ML17055B655

Within this

assessment

period, four radiation specialist

inspections

were

performed.

The Radiological

Control

Program at Unit 2 is primarily the

Unit

1 program extended

to cover Unit 2.

Accordingly, the

inspections

determined that this extension

was generally being

performed acceptably.

The proposed organization

and projected staffing appeared

to

be adequate

to support the combined operations.

The position

responsibilities

and authorities

were generally clearly defined.

" Walkdowns of installed solid and liquid waste .processing

systems

and ventilation filter trains

found them consistent with FSAR

descriptions.

The receipt

and inspection of new fuel was

well'lanned,

and the training associated

with this effort was

acceptable.

Some of the licensee's

radiological control efforts were note-

worthy.

Specifically, the installation of a state-of-the-art

radioactive

waste control

room, including computer controlled

processing,

and

a separate

bridge with associated

equipment for

decontaminating

the reactor cavity demonstrated

a willingness to

design

the plant with radiological control considerations.

Also,

polishing the reactor cavity walls demonstrated

a good

ALARA

approach.

Further,

the licensee's

investigation of a potential

alpha

source

leak was comprehensive,

timely, and technically

sound.

Finally, efforts to incorporate

the experiences

of other

licensees

into radiation shield survey procedures

were very

good.

Inspection results

indicated that

some

program aspects

needed

additional planning

and coordination'pecifically,

the program

for training, qualifying, and retraining radiological control

personnel

was not well defined,

and areas

such

as the

scope

and

frequency of training were undecided.

Subsequent

to the initial

NRC review,

a program

was developed

to train personnel

in safety

significant procedures

and procedure

changes,

but the program did

not, include

a method to evaluate its effectiveness.

In addition,

the application of NRC bulletins, circulars,

and

generic letters to appropriate

operational

procedures

and train-

ing programs

was not comprehensive

or continuously maintained

throughout the life of the projects

This shortcoming

was most

apparent

in the areas

of cross contamination

between

radioactive

and non-radioactive

systems

and storage of radioactive material.

12

NRC presence

has

been

necessary

in this area to assure

proper

development of the Unit 2 program.

Management attention to

assure

thorough application of program requirements

is

warranted.

2

~

Conclusion:

Rating:

2

Trend:

No Basis

3.

Board Recommendations:

Licensee:

Thoroughly apply published

NRC guidance

to development

of operational

procedures

and training'rogram.

NRC:

None

ll

1

13

C.

Surveillance

(95 hours0.0011 days 0.0264 hours 1.570767e-4 weeks 3.61475e-5 months ,

2%)

l.

~Anal .ai a

This area

was not addressed

in the previous

Within the

assessment

period three specialist

inspections,

supplemented

by

some routine resident inspections,

were performed in the Pre-

service Inspection

(PSI) area which provides

a baseline for

future surveillance activities.

The field implementing procedures

were found technically

adequate.

Examinations

were performed

by qualified personnel,

and the resulting data

was properly recorded

and evaluated.

Inprocess

ultrasonic

and liquid penetrant

examinations

were

found to meet

ASME requirements.

The

PSI contractor

appears

to

have sufficient personnel

resources

to effectively carry out the

examination

program.

The licensee

implemented

a conservative

approach

regarding

volumetric weld examination.

The

ASME code requires that only

the lower third of the weldment

be examined while the

PSI site

program specifies

the entire weld be examined.

Review of the docketed

PSI program

showed that the program list

of weldments

was not consistent with the

ASME code categoriza-

tion,

as the welds were listed by plant system in lieu of code

category,

and the

scope of weldments

covered

by the program was

ambiguous.

The licensee

has since re-submitted

a completely

revised

program.

Review of ultrasonic examination

records identified that neither

the licensee

nor any of the contractor organizations

were taking

responsibility

for the acceptability of the data.

The initial program shortcomings

can

be attributed to an over-

reliance

upon the contractor to develop the

PSI program

and

a

lack of licensee

oversight of the contractor's efforts.

2.

Conclusion:

Rating:

3

Trend:

No Basis

14

3.

Board Recommendation:

Licensee:

Institute program to assure

development,

approval

and implementation of technically adequate

surveillance

procedures.

NRC:

Review adequacy

of licensee's

program prior to,fuel

load.

IT

15

D.

Prep erational

Testin

(710 hours0.00822 days 0.197 hours 0.00117 weeks 2.70155e-4 months ,

16/)

l.

~Anal sis

This area

was not addressed

in the previous

During the

current assessment

period,

three specialist

inspections

were

performed in addition to resident

inspector coverage.

Several

examples

were found in which the procedure

acceptance

criteria were inconsistent with the stated

value in the

This indicates

inadequate

review of the procedures

by the

licensee

to ensure

compliance with licensing commitments.

Most

procedures

were found to yield a valid test of the system's

function and logic.

An exception to this was

an improper valve

line-up in the reactor

vessel

hydrostatic test procedure that

'would have prevented

subjecting

a portion of the

system to test

pressure.

This issue,

identified by the

NRC, was corrected

prior to the test.

After the reactor vessel

hydrostatic test,

the licensee dis-

covered portions of five small

bore pipes that had not been

correctly inspected'our

were due to valve line up errors,

and

one was

an instrument line that the licensee failed to

examine during the hydro.

Each of these

lines was subsequently

individually hydrostatically tested.

The licensee's

program for testing is divided into two phases:

preliminary testing of individual components

and preoperational

tests of systems

and components

to satisfy the requirements

of

the

The inspectors

noticed that the licensee

was using

some of the preliminary test results

to satisfy

FSAR acceptance

criteria.

While this is an acceptable

approach,

the licensee

was

slow in responding

to

NRC requests

for

a list of those pre-

liminary tests

so that they could be reviewed

and inspected.

Errors were identified in the list when submitted.

To date,

preoperational

testing is complete for only six safety-

The performance of preoperational

tests

have

generally

been acceptable.

Test engineers

are

knowledgeable

of their systems

and the administrative controls for testing,

and guality Assur ance

personnel

are witnessing the testing.

Preliminary testing of the Diesel Generator units

has identi-

fied numerous

problems.

These

involved wiring errors,

improper

circuit design,

lube oil hose

damage,

and unit operation at

excessive

load.

If left uncorrected,

several

of the deficien-

cies would have

made the diesel

generators

inoperable during

emergency conditions.

While the test

program satisfactorily

identified these

problems prior to plant operation,

discovery

4',

f

I"

I'V

4 q

16

of these

problems

was

an indication'f poor quality design

and

fabrication.

As testing effort progresses,

the licensee

must

be

aware that similar problems

may be identified in other plant

systems.

Review of the training and qualification of system test engineers

identified problems

such

as incomplete

and unavailable

records

which precluded

NRC determination of the adequacy of the training

and qualification of these

personnel.

Documentation of 'the

acceptability of the architect engineer's

(AE's) training program

for startup

personnel

was not available

nor were all resumes

of

personnel

readily available for,review.

When brought to the

licensee's

attention,

a comprehensive

audit of the training,

qualification,

and experience

of startup

personnel

was performed.

The review of the AE's training program

was documented

and the

resumes

of all individuals were located.

In this area,

NRC presence

is mandatory.

While the pace at

which testing is performed is not

a safety concern,

the lack of

an accurate

schedule

of testing is indicative of poor planning,

which precludes effective resource

al,location

by both the

licensee

and the

NRC.

The conduct of testing

and quality assur-

ance witnessing of testing indicates appropriate

management

controls

However,

we are concerned that extensive

NRC involve-

ment is required to identify deficiencies

in the preparation

of

preoperational

test procedures.

Additional management

attention

is warranted

in this area.

2.

Conclusion:

Rating:

2

Trend:

No Basis

3.

Board Recommendation:

Licensee:

Based

on mediocre

past test preparation

performance,

the licensee

should evaluate

the methods

in place to

verify test accuracy

and adequacy of test results

reviews to ensure

compliance with FSAR commitments.

NRC:

None

A"

t

ik

17

E.

Fire Protection

(157 hours0.00182 days 0.0436 hours 2.595899e-4 weeks 5.97385e-5 months , 4/)

l.

~Anal sis

This area

was not addressed

in the previous

Within the

assessment

period two specialist

inspections

were performed.

A team, inspection

was performed during October

1985, to assess

the plant safe

and remote

shutdown capabilities

in the event

of a design basis fire.

An essential

cabling study

had

been

performed

by NMPC,

and the separation

of redundant

cables

was

verified by computer

analysis.

The plant procedures

for

achieving

remote

shutdown

were found adequate.

The licensee fire protection staff and consultants

were knowl-

edgeable,

and the plant routinely exhibited

a conservative

design

philosophy to assure

plant safety.

The licensee

records

were

complete

and well maintained.

Corporate

management

was fre-

quently involved during the

NRC inspection to resolve

items of

concern

and to provide timely formal commitments.

Several

specific items of concern,

such

as fire detectors,

emergency

lighting and

some fire proof installations

remain

open

due to

the relatively low level of construction

completion in this area

at the time of the inspection.

A special

review was performed to support fuel receipt

activities.

Areas

examined

included fire brigade training,

control of combustibles,

and operability of fire extinguishing

systems.

Licensee

management

had directed that continuous

and

roving fire watches

be established

as certain fire mitigating

systems

were not yet operational.

The overall

program

was found

adequately

implemented.

2.

Conclusion:

Rating:

1

Trend:

No Basis

3.

Board Recommendations:

Licensee:

None

NRC:

None

i

~

18

F.

~Securit

(92 hours0.00106 days 0.0256 hours 1.521164e-4 weeks 3.5006e-5 months ,

2%)

1.

~Anal sis

This area

was not addressed

in the previous

Three pre-

operational

security

program reviews,

including one inspection

of the implementation of security

and other storage

requirements

for new fuel,

and

one inspection of the licensee's

program for

control

and accountability of Special

Nuclear Material

(SNM),

were performed

by regional-based

safeguards

inspectors.

The licensee

was very aggressive

in the development of the

physical security

program

and its integration into the existing

security program for Unit 1.

The licensee

modified the existing

security

management staff, redesigned

security plant implementing

procedures

and orders,

and conducted

security training and

orientation in new security

systems.

These additional security

tasks

have

been

accomplished

with minimal impact

on the daily

operation of the Unit

1 security program.

The licensee

aggressively

pursued resolution of outstanding

issues identified during Region I preoperational

security

program reviews.

All security program plans were found to be

professionally prepared,

well organized

and submitted

'in a

timely manner.

Changes

necessitated

as

a result of NRC review

were accomplished

in

a timely and cooperative

manner,

demon-

strating the licensee

commitment to an effective security

program

and their respons'iveness

to regulatory

requirements'anagement

interest in an effective program was further demon-

strated

by the construction of a modern

two story security office

building.

Facilities include

a document control vault, special

purpose offices and

a modern physical fitness

room with lockers

and showers.

In addition, the ground floor of this building

serves

as

a protected

area control point that includes

a weather

protected vehicle entrapment

area.

gA auditors

and survey personnel

were aggressive

and prompt in

following up

on identified issues.

Project engineers,

respon-

sible for the systems

and equipment,

and on-site security manage-

ment personnel

were found to be very knowledgeable

of program

status,

testing

schedules,

turnover dates

and

NRC performance

criteria.

NRC reviews

found that the licensee's

integrated

security resources

were ample, well defined

and effective.

Attention generally

was found to be directed

toward practical

applications

and lessons

learned.

However, in one instance,

some

hardware

problems

were identified by

NRC inspectors.

These

problems

should

have

been detected prior to

NRC involvement.

19

Security personnel

received specialized training on Unit 2

security equipment

and systems.

The training was administered

by qualified personnel

and was consistent with the requirements

of the current NRC-approved Training and gualification Plan for

Unit 1.

Unit 2 security personnel

were observed

by the

NRC

staff to have progressively

improved their capabilities during

this assessment

period.

In contrast

to other support areas,

clear evidence

was obtained

of corporate

management

involvement and prior planning in the

areas of security

and safeguards

aspects

of licensing,

as dis-

cussed

in section

I of this assessment.

2.

Conclusion:

Rating:

1

Trend:

No Basis

3.

Board Recommendation:

Licensee:

None

NRC:

None

I

t

k

t

/V

k

~

t

20

Construction

(2512 hours0.0291 days 0.698 hours 0.00415 weeks 9.55816e-4 months ,

56%)

1.

~Anal sis

The previous

SALP evaluated

the following construction

areas

separately:

containment;

piping systems;

mechanical

components;

support

systems;

electrical

equipment;

instrumentation

systems;

nondestructive

examination;

and engineering.

These

areas

have

been

combined

under the Construction functional

area for this

It is anticipated that future assessments

will reflect

completion of construction activities and will concentrate

on

the operational

assessment

areas.

Concerns identified in the previous

SALP included:

improper

structural

steel

connection bolting; pipe supports

not

installed in accordance

with design

documents;

control of pre-

ventive maintenance

program;

SWEC procurement quality assurance

not always effective;

adequacy of design

change

documents;

and

electrical

equipment wiring deficiencies.

Inspection

coverage

in x,his area

has

been

performed

by both

specialist

and resident

inspectors.

A second nondestructive

examination

(NDE) van inspection

was performed.

The conduct of

the

SWEC Engineering

Assurance

Technical Audit was inspected

hy

both Region I and Inspection

5 Enforcement

personnel.

Vendor wire termination deficiencies

were identified during

sample reinspections

of installed electrical

equipment.

Based

upon the unsatisfactory results,

an inspection

was performed

of all safety-related

electrical

equipment to assure

the adequacy

of the vendor workmanship.

Inspection of other electrical

installations

found conformance

to the design requirements.

The electrical

separation

problems of the

Power Generation

Control

Complex

(PGCC)

have

been

evaluated

in previous

SALPs.

NMPC instituted significant field efforts to rectify the con-

ditions including numerous

panel

walkdowns,

enhanced

cable

marking and enhanced

inspection attributes.

After the comple-

tion of the licensee's

corrective actions,

an

NRR site audit

identified another

PGCC panel

for which General Electric (GE)

had not invoked the separation

requirements.

Completion of

additional

NMPC separation

walkdowns, that are scheduled,

are

necessary

to resolve the outstanding

PGCC separation

concerns.

Inspection of instrument

systems identified

a generally high

degree of design

conformance.

Followup inspection of an alle-

gation received

by Region I identified deficiencies

regarding

Neutron Monitoring System

(NMS) cable installations

and asso-

ciated installation procedures.

The

NRC inspection additionally

identified inadequate

licensee

investigation of the concerns

regarding

the actual

method utilized to install the

NMS cables.

I

~1

I

1

+r!

l

hI

21

Subsequently,

at the request of the

NRC, the

NMS cable instal-

lations were demonstrated

acceptable

during engineering

mock

pulls.

The rework of the Main Steam Isolation Valves (MSIVs) involved

an overlay of the inlet and outlet spool bores.

The

need for

the

MSIV rework was based

upon licensee

recognition of problems

at

a foreign nuclear facility that utilized similar ball valves.

The rework process

was well controlled.

Site organizations,

namely engineering,

construction

and quality, appeared

to inter-

face effectively.

The

second

NOE van inspection

independently

confirmed satis-

factory conduct of site weld inspections.

Licensee corrective

actions to resolve

adverse

conditions were reviewed

and found

acceptable.

The previously identified problems with radiographic

film duplication, film interpretation,

and film indexing were

resolved.

The multifunction and enterprise

supports

fabricated

by Reactor

Controls Incorporated

(RCI) were reinspected

by

NMPC on several

occasions

to establish

the adequacy of the weldments.

RCI

instituted several

measures

at

NMPC insistence,

such

as

use of

work packages,

to better control in-process

work activi .ies.

During

NRC inspections

of RCI activities,

RCI site personnel

were unable to provide responses

to technical

concerns

such

as

fit-up requirements

for fillet welds

and installation tolerances

for pipe restraints.

Based

upon the large

number of reinspec-

tions performed

on

RCI installations

as

a result of NRC concerns

identified initi'ally by the Construction Appraisal

Team (CAT)

inspection,

and the lack of RCI technical

expertise, it is

apparent that

a quality product was achieved

only as

a direct

result of licensee

response

to

NRC concerns

over the past three

years.

Inspection of ITT pipe support installations

have verified the

effectiveness

of corrective actions to address

both welding and

mechanical

deficiencies.

NRC inspection identified two situations,

involving HVAC base-

plate

shimming criteria and

embedment

welding restrictions,

where

SWEC engineering failed to identify the requisite

inspec-

tion attributes for (}uality Control inspection.

In addition,

inconsistent

design information had been

promulgated

in regard

to duct support bracing that resulted

in indeterminate

support

configurations.

Reinspections

were performed,

and all field

installations

were ultimately determined

to be acceptable:

SWEC was responsible

for the implementation of the pre-turnover

Preventive

Maintenance

(PM) program.

The

PM group

has

been

adequately

staffed with supervisory

and craft personnel,

and

dedicated guality Control inspectors

were provided for

PM

I

p1'

q

22

activities.

PM schedules

were maintained

on

a computerized

system.

SWEC engineering

reviewed Environmental gualification

and equipment

manuals to identify all necessary

PM measures.

The site program

was revised to incorporate all of the requisite

PM requirements.

The post-turnover

PM activities are similarly

guided

by

a computerized

scheduling

system.

NMPC maintenance

personnel

are available to supplement

SWEC efforts.

Plant housekeeping

conditions

have deteriorated

in some plant

areas,

particularly those that have not been turned over to

NMPC.

The lack of proper cleanliness

levels

can lead to poten-

tial degradation

of permanent

plant equipment

and is reflective

of poor personnel

practices

and inadequate

supervisory oversight.

Although the overall plant cleanliness

remains

poor, those areas

which have

been turned over to

NMPC exhibit improved control of

cleanliness.

Improvements

have

been

noted in the overall licensee

performance

in this area.

A substantial

amount of NRC inspection

resources

'ere

utilized to review licensee corrective actions

implemented

in response

to

NRC open

items ident,ified by the

1983

CAT and

followup inspections.

As

a result of the problems identified,

extensive efforts were necessitated

and successfully

implemented

during this appraisal

period by

NMPC to verify the adequacy

of

installed plant hardware.

2.

Conclusion:

Rating:

2

Trend:

Consistent

3.

Board Recommendation:

Licensee:

None

NRC:

None

Wr

j,i

I

h

23

H.

Assurance

of ualit

(374 hours0.00433 days 0.104 hours 6.183862e-4 weeks 1.42307e-4 months ,

8%)

l.

A~nal sis

This area

was jointly assessed

in the previous

SALP with that of

Project Management.

The previous concerns

included commitment

tracking, inter-organization

communication interfaces,

and hard-

ware reinspection

results.

During this assessment

period, Quality Assurance

is ag'ain being

considered

as

a separate

functional area.

Management

involvement

and control in assuring quality continues to be

one evaluation

criterion for each functional area.

The various aspects

of Quality Assurance

Program

requirements

have

been considered

and discussed

as

an integral part of each

.- functional

area

and the respective

inspection

hours are included

in each

one.

Consequently,

this discussion

is

a synopsis of

the assessments

relating to the quality of work conducted

in

other areas.

The Quality Performance

Management

Program

(QPMP)

has monitored

key parameters

such

as

hardware quantity installed, quantity

inspected,

QC acceptance

rates,

outstanding

design

changes,

and

nonconformance

document closure rates.

The

QPMP was implemented

in response

to an

NRC order that mandated

liceosee

tracking of

performance

indicators.

Based

upon

NRC observation,

the

QPMP

was helpful to diagnose

construction

problems

and to assess

the

adequacy of corrective actions.

Licensee

QA personnel

have developed

extensive checklists for

guidance during the conduct of survei llances.

The checklists

are

based

upon regulatory requirements,

FSAR commitments,

industry codes,

and design specifications.

The

use of the

checklists during the review of preoperational

test activities

represents

a strengthened

involvement ofQA in the independent

verification of construction

and site test activities in rela-

tionship to licensing commitments.

Review of NMPC audit reports

and associated

audit checklists

indicates that while auditors

are examining plant hardware,

the

audit reports

do not reflect the total

scope of the audit.

The

reports

on occasion

serve

as

an executive

summary

and

do not

document the complete extent of the audit in an explicit manner.

In response

to deficiencies identified during the

NRC Construc-

tion Appraisal

Team inspection

(50-410/83-18),

NMPC instituted

a large

number of hardware reinspection efforts to ascertain

the conformance of hardware installations with,the design

ll

24

requirements.

The

sample reinspections

included piping and pipe

supports,

instrument tubing and supports,

HVAC duct supports,

mechanical

equipment,

concrete,

structural

steel,

nuclear coat-

ings,

expansion

anchors,

electrical

raceway,

and cables.

The

identified deficiencies

were evaluated

by engineering.

A total

plant reinspection

was performed of electrical

equipment

vendor

terminations,

and guality Control inspection

procedures

were

revised

as necessary.

Significant effort was finally made

by the licensee

to address

long outstanding

NRC open

items particularly in the Nondestruc-

tive Examination

area

and those identified during the

CAT

inspection.

NRC review of licensee

actions

has identified two

shortcomings within the corrective action program.

The scope of

some underlying problems

was not fully identified which resulted

in the implementation of incomplete corrective actions.

Some

. cases

were also found where

long term corrective actions

had not

been effectively maintained.

Major licensee initiatives included

an

FSAR verification program

to ensure

implementation of and accuracy of the

However,

FSAR inaccuracies

continue to be identified during routine

inspection activities.

The Preparedness

for Operation

Plan

was

conducted

to assure

tnat all required

NMPC procedures

have

been

developed,

that requisite training has

been

accomplished

and

that responsible

organizations

are prepared for the operation of

the plant.

The project design

process

was assessed

by the

SWEC Engineering

Assurance

Technical Audit.

The NRC'eviewed the audit program

plans.

Conduct of the audit was monitored

as well as the cor-

rective action phases.

Some concerns

were observed with the

auditor s exercising

independent

judgement

on design

adequacy

and accepting

design

guides without verification of appropriate

regulations.

The

SWEC audit concluded that the overall design

process

was

implemented

in

a controlled manner.

A team inspection

was performed of the

NMPC allegation handling

program (guality First).

The inspection

scope

included review

of identified concerns,

interviews of guality First personnel,

review of concern resolutions,

examination of related site

procedures

and hardware,

and interviews of site personnel

not

affiliated with the guality First Program.

The resolution of

safety related

concerns

was found satisfactory.

Some program

weaknesses

were identified in the area of handling of wrongdoing

issues

and level of guality First documentation

to substantiate

concern closure.

25

2. 'onclusion:

Rating:

2

Trend:

Consistent

3.

Board Recommendation:

Licensee:

None

NRC:

None

Jv,%

1

'I

26

1.

~Licensin

l.

~Anal sis

The licensing area

had

a significant level of activity during

the period, particularly in the areas

of responses

to

NRC

requests

for information, responses

to

SER outstanding

and con-

firmatory issues,

support for the

ACRS full and subcommittee

meetings,

support for NRR on-site audits,

support of the Tech-

nical Specification

review,

and response

to the downcomer

bracing issue.

Management

support for licensing activities

has

been evident.

NMPC provided timely and technically adequate

responses

to con-

cerns

from the

ACRS full and subcommittee

meetings

which resulted

in the issuance

of a favorable full power letter from the

ACRS.

A large

number of onsite audits were performed

by

NRR during the

assessment

period to support the licensing effort.

The audits

were generally well supported

by the licensee,

as evidenced

by

availability of appropriate

documentation

and personnel,

and

the audit results

show evidence of prior planning.

The

NMPC resolution of technical

issues

has

been generally

acceptable.

This included the responses

to

SER issues

and was

also noted during the Technical Specification

review process.

The

NMPC responses

generally exhibited

an understanding

of the

technical

issues,

and viable, generally

sound

and thorough

approaches

were proposed.

The downcomer

analysis is an excep-

tion, as this issue

was the source of technical

disagreement

during the later

stages

of the period.

NMPC ultimately applied

extensive effort to respond to most of the staff concerns

in a

short period of time.

A recent

FSAR amendment

included

two caveats

that the

FSAR plant

description

may vary from the as-designed

or as-built conditions.

In particular

NMPC stated that dimensions

and quantities

stated

in the

FSAR are nominal.

Region I review of the Standby Liquid

Control

(SLC) system design

and preoperational

test procedures,

a few days after the close of the assessment

period, identified

that the two SLC pumps are rated for a cumulative flow rate of

82.4

GPM in lieu of 86

GPM as specified in the

This error

impacts the

SER acceptance

of the

SLC system in regards

to

10 CFR 50.62,

which requires

the capability to inject

a minimum of

86

GPM at

13 weight percent

sodium pentaborate

solution.

The

accuracy of the

FSAR is critical for the performance of the

licensing review.

The

NMPC attitude that the

FSAR is not

a

design

document fosters

the problems

noted regarding

the

inaccuracies.

As indicated in section

H of this

SALP,

an

verification program

has

been

implemented

by

NMPC.

The identi-

fication of further inaccuracies

of this nature after the

conduct of the associated

licensee verification efforts indi-

cates further attention is required

in this area.

A'~

'I I

I

27

Followup effort to the October

1984 Caseload

Forecast

Panel

Meeting was conducted.

NMPC chose

not to revise the projected

Fuel

Load date

even

though evidence

existed to support the

NRC

projected slip in the

Fuel

Load date.

In January

1986,

the

licensee

Fuel

Load date

was

revised.

NMPC was continually

unable to adhere to scheduled

commitment dates

made to the

NRC

staff.

This process

posed difficulties for effective

NRC

resource

scheduling,

both licensing

and inspection.

The safeguards

area continued,

in this

SALP period, to be

an

area of effective performance.

There

was consistent

evidence

of prior planning

by utility (including corporate level)

management.

Responses

regarding

safeguards

matters

were tech-

nically sound

and consistent,

demonstrating

the existence

of

well developed policies

and procedures

for control of security-

related activities.

The licensee's

responses

in the safeguards

area

were submitted promptly and in most cases

were acceptable

the first time.

The Security Organization positions

and respon-

sibilities are well defined,

and the security staff is considered

to be more than

ample to implement the facility physical pro-

tection program.

The timely resolution of licensing issues will remain dependent

upon

NMPC responsiveness.

In order to avoid impact

upon the

licensing process,

management

attention

needs

to be focused

on

issuance

of operating

procedures,

testing of Kaman isolators,

justification for deferral of preoperational

tests,

and justi-

fication for alternate

means to provide structural

steel fire

protection.

\\

2.

Conclusion:

Rating:

2

Trend:

Consistent

3.

Board Recommendation:

Licensee:

None

NRC:

None

t,

k

Pr

Pg

II

28

V.

SUPPORTING

DATA AND SUMMARIES

A.

Construction Deficienc

Re orts

(CDRs)

The licensee identified twenty seven

(27) potential

10 CFR 50.55(e)

Construction Deficiencies during the assessment

period,

three of

which were subsequently

found as not reportable.

Table

1 identifies

the reported

items

and the current

NRC item status.

Analysis of the

CDRs for causal

linkage

has resulted

in the identification of the

following linked chains:

CDRs 85-00-06,

85-00-14,

85-00-23,

85-00-27,

85-00-29.

Vendor or

SWEC

design errors resulted

in deficiencies that would preclude

prop-

er operation of the Diesel Generator units.

CDRs 85-00-11,

85-00-13.

Improper vendor

or site craft practices

= resulted

in a hardware configuration that would degrade

the op-

erability of the Diesel

Generator units.

B.

Alle ations

Summar

During the assessment

period

13 allegations

were received

by the

NRC.

Routine inspection

followup has

been

performed in response

to ten of

the all'egations.

Seven of the allegations

were found invalid.

Two

violations were issued for a valid allegation

regarding

the

NMS cable

installations.

The remaining

two valid allegations

were found to

have

been properly addressed

by the licensee.

C.

Escalated

Enforcement Actions

No escalated

enforcement

actions

were initiated during this

SALP pe-

riod.

Section

IV.C of the Enforcement Action 83-137 Order

was modi-

fied on March 15,

1985 to defer indefinitely the requirement

to

perform

a third party independent

appraisal

of organizational

respon-

sibilities, management

controls, staffing levels,

communications,

and

operating practices.

D.

Mana ement Conferences

'1.

February 6,

1985

A management

meeting

was convened at

NMPC

request.

The Management Analysis Corporation report was dis-

cussed

that had

been

generated

in response

to the

CAT Order.

The interim results of the

NMPC hardware reverification efforts

were presented.

2.

February

27 and March 15,

1985

A management

meeting

was con-

vened at

NRC request.

The

SWEC Engineering Technical Audit

program was reviewed.

The proposed

scope

a'nd conduct of the

final technical

audit was also reviewed.

4 yC

I

29

June

17,

1985 - A management

meeting

convened at

NRC request.

The

NMPC reverification of ITT-Grinnell large bore pipe supports

was discussed.

NMPC instituted program enhancements

and per-

formed engineering

analysis to demonstrate

the acceptability of

the pipe

supports'uly

23,

1985

A management

meeting

convened at

NRC request.

The

NMPC reverification of instrument tubing supports,

HVAC duct

supports,

and electrical

equipment

were discussed.

Additionally

the electrical

separation

program

and

FSAR verification efforts

were discussed.

January

22,

1986

A management

meeting

convened at

NRC request.

The plant completion status with respect

to construction,

preoperational

testing,

and operational

readiness

were dis-

cussed.

This information will be utilized by the

Region I Near

,Term Operating

License

(NTOL) Review Panel

to guide

NRC inspec-

tion activities.

E.

Licensin

Activities

II

NRR Licensee

Meetin

s

A large of number of meetings

were held with

Bethesda

to resolve/discuss

staff concerns.

ed by meeting

summaries.

the applicant in

These

are document-

NRR Site Visits 5, Audits

Instrumentation

and Control Audit

Environmental gualification Audit

Seismic gualification Review Team Audit

Pump

and Valve Operability Review Team Audit

Containment

Systems Site Visit

Electrical

Power Systems

Site Visit

DCRDR Audit

Safety Parameter

Display System Audit

Revetment Ditch Audit

January 7-9,

1986

December

16-20,

1985

July 8-12,

1986

July 8-12,

1986

January

7,

1986

December

17-18,

1985

March 19-22,

1985

July 17-18,

1985

August 27,

1985

Licensin

Documents

Issued

FES

SER

SSER-1

,SSER-2

Draft Technical Specifications

Proof-and-Review Technical Specifications

April 1985

February

1985

June

1985

'ovember

1985

August 29,

1985

November 20,

1985

30

4.

A

licant Res

onses

a.

Responses

to requests

for information.

b.

Letters 5

FSAR updates

to respond

to

SER concerns.

c.

Responses

to ACRS

questions'.

Responses

to concerns

on downcomer supports.

e.

Support for the Technical Specification review.

f.

Support for the

ACRS full and subcommittee

meetings.

CP

TABLE 1

CONSTRUCTION DEFICIENCY REPORTS

(February

1,

1985 - January

31,

1986)

NINE MILE POINT,

UNIT 2

CDR No.

85-00-04

85-00-05

85-00-06

85-00-07

Subject

MSIV actuator latching

bearing failure

ECCS manual control

switches

do not main-

tain run position

~ .Overheating of DG con-

trol cabinet

due to

non-safety coil fai lure

Anaconda flexible con-

duit bend radius vio-

lations

Cause

Code

~Disci line

Status

Open

Closed

Open

85-00-08

85-00-09

85-00-10

85-00-11

DG jumpers missing

ITT design of trim

details without

SWEC

review

Structural

steel

sub-

supplier did not have

a

Appendix

B quality

assurance

program

DG lube oil hose

abraded

by timing chain

Determined not

reportable

Closed

Cl osed

85-00-12

85-00-13

85-00-14

Motor lead connections

A

sealed with unapproved

insulation material

DG timing chain

F

.sprocket

locknuts

missing

DG load shedding timer

B

overcurrent

Closed

Open

II

gl~

CDR No.

85-00-15

Subject

Missing jumpers for

limit switch assembly

on

MOV

Cause

Code

~Disci line

Status

Open

85-00-16

Unqualified filler

A

material

used for attach-

ment welds to contain-

ment liner

Closed

85-00-17

DG tested

in excess

of rated

power

Determined not

reportable

Cl osed

85-00-18

Linear indication in

C

tube steel

seam weld

Open

85-00-19

ITT disassembled

valves without pro-

cedure

Determined not

reportable

Open

85-00-20

RCIC suction line

isolation valve missing

Closed

85-00-21

Erroneous

RCIC steam-

B

line drain trap set-

point

Open

85-00-22

Limitorque motor

operator failed

qualification testing

Open

85-00-23

DG current trans-

former wiring error

Closed

85-00-24

85"00-25

85-00-26

PGCC solder

connec-

tions nonconforming

Valve

CNTR did not.

document test

coupon

heat treatment

para-

meters

Panel

boards

not

mounted in qualified

arrangement

Open

85-00-27

UPS induced

DC noise

C

cancelled

DG emergency

start signal

Open

Qb+

V

CDR No.

85-00-28

Subject

Insufficient thread

engagement

of

SWP

motor anchor bolts

Cause

Code

~Di sci line

Status

Open

85-00-29

DG exciter field cir-

B

cuit incorrectly sized

Open

85-00-30

Spatial

clearance

vio-

F

lations between struc-

tural steel

and containment

Open

Cause

Codes

A

Personnel

Error

B Design Error

C

External

Cause

D -

- Defective Procedure

E

Component Failure

F -

Fabrication Error

~Snmmac

Cause

Code

Total

Number

A.

B.

C.

D.

F.

Personnel

Error

Design Error

External

Cause

Defective Procedure

Component Failure

Fabrication Error

, Total

24

CONSTRUCTION DEFICIENCY REPORTS

CORRELATED BY DISCIPLINE

s

~Disci line

Cause

Codes

Total

1. Safety Related Structures

2. Piping Systems

and

Supports

3. Mechanical

Components

4. Electrical

Components

5. Instrumentation

Control

Systems

1/A, 1/C,

1/F

1/A, 1/B

1/A,2/B, 1/C, 1/F

5

1/A,3/B,4/C, 1/D,

11

1/E,

1/F

2/B, 1/F

3

TABLE 2

INSPECTION

HOURS

SUMMARY

(2/1/85 - 1/31/86)

NINE MILE POINT UNIT 2

Functional

Areas

A.

Readiness

for Operations

B.

Radiological

Controls

C.

Surveillance

D.

Preoperational

Testing

E.

Fire Protection

F.

Security

G.

Construction

H;

Assurance

of equality

I.

Licensing

Total

Hours

408

153

95

710

157

92

2512

374

4501

7> of Hours

9

3

2

16

4

2

56

8

100

r

I

TABLE 3

SUMMARY OF INSPECTION

REPORTS (2/1/85-1/31/86)

NINE MILE POINT,

UNIT 2

INSPECTION

REPORT

NUMBER

84-21

85-02

85-03

85-04

85-05

85-06

85-07

85-08

85-09

85-10

85-11

INSPECTION

HOURS

269

40

102

110

112

105

473

112

AREAS

INSPECTED

Concrete

expansion

anchors,

design control,

HVAC supports,

rework control,

PSI,

QA

corrective action

systems

Welding procedures;

RCI and

JCI welding operations

Preventive

maintenance,

electrical,

instrumentation,

HVAC

Welding inspection,

verification, electrical

equipment wiring

Management

conference

on

NMPC

hardware reverification

and

Management Analysis

Corporation report

QA/QC for preoperational

testing,

NSSS pipe supports

Cancelled

Electrical

and Instrumentation

equipment

Management

conference

on

Engineering

Assurance

Technical audit

Reactor Coolant

system

hydrostatic test,

spent fuel

racks,

nitrogen inerting

system

Reactor Coolant

system

hydrostatic test

1

i'

INSPECTION

REPORT

NUMBER

INSPECTION

HOURS

AREAS

INSPECTED

85-12

28

Open item closure,

cable pull

sidewall tension calculations.

85-13

238

Engineering

assurance

audit,

diesel

generator

exhaust,

startup quality assurance,

control rod drive system

installation

and hydrostatic

testing,

MSIY testing,

piping

and pipe supports,

structural

steel,

preoperational

test

procedure

review

85-14

85-15

Review of EA/gA Audit plans

Operator licensing

examinations for 12

SROs

and

12

ROs

85-16

85-17

26

37

Preservice

Inspection of

procedures

and data

Electrical

equipment

and

open

item review

85-18

85-19

85-20

157

93

SWEC Engineering

Assurance

Audit implementation

guality Assurance,

RPY

internals,

preliminary

testing,

flood control

berm

Preoperati onal radi ol ogi cal

controls, radiation protection

organization,

training,

facilities

85-21

85-22

85-23

24

Management

meeting to discuss

NMPC re-verification of large

bore pipe supports

Cancelled

Preservice

Inspection

program,

review of PSI data,

inprocess

PSI examinations

INSPECTION

REPORT

NUMBER

INSPECTION

HOURS

AREAS

INSPECTED

85-24

HVAC installations,

open

item

review

85-25

187

Instrumentation

components,

piping and pipe supports,

hydrostatic testing,

diesel

generator testing,

RPV

internals

85-26

Management

meeting to discuss

NMPC hardware reverification,

electrical

separation,