schedule.

The

site

work force

as

of January

was

7200

manual

and

non-manual

personnel.

Approximately

650 of those

personnel

perform

QA or

QC functions.

n

II

I

Ouring the course of the assessment

period, the Nine Mile point,

Unit 2 project

has

passed

through

several distinct phases.

The

Construction

Appraisal

Team

(CAT) inspection

was

conducted

in

November

and

Oecember,

1983.

That inspection effort identified

far ranging deficiencies

in the application of QA programs

on-

site

and

an

inadequate

level of Niagara

Hohawk project involve-

ment.

The project then entered into the second

phase,

CAT prob-

. lem resolution.

The

CAT identified deficiencies

were analyzed

at great length by the licensee

in order that suitable correc-

tive action

plans

could

be

developed.

During this phase,

the

licensee

realized

that

not only

woUld

hardware

and

software

issues

need

to be rectified, but that additionally,

new manage-

ment practices

would have to be

implemented

to

see

the project

throu 'o successful

completion.

The

HRC '.hen formally commun-

ica'>>e

CAT deficiencies

to the

licensee

in the

form of

a

Notii

Violation and simultaneously

mandated that the licen-

see i ~q

'nt additional actions in response

to an Order.

- ';y

'..

.~34,

the bulk of the

CAT corrective

actions

had

been

ir'iiated

at

the

project.

The

Region'

NOE

Van

inspection

began

the third

phase,

being

the verification of corrective

action

implementation.

Th~t inspection

showed

steps initiated

to resolve

the radiography

problems

had not fully resolved

the

CAT concerns.

The

van

inspection

prompted

further

extensive

licensee

actions

in the

form of complete

reinterpretations

of

all ITT Grinnell radiography film.

Late in the assessment

per-

iod,

a Region I Construction

Team Inspection

was performed.

The

inspection

covered

plant

installation/<nspection

activities

involving representative

plant hardware.

- Ho significant defic-

iencies'ere

identified regarding

the application of site qual-

ity programs.

Over the course of the

assessment

period,

the licensee

has also

implemented

corrective

actions

with the specific

goal

of in-

creasing

the overall plant quality.

The licensee

is performing

increased

surveillances/audits

of contractor

performance

partic-'ularly

as it relates

to hardware quality.

The licensee

QA or-

ganization

performs

an on-going

review of inspection

procedures

to

assure

adequate

accept/reject

criteria definition

and

in-

depth

assessments

have

been

performed of the contractor

QA or-

ganizations.

The licensee

has instituted

a complete

management

reorganization

at both corporate

and site levels.

The licensee

has retained

Management Analysis Company

(MAC) to provide nuclear experienced

personnel

to fill both project

and quality assurance

positions.

The licensee

has significantly improved their control of site

activities by locating project management

on-site

and by modify-

ing the line organization

such that the Stone

and Webster Engi-

neering

Corporation

(SWEC) Project

management

reports directly

to the licensee.

New QA management

has

been brought on-site for

SWEC and the sub-contractor

organizations.

An. IHPO construction

audit was performed

between

September

and

October,

1984.

Site

programs

in the

area

of design

control,

material

storage,

gA program effectiveness,

equipment qualifica-

tion, and test activities were reviewed.

Ho preoperational'tests

have

been

conducted

to date.

The Reac-

tor Coolant System hydrostatic test is scheduled for April 1985.

2.

Ins ection Activities

During the

16 month as

essment

period,

a total of 25

o'nsite

HRC

inspections

involving 5408 inspector hours (or 4055 hours0.0469 days 1.126 hours 0.0067 weeks 0.00154 months

on

an

annual basis)

were conducted with a distributio; in the apprais"

al functional areas

shown in Table 2.

The site

has

been

staffed

with a construction resident

inspector during the entire assess-

ment period and

a second

construction

inspector

was assigned

in

October

1984.

An additional

senior resident

inspector

was de-

tailed

on part-time

basis

to monitor the

pre-operational

test

program.

A CAT inspection

was

conducted

in November

and

Oecember

1983.

The inspection ide'ntified numerous

hardware

and software defic-

iencies.

The

implication of the

identified deficiencies

was

that the site

had suffered

a

gA program

breakdown

and that in-

adequate

licensee

management

attention

had

been

focused

on the

site problems.

The

inspection

resulted

in the

issuance

of

an

Enforcement Action comprised of a Notice of Violation, an 0~der

and, a Civil Penalty.

Following the

CAT inspection

an

Augmented

Inspection

Program

was initiated at

the site

by

Region I.

As

part

of

this

program,

other

Region

I

senior

construction

resident

inspectors

were

detailed

to

the

site

for one

month

tours

to

gain

additional

perspectives

regarding

the

project

quality status.

As

a

followup to

the

CAT,

a Nondestructive

Examination

(NOE)

Region

I inspection

was

performed

in April -

Hay,

1984,

The

inspection

detected

further

problems

with the site

review of

radiographic film.

In order

to

gain

additional

perspective

regarding

the effec-

tiveness of licensee corrective actions following implementation

of

- CAT corrective

actions,

a

Region

I Construction

Team

In-

'pection

(CTI) was

conducted

in December

1984.

The inspection

examined

prospect

management,

quality assurance/control

programs,

and installed

hardware.

In general,

the

inspection

found the

hardware installations to be in accordance

with design

require-

ments

and

detected

improved levels .of management

involvement.

In early

1985,

an

inspection

reviewed

the

preoperational

test

staffing

and

procedural

controls.

They were

found to be ade-

quate

to

support

the

forthcoming

preoperational

test effort.

Tables

3 and 4 provide a synopsis of enforcement

data

and inspec-

tion activities conducted during the appraisal

period.

II'

~

2

{ \\I

d. ~

I

~

~'o%~,

~

2

II.

CRITERIA

'icenseeperformance

i s assessed

in selected

functional

areas,

depending

on whether the facility is in a construction,

preoperational,

or operating

phase.

Each

functional

area

normally

represents

areas

significant

to

nuclear

safety

and

the

environment,

and

are

normal

programmatic

areas.

Special

areas

may be added to highlight significant observations.

One or more of the following evaluation criteria were used to assess

each

functional area.

1.

Hanagement

involvement and control in assuring quality

2.

Approach to resolution of'echnical

issues

From

a safety standpoint

3.

Responsiveness

to

NRC initiatives

4.

Enforcement history

5.

Reporting

and analysis of reportable

events

6.

Staffing (including management)

7..

Training effectiveness

and qualification

Based

.upon

the

SALP

Board

assessment

each

functional

area

evaluated

is

classified into one of three

performance

categories.

The definitions of

these

performance

categories

are:

~dl. Rd

dRRC

I

2

I

.

U

attention

and

involvement

are

aggressive

and

oriented

toward

nuclear

safety;

licensee

resources

are

ample

and effectively used

so that

a high

level of performance with respect to operational

safety or construction is

being achieved.

2~2.

IIRC

U

h

Idh

I

d

11

1.

U

management

attention

and

involvement

are

evident

and

are

concerned

with

nuclear

safety;

licensee

resources

are

adequate

and

reasonably

effective

so that satisfactory

performance

with respect

to operational

safety

or

construction is being achieved.

~CR.

2

h

IIC

d<> .

cate installations correctly- rather

than relying on gA/gC to detect

deficiencies.

Because o'ifficulties experienced

in retaining qualified personnel,

it is necessary

for the site

to

implement

measures

to offset high

levels of personnel

turn'over.

Increased

supervisory oversight of job

performance

and

augmented

training to quality requirements

appear to

be needed.

Project management

attention is necessary

to ensure

that

trained,

qualified craft

and quality

inspectors

are

available

to

support project schedules

without impacting hardware quality.

~

Hardware reinspection

programs

have been established

to determine

the

adequacy

of in situ installations.

The

NRC has

been

presented

with

the interim findings of those efforts,

and the engineering

analysis

associated

with the noted deficiencies.

While the licensee

analysis

shows thai

most

concerns

are

acceptable-as-is,

the

impact

of

the

findings

on

a determination

of overall

hardware quality remains

to

be provided.

Def)ciencies

have

been

detected

which involve primarily electrical

equipment

supplied

by

numerous

vendors.

The'roblems

indicate that

the

source

inspection activity was

not properly

performed

and

has

allowed

sub-standard

equipment

onsite.

Measures

are

required

to

assure

the

acceptability

of

these

components

and

to

address

the

extent of vendor equipment deficiencies.

In

some

instances

site initiated corrective action programs

have not

been totally implemented,

in that

long term actions

have

not always

been effective. This may result

from the lack of a comprehensive

site

commitment tracking

system

to monitor

and

assess

corrective

action

effectiveness.

'

Review of design

change

documents

indicates

that greater

attention

needs

to be paid to assuring

the clarity and technical acceptability

of the design

changes.

Further attention is required to verify that

licensing

comaitments

relative to component

gA level classification

are accurately translated to the site design

documents.

Better

com-

munication is needed

between engineering

and quality personnel

during

the development of inspection plans.

~

A high level of'anagement

attention is nov required to resolve the

outstanding

HRC deficiencies

and to assure

complete

licensee verif-

ication

and timely closeout.

To support

the

licensee

schedule

for

plant licensing,

the

pace of deficiency closeout

must rapidly accel-

erate.

t j

B.

Facilit

Performance

Functional

Area

Category

Last

Period

Category

This

Recent

Periad

Tren4

(10"1-82 - 9"30-83) (10-1"83 - '1"31"85)

A.

Containment

and other Safety

Related Structures

B.

Piping Systems

and Supports

C.

Safety Related

Components-

Hechanical

0.

Support Systems

E.

Electrical

Equipment

and Cables

F.

Instrumentation

and Control

. Systems

G.

Licensing Activities

H.

Project Hanagement/quality

Assurance

I.

Nondestructive

Examination

J.

Engineering

3

2

Not Assessed

2

Not Assessed

Consistent

Improving

Consistent

Improving

10

IV.

PERFORMANCE ANALYSIS

A.

Containment

and Other Safet

Related Structures

(15%)

1.

A~naI

sss

The

1 fcensee

has

essentially

completed

the

fnstal 1 atfon

of

structural

steel

and structural

concrete.

Inspection activity has

examined structural

steel installations;

hfgh strength

bolting;

concrete

placement;

structural

welding

and 'welder qualifications;

revetment

ditch installation;

con-

crete anchor bolts; and the reactor building enclosure.

Ourfng the previous

SALP period,

AISC high strength bolting crf-

teria were not properly implemented onsfte.

Inspections

have

fdentfffed

additional

examples

involving

Quality

Control

(QC)

acceptance

of structural

steel

bolted

connections

that violate

AISC acceptance

criteria.

Overall

QC

adherence

to

inspection

procedures

has

not

assured

the

com-

pliance of installed

beam connections vfth AISC criteria.

NRC

examination of connections

accepted

by

SWEC

QC within primary

containment

indicated

the presence

of oversized

hole geometries

for which hardened plate washers

were not appropriately

pro'vfded.

Further,

NRC examination of the Control

Rod Orfve Restraint

Beam

identified that

Reactor

Controls

Inc.

(RCI) personnel.

had not

erected

and

inspected

the

beam

connections

consistent

with

guiding AISC criteria since

requested

hardened

vashers

were not

used.

While the specific

hardware

installations

questioned

by

the

NRC

have,

been

addressed,

further

licensee

verification

measures

are

necessary

to establish

the

adequacy

of structural

steel

'connectfons.

More vigorous final

QC turnover inspections

are necessary

to address

the problem.

Vendor

QC and

SWEC Procurement

Quality Assurance

(PQA) programs

for structural

veld

inspections

have

not

been

appropriately

implemented

since

the

NRC

identified

undersized

Gives

shop

welds.

The

licensee

has instituted

a sampling

reinspection

of

Cives

veldments

to identify the

extent

of

the

deficiencies.

Engineering

has

analyzed

the identified deficiencies

and

found

them to be acceptable,

however,

the third party

assessment

has

recommended

further re-inspection

efforts to resolve this

con-'ern.

Further

examples

of

inadequate

source

inspection

are

discussed

fn functional areas

C and

E.

Licensee

activities

during

inspections

of concrete

pours

and

structural

steel

welds

made

onsite

were

observed

to

be

acceptable.

I

11

2.

Conclusion

Category 2, Consistent.

3.

Board Recommendation

NRC

'

~

Reduce

level of inspection

consistent

with level of licen-

see work'ctivities.

~

Monitor licensee

resolution

of AISC bolting deficiencies

(85-99-01).

~

Monitor licensee

resolution of inadequate

Cives

shop welds

(85-99-02).

Ucensee

~

Investigate

necessity

to perform

more vigorous structural

steel final

(}C turnover inspections.

~

Determine acceptability of Cives

shop weldments.

12

B.

Pi in

S stems

and

Su

orts (2')

1.'Ana'l sls

During the previous

SALP period,

concerns

were identified re-

garding

inadequate

review of ITT-Grinnel1

(ITT) work planner

packages.

The

licensee

has

implemented

effective measures'n

response

to those

concerns

as

no further

problems

have

been

detected with deficient planner packages.

Major activity has

proceeded

on the installation of large

and

small

bore piping and the associated

supports.

Safety related,

flushing

and hydrostatic tests

have

been performed

on completed

piping.

ITT gC inspectors

have

not performed

pipe

support

inspections

in

accordance

with their

documented

procedures.

The

NRC

has

identified instances

in which attributes like clearances,

gaps,

~ hanger

hardware

and welding

have

not

been

properly

inspected.

The

specific deficiencies

nave

been

documented

and

reworked.

In addition,

ITT has instituted

a program to reinspect

welding

and mechanical

attributes

on pipe

supports

that

were

accepted

'y

gC prior to December

1984.

Since inspection

plans

were not

followed, it appears that the inspectors

were not familiar with

the

inspection

requirements.

Given the high rate of,personnel

turnover,

augmented

training and supervisory oversight

programs

are necessary

to ensure

proper inspection conduct.

Of greater

concern

in two instances,

was that the pipe support

inspection plan was deficient since essential

inspection attrib-

utes

were not explicitly identified.

The complexity and length

of typical

engineering

specifications

necessitates

that

all

pertinent inspection attributes

be extracted

such that they are

clearly defined for inspection

personnel.

It is essential

that

gC and engineering

personnel

review the installation specifica-

tion to ensure that all critical attributes

are captured within

the

associated

inspection

plans.

The presence

of an excessive

gap

was identified by

HRC examination of an accepted

pipe

sup-

port

baseplate.

Shims

were

added

behind

the

baseplate,

the-

inspection

plan

was

modified to incorporate

the

necessary

in-

spection attribute,

and

a sampling reinspection

was performed to

insure

compliance 'with

the

engineering

requirements

for

gap

dimensions.

A second

instance

was identified by the

HRC involv-

ing the thread

engagement

of a sp~ing

support

bar which was not

verified by gC.

The inspection

plan

was

amended

to include the

requisite attribute

and

a number of supports

were reinspected

to

ensure

compliance.

'k

'13

Construction

personnel

have not adhered

to quality requirements

during installation activities.

Such deviations

represent

the

potential for adverse

impact upon the quality of installed hard-

ware.

Examinations

of fn-process

work activities

by

the

NRC

identified

an instance

where

a Tee-quencher

base

stand

was not

installed

fn accordance

with engineering directives

and

a hold

point was bypassed

during the erection of pipe whip restraints.

The

lack of process

control

fs attributable

to insufficient

craft supervfsfon of work activities

and inadequate training of

craft personnel

to ensure

that. quality requirements

are clearly

understood.

The Quality

Performance

Management

Program

{QPMP) has

led to

improved acceptance

rates of pipe

and

support

welds.

However,

the acceptance

goals

have not been achieved,

and the reject rate

on repair

welding

remains

excessive '(approximately

40%).

The

licensee

has dedicated

engfneering

and construction

resources

to

study the problem.

Special

qualification tests

were

performed

- for selected

welders.

These highly trained craft personnel left

the

site

after

they

received

the

additional

trainfng.

The

licensee

efforts

appear

to

be

co~prehensive,

but

a

key ingre-

dient required to achieve

the project goals is the retention of

highly qualified individuals '.n both the construction

and quality

areas..

NRC

examinations

of

SPEC

small

bore piping

and

supports

have

found high quality work.

The site machine welding

program

and

welder qualification programs

have

been

performed fn accordance

with the

ASME code.

2.

Conclusion

Category 2, Improvfng.

3.

Board Recommendatfon

HRC

Continue increased

fnspection

coverage.

Monitor repair

welding

effects

on

piping

base

material

(85"99-03).

Monitor licensee

control of in-process

activfties (~5-99-

04).

Monitor

QC

inspection

training

activities

(85-99-05).

14

Ucen see

~

Review

gC inspection

plans

relative

to

engineering cri-

teria.

Increase

craft

supervision

and

gC

surveillance

of in-

process

work activities.

Perform

enhanced

gC inspector training and increase

super-

visory overview.

Continue

management

attention

to

improve acceptability of

large bore melding.

15

C.

Safet

Related

Com onents-Mechanical

(7Z)

l.

~Anal

sos

Plant

components

such

as

pumps,

motors and heat, exchangers

have

been generally installed fn accordance with design requirements.

NRC examination of installed plant components

indicated satis-

factory

QC fnspectfon

for configuration

and

anchorage

attrfb>>

utes.

Major rework of the

Main Steam Isolation Valves was

mon-

itored and found to be well controlled.

The licensee

has

implemented

a strong internal deficiency iden-

tification and reportability system as indicated

by the four 10 CFR 50.55(e)

reports

that

have

been

made

regarding

inadequate

material certificatfons for valve bodies.

Further deficiencies

in source

inspection activities were iden-

tified by the

NRC involving a Service Vater Strainer shipped to

the site with inadequate

top bolt thread

engagement.

General

Electric

(GE) had

shipped

a motor with an incorrect voltage ra-

ting to the site.

Vendor

QC

and

SPEC

PQA did not detect

the

nonconformances,

and

the site recefpt

inspectfon

is only per

formed to detect

equipment

damage

in transit.

Additional site

overview

of

equipment

source

inspection

characteristics

is

necessary

to provide assurance

of hardware

adequacy.

Ouring the previous

SALP, co .cerns were identified with the Pre-

ventive

Maintenance

(PH)

program

implementation.

Ouring

the

current assessment,

there were continuing concerns

involving the

transfer

of

an

instrument

rack from

SPEC to Johnson

Controls

Inc. (JCI), during which the appropriate

PH requirements

were

not implemented fn a timely manner.

Ineffective coordination of

actions

taken

by the

varfous

groups

fnvolved in the

equfpment

transfer

was

apparent.

Sufficient interface controls

were not

imposed to ensure continuity of PM measures.

The

NRC also

found

that

the

warehouse

Level

A storage

levels were not maintained

and that the

RPV in place

PH requirements

were not met.

A re-

cent

inspection

identfffed

standing

water within

a

heat

ex-

changer

and particulate contamination of various

systems.

Mhfle

the

observed

deficiencies

apparently

have

not resulted

in the

damage

to any equfpment,

the

PH program

has

not

been effectfve.

Greater

management

attention

is required

to

assure

that plant

equipment is properly maintained during the construction

phases.

16

2.

Conclusion

Category 1, Consistent.

3.

Board Recommendatfons

HRC

~

Monitor Preventive Maintenance

Program {85-99-06).

Licensee

Mafntafn high level of management

attention for Preventive

Mafntenance

Program.

Increase

site verfffcation of vendor

fnspected

equipment

characteristics.

I

17

D. ~SS

taRt

l.

~Ana1

sos

The

Support

Systems

area

includes

Heating Ventilation

and Afr

Conditionfng (HVAC), fire protection,

radvaste

and fuel storage

and handling.

Ho vfolatfons vere identified during

NRC inspec-

tions.

The

HRC inspection

program

has

found that installed, HVAC hard-

vare fs fn conformance vfth the design

requirements.

Satisfac-

tory licensee overvfev has ensured

high quality results

from the

HVAC Contractor,

Schnefder

Pover Corporatfon

(SPC).

inspection

further shoved that

FSAR commitments for fire protection

system

pfpfng and supports

vas satisfactorily

implemented at the sfte.

SPEC

gC inspectors

devfated

from th'efr gA program by 'using hand

sketches

to conduct

some

gC

inspections.

The

inspectors

had

,transcribed

data from design documents to a hand sketch

fn order

to carry a single piece of paper to the field.

That process

can

result

fn improper

gC acceptance

of field hardware.

Mhfle the

practice

vas

smmedfately

halted,

the

extent

to vhich ft vas

employed remains

under licensee investigation.

2.

Conclusion

Category

1, Consistent.

3.

Board Recomeendatfon

NRC

~

Continue Routine Inspection.

~

Schedule timely Appendix

R plant revfev (85-99-07).

Licensee

~

Determine

extent

to which

hand

sketches

were relied

upon

to perform inspections.

~

peg

~'l

~

E.

Electrfcal

E uf ment and Cables (11")

l.

Annal

sos

Construction actfvity has

remafned

high.

Raceway installation

of tray

and

conduit

continued.

Large

amounts

of cable

were

pulled and terminated.

Equipment

has

been

energized

to support

the test program efforts.

Early fn the assessment

perfod, deficiencies

were identified fn

electrical

gC

inspection

plans.

Functional

area

8 describes

other

NRC identified concerns relative to inspection

plan ade-

quacy.

Cable separation crfterfa were

not met

and

the

gC in-

spection

plans

dfd not provide sufficient guidance

for items

such as equipment bolting and raceway identification.

The spec-

ific deficiencies

were re-inspected

and

reworked as appropriate

and the inspection

plans were

amended to incorporate

the

missing'ttrfbutes.

Hore recently,

an additional electrical

separation

problem vas

fdentfffed involving conduit

runs that

violated

the

one

inch

separation criteria of Regulatory Guide 1.75.

Fourteen

of fifteen

10 CFR 50.55{e) reports

in this area

were

caused

by off-site deficiencies.

Several

pieces

of electrical

equipment

contafned deficient vendor internal wfrfng.

The scope

of the vendor w'ring deficiencies

appears

to be generic

to all

site electrical

equipment.

The

SPEC

Procurement

gualfty Assur

ance function dfd not effectively ensure

proper

vendor

perform-

ance.

Additional

source

inspection

deficiencies

are discussed

fn functfonal

areas

A and

C.

All of the

equipment

has

been

delivered

making ft a site

problem to resolve.

A program

has

yet to be developed to guide the refnspectfon

of vendor wiring.

It should

be noted that a'arge

number of these

problems

arose

prfor to this assessment

period as

a result of previous

manage-

ment programs.

Interviews of sfte

gC personnel

have

indicated

thaa

a typical

work week is

on the order of

70 to

80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months .

Given that

the

electrical

inspection

function uses

a relatively complex set of

inspectfon criterfa, the excessive

hours could impair inspector

performance.

Supervisory

overview

of

inspection

conduct

is

encouraged

to assure

acceptable

inspection.

2.

Conclusion

Category 3, Consistent,

19

3.

.Board Recommendations
. NRC
~
Honitor inspection
to
ensure
schedular
pressures
do not
degrade
inspection effort (85-99-08).
~
Review licensee
remedial
actions to rectify vendor defic-
iencies (85-99-09).
Licensee
Assess quality levels of vendor supplied equipment internal
siring.
Assure
adequate
gC staffing
to
accoaeodate
construction
schedules.
'I
(ia(
'
~
J
al ~
,'
~
I
h'
C, ~ g
I
I
~
p
~ ~
20
'L"
~
~
F.
Instrumentatfon
and Control
S stems
(5X)
l. 'Anal sls
The
pace
of construction
activity
has been'igh.
Instrument
tubing and supports installation are complete at many locations.
Instrument
racks
and
transducers
have
been
installed
fn
the
plant;
Early fn the assessment,
viring separation
problems
were
iden"
tiffed throughout the
PGCC panels.
The entire
Power Generation
Control
Complex
(PGCC)
vas
inspected
by
GE and
SPEC personnel
to identify all locations
of electrical
separation
problems.
The
inspection
plans
have
been modified to require clear docu-
mentation that the wiring complies with Regulatory Guide 1.75 or
that the compliance vill be obtained at a later date through the
installation
of barriers.
Additional
concerns
regarding
the
acceptability
of
the
PGCC
internal
viring. with
respect
to
terminations
and
harness
supports,
and lack-of as-built veri-
fication were identified during
NRC inspections.
The
equipment
release
for the
PGCC vas
reviewed.
The release
was allowed to proceed
even though it was deficfent with respect
to 'attributes
which gA had previously documented
as problems
on
an earlier
release.
The
PGCC
release
involved
an
extensive
number of open
work items,
for which construction efforts are
continuing. It appeared that the
PGCC milestone completion date
was the motivating force behind the release
in lieu of quality
and work control considerations.
Conscious
licensee
management
decisions
allowed the
PGCC instal"
lations activities to proceed
fn a manner that vas not compat-
ible with the
achievement
.of quality goals.
These'ecisions
vere
made prior to or early in the assessment
period and further
evidence
of these
types of decision
making
processes
have
not
been
observed
during
the
remainder
of the
assessment
period.
Oamage to installed
and .accepted
instrument
tubing
was detected
by the NRC,at
numerous
locations.
Physical barriers
have since
been
erected
to protect the tubing
and instrument
racks.
Site
warnings
have
been transmitted
to the craftsmen
regarding
pre"
cautions
required to protect
the installed tubing.
The licensee
efforts to address
this
problem originally were
inadequate
to
fully correct the observed
problems
until
NRC fi'ndings prompted
more extensive corrective actions,
Increased
management
oversfght
'is
required
to
ensure
that
adequate
corrective
act'~ns
are
implemented in response
to
NRC identified concerns.
'1
21
HgC review of licensee
performance of instrument tubing instal-
lation,
support
material traceability,.review of JCl
QA proce-
dures,
and
mounting of two instrument
racks
was satisfactory.
2.
Conclusion
Category 2, Consistent.
3.
Board Recommendation
HRC
Arrange for management
meeting to discuss
actions taken to
resolve
PGCC problems (85-99-10).
Licensee
Prepare
summary
of
actions
implemented
to
resolve
PGCC
wiring deficiencies.
Continue
to monitor
tubing
damage
and institute further
controls as necessary
to preclude additional
damage.
'r
~
~ ~
p
22
G.
Lfcensfn
Activftfes
I.
~Anal sls
The applfcant's
performance
was
assessed
wfth regards
to the
responses
to staff requests
for information during safety
and
envfronmental
revfews,
responses
to outstanding
and confirmatory
issues
fn the Draft Safety Evaluation Report {DSER), comments to
the Draft Environmental
Statement
(OES),
and
assessment
of the
Safeguards
licensing area.
Ourfng
the
assessment
perfod,
the
management
of
NMPC
was in-
volved
fn
many
phases
of licensing activity.
Decision
making
was usually at
a level that insured adequate
management
review.
However, there were
some areas,
as
noted
below,
where
increased
management
attention
was considered
necessary
during the assess-
ment period.
The applicant
was
requested
to resolve design differences
detected
during the review of the lnstrumentatfon
and Con-
trol (IEC) area
where the
FSAR did not agree
to the plant
drawings.
The applicant
was requested
to verify the verbatim incor-
poration of staff
revfewed
technfcal
responses
into
the
FSAR following NRC detection of an instance
fn which this
had not been
done
as agreed.
Based
on applicant
responses
to the
DSER
and
DES it was
determfned
that the
FSAR and
ihe Environmental
Report
(ER)
dfd not adequately reflect the correct situation, requiring
resolution;
The applicant's
management
and staff
have
demonstrated
sound
technical
understandfng
of issues
involving licensing
actions.
Technical
expertise
has
been
evident.
The applicant's
commit-
ments
have
reflected
a conservatfve
approach,
particularly
in
the
ffre protection
area,
to
provide
for adequate
level
of
safety.
When the applicant
has
deviated
from staff guidance,
sufficient
technical
Justification
has
generally
been
provided to support
such deviations.
Within the
area
of geology,
the applicant's
technical
approaches
were not always complete,
and extensive
NRC
staff effort was requfred to elicit the licensee's
relevant data
and analysis
needed
to reach resolution of problem areas.
a'
23
~
Ws
The applicant
has extended. the break exclusion
zone for the Re-
actor Mater. Cleanup
(RWCU) lines to a valve located over 50 feet
from .the containment boundary.
The HRC staff has fndfcated that
the break exc1usfon extension is not consistent with the intent
'of. the Standard
Review Plan
(SRP).
The HRC staff has requested
that the applicant review the effects of a postulated
break at
the Junction of the iMU line for pipe vhfp and get impingement
considerations.
The
HRC staff has detected discrepancies
betveen
the applicant's
response
to separation criteria concerns
resulting from HRR in-
quiries and to the Construction Appraisal
Team (CAT) inspection.
NRR ts presently coordinating with the Region I inspection per
sonnel
to ensure
a consistent
review of electrical
separatfon
commitments
and fmplementatfon of those
commitments at the site.
The applicant
has
taken
the initiative fn the correction of a
number of technical
problems.
The Hain
Steam
Isolation
Valve
(NSIV) body interior surfaces.
have
been
clad with a corrosion
resistant alloy.
The modfficatfon vas fnitfated fn response
to
corrosion
concerns
identiffed at
the
Lfebstadt,
Svftzerland
plant during preoperational
testing.
There
has
been
a high level of licensing activity to support,
issuance
of responses
to the
HRC staff as
a result of FSAR and
ER docketfng;
responses
to open
and conffrmatory issues
of the
DSER; and comments to the OES.
The
ma)or licensing activity has
been
fn the safety
area.
A
number of responses
vere not received
fn
a timely manner which
adversely
impacted
the
lfcensfng
schedu1e.
The
responses
to
OSER outstanding
issues
in the
Containment
Systems
area
were
particularly late.
A number
of the
formal
responses
fn the
areas of Power Systems,
Geology,
and Procedures
vere lacking fn
thoroughness,
depth,
or vere significantly different from the
proposed
responses
dfscussed
during
meetings
or
conference
calls.
Compared vith experience
on other'cases,
these
submit"
tais required more than the normally expected
number of re-sub>>
missions
to obtain
acceptable
resolutions.
The applicant
vas
additionally not responsive
to
NRC requests
to perform,a
review
of the
OSER,
FSAR and the actual
p1ant design for the Instrumen-
tation
and Control area.
Follovfng management
discussions
be-
tween
the
NRC and applicant,
the responsiveness
vas
improved in
the latter stages
of the assessment
period.
The staff conducted
several
audits at the plant site,
the appli-
cant'
corporate
offices
or
the Archftect/Eng
1 neer '
offfees.
The applicant provided sufficient support for the audits.
The
information provided by the applicant at the audits
was gener-
ally complete
and thorough.
h
Pt
The
NRR evaluation of plant staffing is still fn process.
The
Security
Organfzatfon
positions
and responsibilities
are veil
defined.
The planned
security staff fs considered
to
be
more
than ample to fmplement the facility protection program.
The 'safeguards
licensing
reviev indicated
consistent
evidence
of management
planning.
Responses
from the applicant vere tech-
nfcally sound.
Tfmely resolution
vas
obtained
to staff con-
cerns.
The
guard qualification
and training
program,
as
pro-
posed,
vas satisfactory.
The
HRR evaluation of the description of the applicant's train-
ing
program
discussed
fn
the
FSAR
indicated
no
outstanding
shortcomings.
2.
Conclusion
Category 2, Consistent.
3.
Board Recommendatfon
NRC
~
Give partfcula; attention to timely issuance
of the Tech-
nfcal Speckifcatfons.
Licensee
~
Prior to fnftfal lfcensfng,
the
applicant
should
assure
full consistency
and completeness
among the as-built plant,
the
FSAR, the
SERs and the Technical Specifications.
25
H.
Pro ect Mana ement/ ualit
Assurance
(16%)
l.
~Aaa1 sls
Extensive
changes
have
been
implemented
to improve the licensee
management
control
of site
activities.
Hanagement
Analysts
Company (NC) has
been
retained
to provide
experienced
manag-
erial
personnel
for NHPC.
Site Quality Assurance
programs
have
been
upgraded.
The project does not currently have
an effective site commitment
list to track prior coaxaitments
for periodic auditing to ensure
that the corrective
actions
are .,indeed
ongoing.
This
has re-
sulted in the identification of several
problems
by the
HRC in
which quality comaitments or corrective actions
have
had inade-
quate
long
term implementation.
Examples
which indicate this
.include recurring excessive
QC reject rates,
inadequate
measures
to preclude further
damage to instrument tubing, and the failure
to train the craft to adhere
to
engineering
directives.
The
third party assessment
found further evidence that the'roject
has difficulty implementing effective corrective actions
in re-
sponse
to deficiencies
identified
by external
organizations,
such as the
HRC.
There
appears
to be
a problem controlling craft personnel
which
is also
discussed
in functional
area
B.
The particular
NRC
identified problems
involved inadequate
control of issued
weld
filler material;
poor primary containment houseclear.ing
and fire
prevention measures;
and unauthorized
construction
rework with-
out
QC .notification.
In these
cases,
prompt steps
were imple-
mented by licensee
management
to correct the problems.
Several
unresolved
concerns
deal
with problems
that resulted
from inadequate
communications
between site organizations.
Poor
feedback
was iCentified between
SPEC
QC supervision
and
the
QC
inspectors.
The
inspectors
requested
clarification of proper
implementation of the
QA procedures,
and the supervisors
did not
properly respond
to the inspector questions.
A lack of control
was observed
between
organizations
making attachments
to struc-
tural
steel
members.
The inspection
status
of the steel is not
always readily available.
The
licensee
organizations,
QA
and
engineering,
have
not yet
reached
agreement
on
the inspection
required
to comply with Regulatory
Guide
1.29.
The
items
in
question
are non-safety
related
items
suspended
over safety ri-
littd equipment.
At this time, only
a
surveillance
inspection
which does
not
appear
to fulfill the licensing
commitments
is
performed
.
k
26
';The
licensee
has
instituted
a
hardware
reinspection
effort.
'ue
to the problems identified with previously
QC accepted
in-
. stallations not in compliance with the engineering design,
sample
. reinspections
were performed to ascertain
the acceptability
of
the field hardware.
Licensee
engineering
has
reviewed the data
and determined the majority of the problems
are not detrimental
with the exception of mechanical
fastener
problems.
The assur-
ance
must be gained
by the
HRC that sufficient licensee
rein-
spection activity has
been
performed to detect the worst case
deficiencies,
that
proper
analysis
has
been
performed
on
the
'esultant
data,
and that the current first line inspections
are
properly performed.
Satisfactory
licensee
performance
was observed
during re'view of
the
implementation of the Quality First program,
document
con-
trol activities in the
PGCC area
involving
GE
and
SWEC design
changes,
development
of
HMPC surveillance
program
and detailed
surveillance checklists,
resolution of nonconformance
reports
by
~ engineering,
development of the
new construction
QA program and
infusion of new QA management
personnel.
As noted in section I.C, the licensee
has instituted
a major manage"
ment
reorganization
and
has
implemented
numerous
actions
to
assess
the quality of prev'ously
performed
work'and to ensure
that current installations
meet the quality requirements.
The
licensee
has
developed
a Quality
Performance
Management
Program
(QPMP) which monitors
the quality status
of the site.
Key parameters
such
as quantity installed,
quantity
inspected,
and
QC acceptance
rates
are monitored for construction
hardware
commodities.
The
program
monitors
outstanding
design
changes
and
open
QA deficiency documents.
Trending is performed
on
some
of the documented
nonconforming conditions.
Region l is monit-
oring the utilization of QPMP by the licensee
through management
meetings in conjunction with review of
QPMP data
and attendance
at the licensee
QPMP meetings.
The
QPMP appears
to be function-
ing well as
a management
tool to diagnose
problems
and to assess
the adequacy of corrective actions.
Quality
Control
organizations
have
experienced
a
significant
problem in attracting
and retaining qualified personnel
to keep
pace with the construction effort,
This has resulted
in exten-
sive
use of inspector
overtime which could reduce their effec-
tiveness.
A positive benefit of the
CAT,
?NPO and re-inspection
programs
on the quality staff has
been
that
QC inspectors
indi-
cate
they currently receive
management
support.
Recent
review
indicates that the progect
management
team
appears
to be
func-
tioning well, that significant
program
improvements
have
been
made
and bettor lines of communications
have
been
established.
The
end result
is that
the site
programs
are
able to identify
and resolve pro)oct quality issues.
S ~ wW
~
W
I
\\
27
2.
. Conclusion
Category 2, Improving.
Board Recommendation
NRC
A
~
Continue to monitor implementation of gPHP effort (85-99-
11).
~
Evaluate licensee reinspection results (85-99-12).
Monitor adequacy of long term corrective action implementa-
ti'on (85-99-13).
Licensee
~
Use
gPHP as
a dynamic management
tool to identify and trend
quality problems.
Establish
control
over contractor
interfaces
and
develop
confidence
level
of historicai
hardware
in light of
gC
deficienciesi
Ensure
schedular
pressures
do not adversely
impact quality
goal s.
~
Establi sh
effecti ve
site
commi tment
tracking
to
ensure
implementation of long term corrective actions.
Expedite resolution of NRC open
items and provide complete
verification of associated
corrective actions.
~
Resolve'Regulatory
Guide 1.29 inspection issue.
28
I.
Nondestructive
Examination (27K)
A~naI sIs
Nondestructive
fxamination.(HOE) is a new functional area.
Pre-
viously,
NOE was
assessed
in the piping and pipe supports
area.
Ouring the previous
SALP period, there were
concerns
regarding
- ITT, Grinnell (ITT) radiography
operations.
Of particular con-
cern
was that film had
been artificially altered.
Given
the
extensive
inspection effort and significant problems identified
during the current assessment,
NOf vas assigned
a separate
func-
tional category.
In concert with the rapid construction installation pace of pip-
ing and supports,
NOE has
seen .substantial
activity during the
assessment
period.
The first line
HOE is performed
by Reactor
Controls,
Inc. (RCI) on the Recirculation
and
CRO piping.
ITT
performs
NOE on the'emaining safety-related
piping systems.
In
light of the extensive
problems that were previously identified,
this section
covers
the progress
made to date to correct
those
deficiencies.
Early in the assessment,
major deficiencies
were identified in
the
ITT radiography
program.
The deficiencies
included
weld
quality, film quality,
and
inadequate
documentation.
The
over
view of HOE activities by Stone
and webster Engineering Corpora-
tion
(SPEC)
and
Niagara
Hnhavk
Power
Corporation
(HHPC)
vas
inadequate
as
some similar problems
had been identified by site
gA/gC, -yet timely
and effective corrective
actions
were
not
implemented to correct the deficient
HOE programs.
The conclusion
was that
ITT radiographic
interpreters
had not
adequately
evaluated
radiographic
film and
reader
sheets
for
weld quality, film quality and completeness
to assure
compliance
with ASME Section III and
V requirements.
Further problems vere
identified vith unsatisfactory
liquid penetrant
examinations of
stainless
steel piping.
In response
to the identified deficiencies,
numerous corrective
actions
were
implemented
to
enhance
day
to day
NOE operations
and
to
assess
the
adequacy
of previously
examined
hardware:
ITT replaced
their liquid penetrant
technicians
and re-
examined
all
safety
related
liquid
penetrant
inspected
stainless
pressure
boundary weldments.
IP
A"';
Qgg clpt,'
p

~
~
29
g
~
~ P%
~ ~
s
Review of ITT shop
and field radiographic film by ITT/NMPC
HOE personnel
to assure
adequacy of weldments
and
documen-
.tation.
~ ~- " Increased training of ITT radiographers
'-..-. Repair of deficient weldments
Retention of all ITT radiographic film
Assignment of the ITT Level III to the site
Increased
SWEC
and
NMPC surveillance
of
NOE activities
A subsequent
NRC inspection
found that marginal
corrective
ac-
tions
had
been
implemented
by the licensee
in response
to the
radiography
problems.
The
adequacy
of the
ITT and
NMPC file
re-review
was
questioned
as
an unacceptable
transverse
indica-
.tion was found by the
NRC.
A further problem was that Inservice
Inspection
weld preparation
had resulted
.in minimum wall viola-
tions.
The extent of the problem remains under licensee
review.
The. radiographic proble.ns
appear to be attributable,
in part, to
'he fact that there is not a site Level III charged with respon-
sibility for all NOE op~~ations.
The
licensee
subsequently
directed
SPEC
Boston to provide
NOE
personnel
to again
~ e-interpret all ITT film in the vault.
Our
ing the course of the
SPEC film review,
two welds were identi-
fied for which the wrong weld had
been
radiographed
in lieu of
the
designated
weld.
The vault contained
two
sets
of radio-
graphic film marked to indicate two dissimilar weldments
when in
fact only one Joint
had
been
shot twice.
The licensee
identi-
fied a singular radiographer at fault in both cases
but has also
detected
the lack of radiography
procedural
controls.
A sample
re-radiography
program is underway to assess
the
scope of this
construction deficiency.
More recently,
an
inspection
conducted
at the
end of
1984 did
not identify any further problems in the site
NOE programs.
The
inspection identified satisfactory corrective action implementa-
tion for the. outstanding deficiencies,
with the exception of the
duplicate film concern for which licensee
actions
are
underway.
)g +ii~~'(@pi
~
~ e ~, ~
~
+> W
~
~
30
~
~
~
~
2.
3.
Conclusion
I
Category
2,
Improving.
The
licensee,
has
instituted
numerous
program enhancements
over the assessment
period.
\\
Board Recommendation
NRC
~ .
Review corrective actions
in radiography,
particularly the
duplicate film concern (85-99-14).
~ 'valuate
necessity
to schedule
NRC van inspection prior to
OL (85-99"15).,
Licensee
~
Continue aggressive
oversight of NOE activities.
~ ,
Resolve
outstanding
concerns
as ~xpeditiously
as feasible.
~
Evaluate benefits of establishing
site
NOE Level III posi-
tion.-
I
P
>>a ~
I
I! ~
~V <
s
1
a
J.
~EI
I
(5%)
~Ana1
sos
~ .'31
~a
. Engineering
was
not previously assessed
as
a unique functional
'rea.
During the course of both team
and routine resident in-
.'pections,
a substantial effort has
been
expended
in the review
of the design
and design
change
process.
The
SWEC site engineering workforce has greatly expanded to sup-
'port construction efforts;
The rate of design
change
issuance
~
has
remained high.
Engineering activities at the project design
office are tapering off.
Significant areas
of work remain
in
the stress
reconciliation of ASME piping and the resolution of
equipment qualification testing.
Inadequate
control of the
design
change
process
was
a problem
as indicated
by design
change
documents
not completely reviewed
to assure clarity, many design
changes
issued
to revise or cor
rect previously issued
design
documents,
design
changes
not in-
'corporated
into drawings in a ti~ely manner,
and design
change
documents
used
to resolve
nonconformances.
The design
review
process
has
subsequently
been
enhanced.
A trending
process
is
in place to track release
of deficient design
change
documents
.for, correction of root causes.
Site engineers
were retrained
on
the proper use of nonconformance
reports to avoid an inadvertent
bypass
of the
gA program.
Greater
technical
and
management
overview
is
required
of
the
design
change
control
process.
The
NRC has identified plant components
that were not properly
designed
as evidenced
by the identification of the diesel
gener-
ator cranes
and control
room partitions that
had
not
been
de-
signed to seismic standards.
The items were redesigned
to seis-
. mic criteria
and
a total plant
review
has
been
performed
to
assure
that
no further
instances
of that
type
can
exist
in
safety related plant areas.
Fifteen out of sixty-five Construction Deficiency Reports
(CDRs)
were
assessed
to
the
Engineering
area.
The
SPEC
Engineering
Assurance
technical audit identified that the construction
draw-
ings for the
RHR
heat
exchanger
bracing
had
not
been
drawn
according
to the computer analysis
bracing details.
This
i,s
a
significant deficiency
in which the audit process
identified
a
design control
problem which
had direct
hardware
consequences.
Several
of the deficiencies
involved the failure of the design
to accommodate
either hydrodynamic or seismic loadings.
2.
The
HRC has identified'two cases
in which engineering
drawings
have
. not 'roperly
'classi fied
safety-related
structures
as
such.
The engineering misclassification
results
in the lack of
required
gA/gC overview of the
component
during installation.
The particular concerns relate to the Reactor Building roof and
a refueling crane
which was designed
by GE and described
in .the
'SAR
as
a
safety-related
item.
Oue
to
a
design
interface
problem,
SWEC
had
issued
direction
to erect
the
crane
as
a
non-safety
item onsite.
Concerns
were further .identified in the following areas:
ITT
. apparently
did not backfit more stringent
design
requirements
promulgated
in design
cha'nges
against
the
acceptance
criteria
used 'o
previously
accept
hardware
installations;
inadequate
. design control
was enforced over design
interfaces
for
attach-'ents
to structural
steel
to ensure
adequate
beam stiffening;
inadequate
review of field installaQons
was performed
by engi-
neering to assess
the total
scope of the problem prior to issu-
ance
of
a
design
change;
the
licensee
maintained
no
formal
'tracking
mechanism
to ensure
that
the
design
changes
were
in
fact implemented
by
SWEC or GE; design
drawings
had
improperly
incorporated
design
changes;
site engineering
does
no~ correlate
attachment points of small bore support
changes
issued
on ACH's
with the associated
embedment
drawing thus resulting in an inad-
equate
engineering. resolution of a nonconforming condition,
and
some
engineering
personnel
had
not received all
the
required
formal training classes.
In summary, 'the above findings have resulted in a lack of conf)-
dence
in the
design
change
process.
The technical
content of
some design
changes
has
been lacking.
Inconsistencies
have
been
detected
between
FSAR gA requirements
and the site issued design
gA categorization.
Engineering
and
gC personnel
have
not
com-
municated
to ensure
that inspection
plans capture
the requisite
design. verification attributes
as
discussed
within functional
areas.-B
and
E.
To gain confidence
in the engineering
products,
further
design
reviews
in
the
form of Engineering
Assurance
audits,
Technical
FSAR verification,
and
licensee
engineering
overview are necessary.
Conclusion
Category
3, Improving.
3.
Board Recommendation
NRC
~
Honitor
adequacy
of
design
change
documents
(85-99-16).
~
~
i ~
0'
')~g i
" 33
h
~z +
~
.,,,"..
Region I and
IE:.,continue active monitoring of
SWEC Engi-
'..:":'eering Assurance efforts (85-99-17);
Conduct
further inspection
of
FSAR content
versus
design
documents
and monitor FSAR verification process
(85-99-18).
Licensee
.'
P
~
~
~
Examine
implementation
of IE Bulletin requirements
to as-
sure technical resolution of identified problems.
". ~
',
Perform
enhanced verification of drawing incorporation
and
- exercise
greater
technical
oversight of design
change pro-
'-.'.: cess.
.
~
-
Investigate
design
interfaces
to ensure
proper
communica-
tion of component
gA categorization.
.
~ ~ .
Conduct sufficient verification of FSAR commitment transla-
tion to ensure plant is built in accordance vith licensing
commi tments.
~
~
J>>>>>>
~
~
~ I ~
( ed'+>>
p ~
g
" 'o,+g
c
-
~
C'::." V.
P ~
34
~ r
SUPPORTING
DATA 'AND SUMMARIES '
+~.:.
A.
Investf atfons and Alle atfons Revfev
During the assessment
period,
14 allegations
were receIved of which
7 vere unsubstantiated.
The remainder are described belov.
I
~
Three
formal
investigations
vere
conducted
during
the
assessment
period.
The following allegations vere investigated:
Confrontation between
an electrician
and electrical
gC inspector
regarding
PGCC'lectrical
termination
reviews,
remains
under
investigation.'arassment
of
NMPC
gA auditors for identification of quality
concerns,
remains
under investigation.
I
Harassment
of a
gC inspector
by. site engineering,
remains
under
fnvestfgatfon.
Routine
inspection
followuo
was
performed in response
to selected
portions of allegations:
Deficient JCI tubing installations
and other procedural
defic-
iencies.
The licensee
had corrective
actions
fn place in ad-
dress
the
concerns.'MPC
gA lead auditors not properly certified.
Inspection
sub-
stantiated
the validity of the
licensee
audit findings.
The
licensee
reviewed all -lead
auditor
certfffcatfons
and
audit
reports to address deficient certfffcatfons.
Concerns that electrical termination bolting hardware could not
'e verified as silicone bronze.
The hardware
concerns
were not
substantiated.
Hovever,
the
lack of communication
between
gC
supervisors
and
gC inspectors
was apparent.
Alleged
improper electrical
terminations
and bypassed
gC hold-
pofnts.
The licensee fdentfffed instances
fn which terminations
were performed vfthout the requisite
gC inspection
and reported
under
10 CFR 50.55(e).
The licensee
performed reinspections
of
bus
bar
material
to
determine
the
adequacy
of
the
bolting
material.
1
h
\\
I
~
~
\\
4 ~
~
~
'.
~'
j . f
~
I

Audit..findings had
been watered 'down. between
a draft and final
audit report.. The audits in .question
were reviewed
and
a deter-
. mination
made that the;,technical
concerns
had
been fully iden-
. 'tified within the final'report.
In addition the
licensee
sur-,
veillance 'program
had
been totally restructured
to address
the
noted, deficiencies..
-.;" .="-
=:.
A11eged.that
J-bevel
weld preparations
cannot
be
inspected
by
QC;:-".. Determined -that,
QC . was
not
. provided with radius
gauges,
which were. subsequently
'purchased
by ITT and
issued
for use.
.:The machining operation resulted in an out of tolerance J-bevel,
~
. 'hich was found acceptable
by engineering..
'11eged
that'he project director intimidated
a group of ITT QC
inspectors..
The project director
was
counseled
at length
by
NMPC
QA. on
QA organizational
- freedom.
Site
directives
were
issued with regards
to
QA independence.
The
QC inspectors
were
assured
that
no retributions
were. forthcoming,
and
they
subse-
quently stated their concern
was satisfied.
Escalated
Enforcement Actions
1
~
~
~
~ *
~ ~~C
As
a result of a Construction Appraisal
Team
(CAT) inspection
con-
..'ucted in November - December,
1983, which identified extensible
site
quality problems which are discussed
in Section
IV of this report,
an
Enforcement Action (EA) was issued
on March 20,
1984.
The
EA con-
sisted
. of
a
Notice of Violation,
an
Order,
and
a
proposed
Civil
~ Penalty.:,',
C,
. Mana
ement Conferences
In .addition to the
two formal
management
conferences
listed below,
there
were'umerous
discussions
between
NRC
management
and project
management'uring
the assessment
period.'.
February 22,
1984 " A Management
meeting
was held to discuss
the
management
reviews that, had
been
performed
prio~ to the
CAT
inspection.
The planned
licensee
reorganization
was
presented.
Additional discussions
were held with regards to licensee
imple-
mentation of corrective actions in regards
to
CAT and
SALP con-
cerns.
b'.
November
14,
1984
>> A Management
meeting
was
convened
at
NRC
request to review the corrective actions
implemented in response
to
CAT.
The results of the third party
MAC audit were reviewed.
The development of the site Quality Performance
Management
Pro-
gram
was
reviewed.
The licensee
discussed
QA verification ac-
tivities of previously installed hardware relative to the design
documents.
Licensee
actions
to
address
the
site
radiography
deficiencies
was presented.
l
4WI
~
0
k
~
D.
~ufy.>'4 r&~p+~g
'tpQ$Wle".i4~%%~pjg+g
.",'.. "" ~-'-
.* "-'.,
'.,-.'.'6
~
I
I
~
"
I~
~
~
+
~
~
/ +4
~
Construction Oeficienc
Re orts
CDRs
.
Sixty-five. (65)
COR's:were 'eported
by
the
licensee
during
the
assessment
period. - One was'not reportable
according to the licensee.
Numerou's
COR's we'e evaluated at'ength
by NMPC and found to not pose
,adverse-~consequences
'to eventual .plant operations.
However,
since
extensive;efforts 'were
expended.'to
. reach
those
determinations,
the
. reports'-.are 'still classified
as" 10 CFR 50.55(e)
items.
These defic-
'.- ienciesare .listed in Table;1;- and ..were
selectively
evaluated
and
'iscussed
as part'of the appropriate functional area.
Analysis,.'f the
COR's for 'causal
linkage has resulted in the identi-
fication* of the following linked chains:
CORs 84-00-02,: 84-00-06, 84-00-29,.84-00-39,
84-00-49, 84-00-53.
The
denoted
. COR's" apply to the
conduct
of. deficient weld examinations
through. visual
and
NOE.
The subject welds were
found to'e
not in
compliance with, either the applicable 'codes or design criteria.
The
problems are pervasive in nature and'involve both pipe and structural
welding. 'he
root cause
problem
was
a 'failure
on
tne part of the
personnel
involved in welding
and
inspection
to follow applicable
procedures.
CORs 83-00-22, 84-00-'3, 84-00-40.
85-00-03.
The listed
CORs involve
the failure of engineering to adequately
account for the effects of a
seismic design basis event.
CDRs 84-00-14, 84"00"18, 84-00-25, 84"00-31, 84-00-32, 85-00-31. Site
.inspection, of electrical
equipment
has
identified the .failure
of
equipment vendors to properly install the internal wiring. Electrical
separation
violations
and
workmanship
deficiencies
were
involved.
P
~
~
4 ~
'~a
~ ~
y
C.P~~:
+Q a v'~is
,. '
':'.'
B.
',',.'
D.
F.,
g
~.1
A,"
a~. i
C,
E.
V
+ V ~
TABLE I
'A<
CONSTRUCTION DEFICIENCY REPOR
1 /1 83
1 31/8
~
~
~ S
T e'of Deficiencies
'
'.
Personnel Error.......................'.......20
Design Error.'................................20
External Cause................................7
Defective Procedures..........'...'.............2
Component" Failure..'..........;...........-.....14
$
Fabrication Error................;............1
TS
. 'AREA
Containment'nd
Other Safety-Related
Systems
-
~':
Piping Systems
and Supports
Safety-Related
Components-Mechanical
Support Systems
Electrical
Equipment and Cables
Instrumentation
and Control Systems
Licensing Activities
Prospect'anagement/guality
Assurance
Nondestructive
Examination
Engineering
J ~
1
NUMBER/
CAUSE COOE
~TO AL
1/A, 1/F
5/As 3/Cs
4/A, 2/B,
3/E
7/A, 2/B,
2/A, 1/B,
1/0
1/A, 1/0
15/B
/E
9
1/C, 3/E
10
3
2/C, 4/E
15
1/C, 3/E
7
0
1
2
15
e4
CONSTRUCTION DEFICIENCY REPORTS
CORRELATED BY FUNCTIONAL AREA
c4,
P
'ABLE 2
Hours
788
1103
nical
382
234
574
tees
255
rance
896
913
263
~
Total
.
~408
INSPECTION HOVE SUMNARY
1/18
1
18
~
~
~
4 ~ ~
~
. Functional'Area
A.
Containment'and
other Safety-Related
.I.";;,p;
.
".'. Structures.
':...
B;
Piping Systems
and Supports
., C.

. Safety Related
Components-Mecha
0.
Support Systems
E.
. Electrical Equipment.and
Cables
F. 'nstrumentation
and Control Sys
>'.:,-;,,','.:., Licensing Activities
.
-'.
Progect management/ttuality
Assu
I. ,-'Nondestructive
Examination
J.'.
Engineering .. .; '
~ y
'P
X of
Time
20
7
4Il
5
16
27
5
TR
k
l
'f
~ l
)
I ~
~
~
',
>
~
.
~ 8
~
TABLE 3
.;.:.",'j" -'~>>'.: =. ENFORCEHENT 'OAT
1
1/83
I/31/85
t
~ 4<~ t"
'.. Number "and'everit
Level of Violations'.
~
=
Severity Level I
'
0
Severity Level II -'1
Severity Level III
0
Severity Level IV
16
Severity Leve'I
V
5
Oeviation
- "
-
0
~ I
-".. B.
- Violation correlated
b
Functional Area
Severit
Levels
" Functional'Areas
I
A.
Containment'and
other
~ fety related
4
systems
,". B.
Piping systems
and supports
. C.
Safety Related
Components-Hechanical
0.
Support Systems
E.
Electrical, Equipment and Cables
F.
Instrumentation
and Control Systems
G.
Licensing Activities
H.
Prospect
Hanagement/equality
Assurance
1
.;.;"'::, I.
Nondestructive
Examination
!,:,'.;
.J.
Engineering
TOTALS
1R
c
'~ Violation'composed of deficiencies within Areas A-E, H,I and J
I
I
V
V
4
2
1
1
1
4
3
1
2
Two Single violations composed of multiple examples within two areas,
total
of 17 Severity Level IV violations actually issued.
I
~ ~ I
' 64+ f gt'
g 4.
O4
'" )
'iV
'II4 44AL
4
I
I
'
~
4f
~
V
Nonconforming support welding
accepted
by quality. control
Deficiencies with conduct of
inspection activities, deficient
radiography
program, lack of
licensee oversight audits,
document control problems.
Final inspected
supports
do
not conform 'to design criteri.a
Inadequate
implementation of
site procedures
for handling of
~ 4I',
4
II
IV
'. po tential construction
deficiency reports
~
~
I
~
~
'r
~
> II ~
~
~
-'C'. "'-~u~arur:.,'.";i';
Inspection,; '. Severity" Functional;.
iolation
3-16
..'V.;
'
8
It
l"
'83-18'I
H
~
7
I
4
I
~ J
~
~
P
84-01'V
B
~ ~
~
~
0
84-02
84-05
'
84-06
4
~
'
~
~
IV
IV
IV
H
Incorrect nonconformance
report
.form is use
. Equipment in Category I plant areas
not, seismically designed.
Veld material not properly
controlled
Post inspection
rework not
controlled for structural
steel
IV
IV
IV
Inadequate
inspection of
structural
steel
connnections
and
of pipe support attachment
thread
engagement
Inadequate
structural
steel
inspection status
system.
Deficient primary containment
housekeeping
and fire prevention
measures
84-08
Radiograph
reader
sheets
did not
document interpretation of linear
indication
Radiograph identified containing
respectable
linear indication
e )3
et
') ~
'
)'
v
o
t
r
)
\\ ~
Inspection

Severity
Functional
'Re art
N'o
.,-
Level:
Area
.
Vlolatloo
3
~
~
~
1 ~": IV
I
I
~

~ .r
Ci
~
\\
C \\~
3)
)
)g~t
~~/
~
~
~
rg<:.'..'.t. '
~~'],
v
L
~
~
'84"09
84-11
84-I3
84-18
'V
IV
IV
IV
IV
V
IV
H
C
B
)
Veld violated minimum wall
thickness
requirements'nadequate
application of
corrective action to lower
trended re3ect rates
Electrical penetration
welds
not properly examined
Nip restraint installation
hold points by-passed
Inadequate
control over
promulgation of design
change
information
Inadequate
thread
engagement
of strainer
top bolts
Failure to maintain control
of field issued weld rod
material
Excessive internal particulate
contamination of piping system
and inadequate
preventive
maintenance
measures
84-19
IV
IV
IV
F
Undersized
welds
on
instrument rack
Excessive
gap behind pipe
support baseplate
Undersized weld on
instrument tubing support
Lack of corrective action
to preclude further damage to
instrument tubing lines
I
e
'Inspectfon .
Severfty 'unctfona1
, '~Re art Mo.
LeveI
Area
= Vfolatfon
Pfpe sUpport fnsta11atfon
not
performed fn accordance
wfth
engfneerfng dfrectfve
r
r
I
e
I
-83-1/31/85
'
"
AREAS
INSPECTED
i ~
Regional:Environmental
protection
program
Regional: Electrical cables,
motor
control centers
and gA records
.-gpg"'-'+ ~$~gQ
I
+
~
~
~ T
43
'
~
~
TABLE 4
'NSPECTIOM
REPORT ACTTVITIES
10-1
N
N
MIL
0
N
UN
'
" " '"INSPECTION:, ~
':,'::;;.",," .'-.;.': REPORT:."
': INSPECTION
.
'UMBER ~ *, 'OURS
-~:. 83-13
14
.
4
83-15 "
28
'I
~
+
~
(
V
~ 83-16
83-17
.
83-18
84-01
84"02
84-03
84-04
84-05
184
166
1920
176
32
28
36
122
Resident:
Equipment turnover,
piping, pipe support, reactor
building enclosure,
CRD piping,
fire protection,
instrumentation
gA program
Resident:
RPV storage,
hydraulic
control unit installation, piping,
. pipe supports,
welder
qualification,. HVAC systems
ICE Hdq CAT inspection: welding,
NOE, electrical, structural/civil,
gA, mechanical
Resident:
pipe supports,
diesel
generator
cranes,
reactor vessel
internals,
gA program
Regional:
Cables,
switchgear
and
gA records
Management
meeting
on licensee
corrective actions for CAT
findings
Regional:
Concrete
anchor bolts
and structural
steel welding
Resident:
Electrical terminations,
piping, pipe supports,
gA
surveillances,
contractor audits,
design control of non-safety
related
items
suspended
over
safety related
equipment
4
V
~
."'-~ -,:.-'; -'... '...:. REPORT
.':-.'f'i>>:;- "':%:!i'NUNBER
84-06
'

~ ~
$
~
~
~
/
84-07
84-08
e
INSPECTION:
HOURS
237
31
662
84-09
179
~ 0
': -":." ':" "'
'
INSPECTION
AREAS
'NSPECTED
Resident: Structural steel,
weld
material control, pipe supports,
housekeeping,
post inspection
.rework control
Regional:
Large and Small bore
pipe supports
Regional:
NDE van inspection of
hSHE and structural veldments
by
independent
examination
Resident:
Corrective action
. programs, electrical penetrations,
pipe whip restraints,
component
supports
kl)~h, ( .
+gal
)j&,.
~ >S:q'.
).
~
~
dr
~ ~
)
~ Y
)
84-10
84-11
84-12
84"13
84-14
84-15
84"16
30
196
Cancelled
114
34
202
Regional: Pre-operational
secur ity
inspection
Resident:
Document control,
containment
supports,
design
change installation,
equipment
preventive maintenance
-'..
- Resident:
Design change control,
revetment ditch, pre-op personnel
.
qualifications, hydrotests,
preventive maintenance,
standby
liquid control system, veld filler
metal control
Regional: welder qualifications,
welding, welding records
Resident:
Electrical cable
separation,
containment
penetrations,
diesel
generator
modifications
Regional:
Radiological Control
staffing
~ a
'
0
4;<%.Table 4"
<<'.-."-',>>;,,"', .... INSPECTION
.
r
-
NUMBER
. ~h,'84
17 c
~
~
(
hr i
84-18
'I
. 84-19
r
h
84-20
\\
~
~yt
t'
~
~r
~ '
t
~
~". "45
r~
INSPECTION
~ HOURS
'30
'07
239
'AREAS
INSPECTED
Regional: Safety related
equipment, installation,
inspection of equipment,
preventive maintenance
Regional: Construction
Team
Inspection,
prospect management,gA,
design control, welding,
NOE,
electrical, mechanical, structural/
, civil
. Resident:
MSIV cladding
operations,
instrument tubing and
support,
small bore pipe supports,
ITT pipe supports,
concrete
expansion
anchors
Management meeting
on licensee
, corrective actions to CAT and site
radiography program
Ih,
~
~
'
J
a /
85-01(draft)'6
Regional: Preoperation
Administra-
tive controls
~ L
'
~
kt
t
~
~ )
46
1018 -1318
I,
r
, ~ +
q \\ ~
,PP
$ q
~
I
TABLE
S'RR
SUPPORTING
DATA
4::-.
1, - HRR-Ucensee'eetin
s
~
~
A large
number. of meetings
were held with the applicant in Bethesda
to
resolve and/or discuss staff concerns.
The meetings
are documented within
meeting summaries.
r'.
NRR Visits and Audits
Structural site visit and audit at Stone 5 webster. design office
Mechanical audit at Stone I Vebster design office
Instrumentation'and
Control visit to General Electric design office
Auxiliary Systems site visit
Reactor
Systems, site visit
Second environmental site visit
i
3.
Licen sin
Document
Issued
)P P
P ~
~ '
I
~ )1
c~
Draft Environmental
Statement
) ~P
Draft Safety Evaluation Report
Safety Evaluation Report
4.
A licant Res onses
Responses
to request for information in the safety
and environmental
areas
Letters and
FSAR updates to respond to OSER concerns
Comments to the
DES
'R
1

ML17054B564

Text

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