ML17276B421
| ML17276B421 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/01/1981 |
| From: | Dodds R, Haist D, Haynes R NRC - SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REVIEW |
| To: | Faulkenberry B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML17276B420 | List: |
| References | |
| NUDOCS 8205040777 | |
| Download: ML17276B421 (49) | |
Text
8205040777 820429 PDR ADQCK 05000397 A
PDR REGIONAL PERFORMANCE EVALUATION REPORT I.
UTILITY PERFORMANCE EVALUATION -
REGION V
Utility: Mashington Public Power Supply System Facilities:
MNP-2 (Construction)
MNP-1/4 (Constructi.on)
MNP-3/5 (Construction)
Appraisal Period:
MNP-2 May 1, 1980 - June 30, 1981 MNP-1/4 July 18, 1980 - June 30, 1981
'MNP-3/5' September 1,
1980 - June 30, 1981 Review Board Members:
'WNP-2
'~WNP-'1 4
WNP-'3/5
'.T.
R.C.
D.P.
A.D.
'.O.
J.D.
P.P.
D. F.
T.M.
R.
R.M.
L.L.
- Dodds, Chairman, IE:V
- Haynes, IE:V Haist, IE:V Toth, IE:Resident Inspector Elin, IE:V J
- Carlson, IE:V Narbut,'E:V Kirsch, IE: V Bishop, IF:Resident Inspector
- Auluck, NRR
- Hernan, NRR
- Mheeler, NRR X
'X X
X X
X Areas of Good Performance Following the appointment of Mr. R. L. Ferguson as Managing Director in June 1980, substantial Supply System and'-reactor project organizational changes were made.
The changes included the establishment, of site-based Program Directors responsible for construction, startup; and initial power generation.of the facilities..
Othe'r changes included deintegration of the MPPSS site organization from day to day engineering and construction management decisions and placing 'them in the true role of oversight project management.
Experienced management has been brough't in to key positions to implement these changes.
The utility has also had a team of industry management experts evaluate all projects.
This has lead to substantial contract changes to strengthen construction management.
It is too, early to assess the'et effect of. all of these
- changes, but the results to date appear promising.
Utilization by the Utilityof independent investigators from the'home office to examine allegations and significant problems appear to add an additional degree of'ndependence and lends credibility to findings.
A "hotline" program has recently been established for concerned site personnel to use when their own "in-house" management is not responsive to their problems.
The "hotline" provides a mechanism for quality problems to be brought before top Supply System management to be, resolved.
There has been strong emphasis from top management of the need for attention to a quality product.
This has. been particularly noticable during the last five months of the review period.
This has been reinforced by several memorandums and by the involvement of corporate level personnel.
Areas Where Im roved Performance is Warranted While the deintegration of project management from construction management and quality assurance is believed to be a strength, the changes were implemented prior to the necessary changes being made to the program plan, Also, the associated implementing procedures have lagged these changes unduly.
In the Supply Systems response to the 10 CFR 50.64(f) request for information, the utility committed to a lessons learned program.
Implementation of this program has been delayed and only recently has it begun to function effectively.
A special team audit (nine auditors for two weeks) was conducted by the utility at the WNP-1/4 site in January 1981.
This was conceived to be preparatory to a proposed NRC team inspection.
The audit appeared to be very thorough and uncovered many significant deficiencies requiring corrective action by the Project -and its contractors.
Based on the results of this one major audit, it appears that all sites could benefit from periodic audits of this type directed by utility management.
The Supply System was very responsive to supplying team members for task force assignments at WNP-2; however, there was a constant change of personnel and management for this effort.
This made it difficult to provide continuity to the review effort and has resulted in delays and the loss of identification of some weak areas that should be examined during the reverification effort.
While NRR only gave the Utility a rating of "below average" at one facility, all of the NRR Project Managers expressed concern with the timeliness of licensee responses to requests for technical information, believing that it took'longer than necessary to clear material through licensee management.
Com arison Between Reactor Sites All three sites deintegrated their organizations a little differently depending upon the particular needs of the facility and upon the strength
3.
of the architect-engineer and construction contractors.
Bechtel has assumed construction management and system turnover (completion in some instances)-at WNP-2 and only construction. management at WNP-1/4; while at WNP-3/5, Ebasco noh has complete responsibility for construction management as well as engineering.'n the surface, the changes appear to have been for the better.
The utility needs to evaluate the quality of 50;55('e) reports (construction deficiency reports).
The reports from'NP-3/5 aire quite comprehensive and seldom require contact with the licensees to'btain pertinent data needed to assess the deficiency and its generic implications.
The reports from the other two sites tend to be quite sketchy and generally require immediate followup by the NRC for additional information.
With the placement of a Project Director at each site, onsite equality Assurance no longer reports directly to the General Office.
IIle have not had sufficient time to. assess the full.impact of this change, but as yet,.we have not
.seen
-any Toss of objectivity or. freedom to identify quality problems of site quality assurance personnel.
Overall'Evaluation There are indications that the management reorganization initiated, in the past year and. the. subsequent contractual
- changes, such. as involving the Bechtel Power Corporation in construction management, 'will result in overall betterment in licensee performance.
This has had a partial detrimental effect on morale, resulting in lost production;
- however, it is not evident that this has adversely effected the quality of construction.
Total effectiveness'f the utilities management gA program continues to be suspect; The NRC's -inspection experience, as well as the utility's findings, continue.to show that the failure to adhere to procedures and failure to include'code and industry standard requirements, in the procedures are the predominant causes of items of noncompl'iance.
The util-ity has initiated a lessons learned program that should assist.the earl'y identification of common problems.
SUMMARY
OF WNP-2 SALP CYCLE 2 REVIEW II.
LICENSEE PERFORMANCE EVALUATION Facility:
Washington Nuclear Project No.'
Licensee:
Washington Public Power Supply System Unit Identification:
Docket No.
Licensee. No./Date 'of" Issuance
'Unit No.
50-397 Reactor Information:
CPPR-93/March 19, 1973 NSSS GE MWt Appraisal Period:
May 1, 1980 - June 30, 1981 Appraisal Completion Date:
August 18, 1981 1110 Mlle (net)
Review Board Members:
R.
T. Dodds,
- Chairman, Chief, reactor Projects Section 2, IE:RV D.
P. Haist, Project Inspector, IE:RV A. D. Toth, Senior Resident Inspector, IE:RV R.
C.
- Haynes, Deputy Director, IE:RV J.
D. Carlson, Reactor Inspector, IE: RV R. Auluck, Project Manager, NRR Overall Licensee Mana ement'Evaluation Based upon serious deficiencies in the sacrificial shield wall, pipe whip restraints, and other construction deficiencies identified in 1979 and early 1980 the NRC issued a notice of violation, a
$61,000 civil penalty, and a 10 CFR 50.54(f) inquiry on quality assurance to the licensee in June 1980.
During this same month a labor dispute effectively halted construction activity at the site.
In response to allegations regarding the prime mechanical contractor the NRC conducted an extensive investigation -in June and July 1980.
This investigation resulted in thirteen items of noncompliance and an Immediate Action Letter preventing further work by the contractor pending corrective actions.
Because of the notices of violations, the civil penalty, the 50'4(f) inquiry, and the construction halt the licensee redirected major management efforts from construction activities to addressing the NRC concerns.
This included developing programs to assure that future work will be properly controlled and that previously completed work conforms to requirements.
Mhile the labor dispute was settled in November 1980 the licensee did not permit safety-related site contractors to resume work until the licensee was assured that contractor quality controls were effective and resumption of work would not preclude rein'spection of previously completed work.
By the end of March 1981'most of the contractors were allowed to start work.
The majority of the NRC construction inspection effort during the appraisal period was dedicated to followup and verification of the licensee actions necessary to resume work following the construction halt.
Results of these inspections show that the licensee's-guality Assurance organization, with management support,.is providing additional emphasis to site orgariizations (including contractors) on the importance
'f quality assurance.
It appears, generally, that the equality Assurance organization has held contractors to a high standard ofreview during the restart efforts.
These reviews,'he design verification efforts, and the as-built documentation program have resulted in the identification of a large number of reportable deficiencies (51 reportable or potentially reportable 50.55(e) items).
NRC inspection, results have also identified weaknesses in licensee management
- planning, program, direction, and attention to the detailed. commitments made to the NRC.. This situtation has
- improved, somewhat, since early in the appraisal period, but many of the licensee corrective actions are not yet complete.
Concerns currently exist with regard to the licensee's ability to effect corrective actions, to properly control design
- changes, and to'ssure piping and supports meet quality requirements.
Sixteen specific items of noncompliance were identified during the appraisal period (thirteen from the investigation of the mechanical contractor and one each in the areas of quality assurance, structures, and piping).
The licensee's Test and Startup Program has been developed in accordance with the endorsed criteria of'egulatory Guide 1.68-Initial Test Programs for Mater Cooled Nuclear Power Plants.
In addition, the startup organization is considered to be adequately stafi'ed with qualified personnel.
Although little preoperational testing has been conducted to
- date, the licensee is considered to be ready in both the star tup and operations areas to, conduct an adequate test program.
NRR's experience with the licensee's performance in resolving and responding to NRC concerns has improved significantly in recent months.
However, for the majonity of the review period, responses were not timely and essentially nonexistant accept for responses to geo-science questions.
The Board has determined that there has been improvement in the licensee's project management
- team, management controls, and in the attitude of project personnel towards quality since the previ'ous appraisal period.
- However, due to the minimal amount of construction activity and the
incomplete status of some licensee corrective measures the NRC 'has not yet been able to conclude that these improvements are resulting in substantially better project performance.
HRC representatives have significant concerns with the licensee's performance in the areas of corrective actions, destgn
- changes, pi.ping and supports, and timeliness of responses to licensing inquiries.
Evaluation Criteria The various functional
- areas, and the licensee's overall performance.
were assigned a Category 1, 2, or 3 rating based upon the following evaluation criteria:
1.3 1
3PP" Pl
~ management attention and involvement are aggr essiye and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high. level of performance with respect to'opera-tional safety or construction'is being achi'eved.
- 2. 2<<1 h
ld3 Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are. adequate and are reasonably effective. such that satisfactory performance with respect to operational safety or construction is bei,ng achieved.
~C3.
hd dll
<<1 h
ld 1
d.
L>.censee, management attenti'on or involvement is acceptable and considers, nuclear safety, but weaknesses are eyident; licensee resources appear.to be strained or not effectively used such that minimally sati s factory per formance with respect to operational safety or construction is being achieved.
III. PERFORMANCE ANALYSIS Of FUNCTIONAL AREAS A.
Oualit Assurance l.
~Anal sis Licensee performance in the'area of quality assurance reflected strength on several areas as indicated below:
The quality assurance organization, with management
- support, has provided additional emphasis to site organizations (including contractors) on the importance of quality assurance.
It appears generally, that the quality assurance organization has held contractors to a high standard of review during tne restart efforts.
Licensee management has communicated the freedom to identify and document quality concerns to personnel.
WPPSS appears to be opening up channels of communication for employee concerns. as evidenced by a decrease in the number of allegations.
The equality Assurance Surveillance engineers have had good management support.
The licensee contracted with Bechtel Corporation for systems-completion services.
Incomplete segments of a contractor's work scope could be reassigned for completion under direct Bechtel management.
This provides a clear alternative for acting on unacceptable contractor performance.
The licensee abolished the integrated HPPSS/Burns-Roe management organization, replacing it with Bechtel Corporation as the construction manager.
The new construc-tion manager brought a mature quality assurance program for management of the contractors'he architect-engineer has assigned more engineering functions and perso'nnel'o the site, and opened an office in the nearby town of Richland.
This supported evaluations and disposit'ion of engineering questions relating to deficiencies found during reviews of detailed work methods and backlogs of nonconformance documents.
There were five items of noncompliance identified that directly related to this functional area, none of which would be considered to be classified as severity level IV or above.
One of the items dealt with the failure of the principal mechanical contractor to maintain organizational freedom of the quality assurance function from cost and schedule.'he others were primarily program documentation deficiencies.
Instances were identified where the audit organization has not been auditing against PSAR/FSAR commitments, e.g. contractor desiqn verification.
Other weaknesses iden'tified during the appraisal period are identified below:
0 l
) (
The principal mechanical contractor's. quality assurance organization has experienced significant management and, personnel changes.
These organizational changes and other transitional activities have had a
detrimental. effect on morale of the quality assurance organizations.
However, there is to date no basis for assessing whether or not'this has in turn adversely affected the quality of facility construction.
License action on the resolution of the large backlog of outstanding NRC open items was considered poor throughout the first half of the appraisal period.
These actions slightly improved with the assignment of a specific individual for followup of NRC items but in several cases the items were not adequately researched or ready for closure when examined by the NRC.
The continuity of this effort was adversely affected by, reassignment of the responsible, licensee individual midway through the effort.
This effort has again been reassigned, this time to Bechtel, which may further affect continuity.
2.
Conclusion Performance in this area is rated as Cat gory 2.
3.
Board Recommendation The Supply System and Bechtel guality Assurance Program should be audited as part of a special team inspection.
The status of all open items should be assessed and efforts expended towards expediting their closure.
B.
Substructures and'Foundations (including Containment) 1.
~Anal sis Mork in this area is essentially complete except for modification activity inside the dry well and wet well.
No items of non-compliance were identified in,this functional area.
The contractor's actions to re-evaluate his previously completed work represents a significant strength.
- However, a minimal amount of monitoy'ing of work was done by the licensee which appears to be a weakness in performance.
2.
Conclusions Performance in this area is pat d as Category 2.
3.
Board Comments Consideration sh'ould be given to reopening the routine inspection program to check modification work being done by the contractor, including documentation and engineering dispositioning of corrective actions.
C.
Safet Related Structures
~Anal sls Host of the activity in this area related to the examination of the sacrificial shield wall. for defective welds and the repair girth weld to join rings 3 and 4 of the shield wall.
Two items of noncompliance were identified in this functional
- area, neither of which would be considered to be classified as severity level IV or above.
The items related to failures to perform weld inspection in accordance with the procedure and failure to record a relevant magnetic partiqle indication during.
the preparation for the repair girth weld.
The licensee did not properly identify all accessible sacrificial shield wall welds.
NRC inspection of this activity disclosed that early shield wall inspections were performed without the full benefit of scaffolds or available inspection tools (e.g.
Licensee representatives reported that 1170 welds
--were accessible at that time and that 140 of these welds contained defects.
Following the NRC reviews subsequent licensee inspections concluded that at least 1497 were accessible and 179 of 'these contained defects.
This matter appears to show a lack of thoroughness in responding to the original NRC concern with shield wall adequacy.
Repair of these defective welds has not yet been undertaken nor has the repair of the concrete void areas discovered inside the shield wall.
2.
Conclusions 3.
Performance in this area is rated as Category 2.
Board Comments The inspection program should include followup of the repair of the sacrificial shield wall welds and concrete void areas.
D.
Pi in -and Han ers - Reactor Coolant and Other 1.
~Anal sis NRC investigation into allegations regarding the prime mechanical contractor resulted in thirteen items of noncompliance Five of these items specifically pertained to this functional area.
Following the investigation an, Immediate Action Letter (IAL) was sent to the licensee to allow the NRC to examine corrective measures before th'e contractor resumed work.
Another i tem of noncompliance relating to this area was identified during a routine NRC inspection.
In addition to the items of noncompliance other significant deficiencies have been identified. in the areas of design, documentation of as-built conditions, maintenance of minimum pipe wall thicknesses, and adequacy of sway brace assemblies.
Licensee and contractor reviews of contractor procedures and quality related documentation has resulted, in the identification of several 10 CFR 50.55(e) significant construction deficiencies (including the failure to properly lay up and protect the Low Pressure Core Spray and Standby Service Hater piping systems).
Not unti 1 Hay 1981 was Regional management" in a position to conclude that the licensee's reevaluation and corrective action plan for the prime mechanical contractor were in accordance with the commitments stated in the July 1980 reply to the NRC's 10 CFR 50.54(f) inquiry.
2.
Conclusion Performance in this area is rated as Category 3 ~
3.
Board Comments The routine inspection program should be continued.
The licensee's reverification effort should be closely monitored.
10 CFR 50.55{e) significant construction deficiencies and the as-built condition of systems in accordance with IE Bulletin 79-14 should be closely examined.
E.
Safet -Related Com onents (Includin HVAC 2.
~Anal sis Little construction work was done in this area during the r ev iew period.. There has been a subs tanti al improvement in the housekeeping around safety-related components.
The licensee has included the review of procurement of safety-related components as a reverification program requirement.
One item of noncompliance-was issued for failure to properly maintain storage conditions of safety-related components and incomplete implementation of maintenance procedures.
The licensee has found that the HVAC contractor/subcontractor have not provided calculations of HVAC instrument panel design and that the subcontractor did not have a gA program in effect while performing his work.
Conclusion 3.
Performance in this area is rated as Category: 2.
Board Comme'nts The NRC should followup on the reverification of procurement and the licensee's evaluation of the HVAC subcontractor's instrument panel design and other work.
F.
Electrical E ui ment Tra and Hire l.
~Anal sis There were no items of noncompliance identified in this area.
Limited inspection was performed in this area due to stop work condition in effect at the site.
A major area of concern involved the lack of proper definition of acceptance criteria for insuring electric'al independence of redundant safety related circuits.
The licensee's initial criteria was not acceptable to the NRC.
A revised criteria was submitted in June 1981 and appears to be acceptable.
>lith electrical cable installation 90K complete significant rework may be required to meet the new criteria.
Power Generation Control Complex cable separation and labeling criteria has not been included in the FSAR.
The licensee was unaware of this
- omission, but now plans to revise the FSAR in this area.
0
The licensee has reported significant construction deficiencies during the appraisal period in the area of electrical equipment, trays and wire.
These 50.55(e) reports include:
incorrect identification of electrical conduit, lack of documentation for 'Class IE cables in the main control room raceways, limitorque valve operators not meeting environmental qualifications, deficiencies in limitorque motor operator wiring interfaces, inadequate diesel generator air intake structure for tornado loads, inadequate friction clamps on conduit and tubing, and essential control room balance of plant panels designated nonessential.
2.
Conclusion Performance in this area is rated as Category. 2.
3.
Board Comments The NRC should continue with the routine inspection program with special emphasis on the implementation of the new separation criteria and followup on 10 CFR 50.55(e}
reportabl e defici enci es.
G.
Instrumentation 2.
~Anal sis The licensee has improved the previously deficient program of equipment protection, and has demonstrated aggressiveness in working with the NRC inspectors and resolving identified problems.
'he,NRC inspections of'his contractor identified no significant deficiencies during this appraisal
- period, nor were there significant events or major problems identified by the licensee.
Conclusion 3.
Performance in this area is rated as Category 2.
Board Comments The NRC should continue with the routine inspection program in this area.
H.
Fire Protection No inspection activity was performed in this functional area during the current appraisal period.
I.
Preservice Ins ection l.
~Anal sis Inspection activity in this area was limited to observations and review of pipe wall thickness measurement.
No deficiencies w'ere identified.
No significant deficiencies were reported by the licensee during the current appraisal period for this functional area.
2.
Conclusion Performance in this area is rated as Categqry 2.
3.
Board Comments The NRC should continue with the routine inspection proqram in this area.
J.
Corrective Actions and Re or'tin 1.
~Anal sis The NRC enforcement actions in June and July 1980 caused the licensee to initiate intensive efforts to assure that future work is properly controlled and that previously completed work conforms to requirements.
The majority of the flRC inspection activity for the current appraisal period focused on these licensee corrective actions.
Licensee performance in the area of corrective action refected strength.in several areas as indicated below:
The licensee has established performance standards and variance reports to highlight adverse trends to management, and has improved procedures for reporting significant items to the NRC.
A rigorous commitment control program has been initiated with particular attention to NRC items.
10
The licensee has also closely involved engineering resources in the evaluation and disposition of identified deficiencies, including increased sensitivity to generic implications of identified problems.
Corporate reorganizations and the assignment of a separate construction management contractor have increased management resources and responsiveness at the site.
The licensee and contractor site management have achieved a high degree of awareness of specific and programmatic functioning of the quality assurance
- programs, management interfaces, and past problems areas.
Large numbers of licensee and contractor staff members have become knowledgeable of past deficiencies, through training and review work assignments.
Site contractors have taken steps to review records, perform some reinspections, 'identify problems, and define corrective actions.
A site-wide quality awareness has been achieved.
It should be noted that significant improvements have been made in the work specifications and contractor work procedures, which now incorporate applicable
- codes, standards, and regulatory requirements.
However, additional work in this area may be required to ensure the workability of procedures.
Ouring the appraisal period one item of noncompliance was issued in the specific area of corrective action and reporting.
This involved the failure to report a
significant construction deficiency as required by 10 CFR 50.55(e).
While improvements have been made in this area, the NRC is concerned that.not all problem reporting systems are being evaluated for 50.55(e) reportability (e.g., start-up problem reports).
The reports are generally very brief and typically require additional investigation by the NRC to enable NRC closeout.
Other weaknesses identified during the appraisal are identified below:
Until very recently, the licensee has allowed 50.55(e) items and NRC open items to accumulate without an effective followup or tracking system.
Interfaces with contractor personnel are often poor or unknown resulting in reduced inspection efficiency.
The licensee has addressed the problem of backlogs and some progress has been made.
Bechtel has now assumed responsibility for followup of NRC items.
In response to the NRC's 50.55(f) inquiry the licensee identified an agressive program for achieving overall corrective actions.
The original program called for three task forces to reduce backlogs of unresolved problems, establish performance standards, sample review documentation and inspect
- hardware, review and upgrade contractor work methods, and use lessons learned to upgrade on-site management systems and systems of other l/PPSS sites.
The program initially suffered setbacks from insufficient planning, insufficient management direction, and insufficient" attention to details.
In some cases the results of the licensee's restart'procedure review efforts did not meet the objectives of the effort.
For example, the mechanical contractor deemed the resul'tant procedures as unworkable and unsuitable for training personnel, the training program as overly burdensome, and the "base-line clean work package" principle as unworkable for partially complete work.
For the fir'st work restart, the contractor's procedures'roved defective, and implementation and training deficiencies were encountered.
The results of the other related licensee efforts were in some cases unacceptable to NRC.
Requested weld defect data and some responses to NRC Items of Non-compliance were found.to be incomplete and inaccurate.
The licensee's planned implementation of Regulatory Guide 1.58, 10 CFR 21, and 10 CFR 50.55(e) were unacceptable.
The licensee's task force approach was not initially integrated into the project organization nor the quality assurance
- program, and its interfaces with the rest of the project were not defined in appropriate procedures until this issue was raised by the NRC.
The task forces were eventually absorbed into the project organization.
12
1
2.
Conclusion Performance in this area is rated as Category 3.
3.
Board Comments Additional inspection effort above and beyond the routine inspection program is warrented in. this functional area.
Specific attention should be provided in the following areas:
The licensee has not yet commenced re-inspection of completed work.
The integrity of these reviews should be closely monitored by NRC.
Sample size selection, credit for prior reviews by contractors, thoroughness of document review and re-inspection checklists, and the minimization of acceptance criteria are typical issues.
The use of a construction completion contractor establishes new interfaces.
The turnover of systems to Bechtel for completion, and associated resolution of backlogs of nonconformances, appear to be unusual 'activities, and have not been examined by the NRC.
Essentially all contractors have new work methods.
It may be desirable to re-open portions 'of MC-2512 inspection modules regarding procedure and quality assurance program reviews.
This is particularily true for the prime mechanical contractor who has expressed concern regarding the workability of the new procedures.
The licensee has overlooked commitments made to the
- NRC, and has in several cases modified approaches and planned actions described to the NRC to the 10 CFR 50.54(f) letter and subsequent reports to the NRC.
It appears desirable to closely monitor deviations from such commitments.
Attention should be given to working off the large backlog of open-items, including followup of 50.55(e) items.
K.
Procurement 1.
~Anal sis There was one item of noncompliance regarding maintenance of vendor survey files (80-08-02), which was typical of deficiencies in the mechanical contractor vendor surveillance system.
The specific issue has been resolved, and action plans developed for 13
the contractors to revise procedures and review procurement
- records, including prerequisite and hold point actions for release of materials.
Due to limited ipspection in'his area the NRC has not completed an assessment of the effectiveness of the new site-wide controls'.
The licensee reassessment program will address previous procurements.
2.
Conclusion Performance in this area is rated as Category 2.
3.
Board Comments Perform routine inspections of procurement activities and perform followup inspections on the effectiveness of the reverification program.
1.
~Anal sis Licensee performance in this functional area has exhibited weaknesses as identi fied bel ow:
It is not apparent that Architect/Engineer has been performing a systematic, planned and documented design verification effort.
Examples of failure to verify design are appearing in 50.55(e) significant construction deficiencies reports and startup problem reports.
This area is still under review by the Region.
It is not apparent that contractors performing design activities have been performing design verification.
The applicable ANSI standard requirements (N45.2.11) have not been imposed on the site contractors, with the exception of Gilbert-Commonwealth.
The principal mechanical contractor was found not to be performing design verification of large bore piping and support designs by Nuclear Power Services.
This task has now been assigned to Burns
& Roe, Inc.
The design verification of smallbore piping and support designs is now being performed by Gilbert-Commonwealth.
The HVAC contractor imposed no design control requirements on its subcontractor for.HVAC instrument panel design.
One item of'oncompliance was issued for failure to provide calculations to support deletion or redesign of support wel ds.
14
One item of noncompliance was issued for failure to update drawings in accordance with procedures.
Load capacities exceeding design stress allowables were discovered on standard support details for small diameter pipe issued to Gilbert-Commonwealth by Burns Roe, Inc.
Conclusions Performance in this area is rated as Category 3:
3.
Board Comments The NRC inspection efforts should address special attention toward the qualification of the Architect/Engineer staff since many new personnel have been a'ssigned to the organization.
NRC RIV assistance should be obtained for audits of the Burns 8
Roe organ'ization and others with design responsibilities (e.g.
Gilbert-Commonwealth).
Site contractors with design responsibilities should be examined to insure appropriate controls are in place.
M.
~TnalnIn l.
~Ana'I sis The licensee has taken project-wide steps to upgrade the contractors'ersonnel qualifications,'ertification, and training programs.
>Ji th maj or. revisions of contractors 'nd Burns 5 Roe and licensee procedures, steps have been taken to indoctrinate and re-train personnel to revised requirements.
The new construction
- manager, Bechtel, brought its corporate training policies and instituted detailed training of Bechtel quality control personnel during transition periods.
Some -weakness was identified in the implementation of licensee's program:
The licensee di'd not prescribe training program details for the site, and the mechanical contractor elected to establish comparatively severe requirements which were later found not to be achievable.
The mechanical contractor experienced problems that were attributed directly to inadequate
- training, and qualifications of personnel were insufficient or inadequately verified.
Contractor management has recognized this situation and corrective steps have been initiated.
15
The architect-engineer failed to conduct training of weld engineers to most recent procedures governing design changes for the first restart work.
For the entire site, the high rate of personnel
- turnover, and the significant revisions, to the established work procedures, have undermined the effectiveness of the increased training efforts.
2.
Conclusion Performance in this area. is rated as Category 2.
3.
Board Comments The region should continue to examine this area to,assure that the large scale training effort achieves the desired results.
N.
Plant 0 erations l.
~Anal sis The Region considers plant procedure, preparation guidelines and the general employee training program to be adequately described in the administrative procedures.
Implementation of these requirements could not be examined due to a lack of activity.
No i tems of noncompliance or deviations were identified.
2.
Conclusion Performance in this area is
. qted as Category 2.
3.
Board Comments Continue with the routine inspection program for this functional area.
0.
Fuel Loadin Pre aration This area was not inspection during the current appraisal period.
16
P.
Maintenance l.
~Anal sis The licensee's operat'ional plant maintenance training program was found to be excellent.
Observation of maintenance activities indicate that the licensee has established an effective quality assurance/quality control program for these types of activities.
One item of noncompliance was issued regarding the maintenance of systems under construction.
This item was discussed in paragraph E (Safety-Related Components).
2.
Conclusion Performance in this area is rated as Category lI'".
3.
Board Comments Continue with the routine inspection program for this functional area.
Securit and Safe uards This area was not inspected during the current approved period.
R.
Surveillance and'Preo erational'estin 1.
~Anal sis Inspection effort in this area previously related to review of (1) test and startup organization,'(2) preoperational test procedures, and (3) component and system flushing program.
Very little physical work was performed by the licensee, with most of the activity being programatic in nature.
No items of noncompliance or deviations were identified.
2.
Conclusion Performance in this area is rated as Category 1.
3.
Board Comments Continue with the routine inspection program in this functional area.
17
S.
Emer enc Plannin This area was not inspected during the current appraisal period.
T.
Audits, Reviews and Committee Activities 0 erations l.
~Anal sis The offsite and onsite quality assurance audits were being conducted as required, and the onsite quality assurance organization was performing surveillances of plant operations and preoperational testing activities.
Test Working Group (TWG) has been performing in accordance with its charter in the test and Startup Program Manual.
No items of noncompliance or deviations were identified.
The quality assurance supervisor has been in an acting capacity for a long time; consequently, this area lacks the solidification necessary to provide stability prior to implementation of the program for pre-operational testing.
2.
Conclusions Performance in this area is rated as Category 2.
3.
Board Comments Continue the routine inspection program.
It would be desirable to reopen quality assurance for preoperational testing due to substantial revision of the Operational equality Assurance Manual.
18
0
IV.
SUPPORTING DATA AND SUMMARIES A.
Noncom liance Data Noncompliance Category or Severi t Level
'iolation Infrac tion Deficiency Level IIIIII IV V
YI
'Number 0
8 5
0 0
0 0
3 0
To tal 16 I
See Attachment IV-3 for additional noncompliance data.
B.
See Enclosure (1) for list of noncompliances.
See Enclosure (2) for enforcement history data.
~RD 1.
LER Nos.
Reviewed - N/A
'E 2.
Construction Deficiency Re orts (Reactors under Construction)
The extensive licensee and contractor efforts to re-evaluate and improve detailed work methods has resulted jn fifty-one potentially reportable construction deficiencies as they are defined in NRC guidance on 10 CFR 50.55(e) construction deficiency reporting dated Ppril 1, 1980.
Of these fifty-one potentially reportable
- items, e]even have been determined by the licensee not to be reportable and twenty-five are still under evaluation.
Enclosure (3) is a listing of all reported potential 50.55(e) items.
Six reportable deficienci'es were examined during this appraisal period.
(Gaps and'voids in sacrificial shield wall reported June 23, 1980; Borg Warner valves with limitorque operators reported July 24, 1980; Defective sway brace brackets reported August 20, 1980; Non-Seismic DEH cabinet reported November 14, 1980; Diesel generator swi tchgear reported November 14, 1980',
and Defective main steam tunnel support beams reported November 17, 1980).
Actions taken by the licensee on these specific deficiencies were adequate.
"19
One item of noncompliance was issued (Report No. 80-16) for failure to report a 10 CFR 50.55(e) construction deficiency involving the effect of rigid conduit versus flexible conduit on the seismic analysis of switchgear.
C.
Licensee Activities On June 2, 1980, a labor dispute disrupted site construction activities with the exception of maintenance, quality control inspection, and ouality assurance documentation review.
The labor dispute was settled in early November and site contractors resumed some work on items not subject to quality assurance program requirements..
On June 17,
- 1980, NRC issued a
10 CFR 50.54(f) inouiry on quality assurance, simultaneous with a notice of violation and civil penalty (see paragraph F below).
On July 17, 1980, the licensee responded by halting work by the prime mechanical contractor.
The licensee also stopped work by all site contractors pending an evaluation of their detailed work methods to assure that there would be no quality problems.
The following nine months were spent on the planning, mobilization, and operation of three task forces to implement the corrective actions outlined in the response to the 50.54(f) inquiry and notice of violation.
Another major licensee activity has been the addition of a circumferential girth weld at the 541 foot elevation of the sacrificial shield wall.
NRC concurrence with the start of work on this weld was given in January, 1981 following NRC review of task force *II review results relating to the readiness of the mechanical contractor to perform safety-related work.
The weld has now been completed.
Following the appointment of Mr. R. L. Ferguson as Managing Director in June, 1980, substantial Supply System and
'l(NP-2 organizational changes-w'ere announced.
These changes include the establishment of a site-based Program Director for WNP-2 who is responsible for the construction, startup, and initial power generation of the facility.
Other actions included a
change in the reporting relationship of the WNP-2 Project Quality Assurance Manager fr'om the. Corporate Quality Assurance Director to the WNP-2 Program Director and the establishment of a new Corporate Directorate of Nuclear Safety.
In March, 1981, it was announced that Bechtel Power Corporation would assume the function of Construction
- Manager, including equality Assurance, effective'une 1, 1981.
The integrated WPPSS/Burns and Roe, Inc. organi zation has been abolished with Burns and Roe retaining the function of architect-engineer.
The licensee is now performing quality assurance overview.
Bechtel is also functioning as systems completion contractor and will perform the reverification of completed safety-related work.
20
D.
Ins ection Activities Routine regional and resident inspection programs were essentially suspended throughout the assessment period.
The total 2952 manhours of inspection effort includes 1908 manhours regional-based inspection aqd 1044 manhours of resident inspection.
The regional-based inspection included 782 manhours for, a special team investigation of allegati'ons relating to work per formed by the principal mechanical contractor.
gn June 23, 1980, the resident inspector at WNP-1/4 was reassigned to the hlNP-2 project to examine licensee and contractor efforts to re-evaluate and improve detailed work methods and to verify compliance to commitments made in response to a 10 CFR 50.54(f) inquiry regarding qual i ty assuran'ce.
Regional-based construction inspection activity was reactive in nature and consisted of supporting the residen't inspector's review of licensee evaluation of individual contractor's work methods, verifying adequate maintenance of equipment during the work stoppage, examination, of sacrificial shield wall girth weld, examination of the ma'y '10 CFP, 50.55(e) constructiqn deficiencies, and examination of corrective actions resulting from the team investigation of the mechanical contractor.
The preoperational inspection program activity was minimal since there has been very little preoperational testing to date.
Il Investigations 'nd'Al 1 e
' ti'on'eview The major investigative activi'ty during this period involved
- allegations of material traceability discrepancies, quality record irregularities, and discrepancies related to corrective action specification" and implementation by the prime mechanical contractor.
The investigation conducted between June 3 and July 25, 1980, involved 782 inspection
- manhours, and was focused on the following generic areas:
(1)
OA/gC Program Administrati'on (2)
Procedures and Procedure Implementqtion (3) guali ty Program Implementation - Hardware (elated (4)
Minimum Pipe Weld Thickness (5)
Material Traceabili ty and gaterial Control (6)
Design of As-Built Supports (7)
Cleanliness and Hydrostatic Testing (8)
Allegations Related to Other Activities (9)
Documentation Of the nine generic areas investigated and inspected, twelve i tems of noncompliance were identified primarily in the areas of work activi ty management, adherence to procedures, and documentation programs.
21
F.
Escalated Enforcement Actions 1.
Civil Penalties As a result of serious deficiencies in the sacrificial shield wall, pipe whip restraints, and other construction activities's detailed in the May 7, 1980 appraisal, a $61,000 civil penalty was assessed on June 17, 1980 accompanied by a 10 CFR 50.54(f) request for information on the steps to be taken to provide reasonable assurance that the approved quali ty assurance program has been implemented and steps to be, taken to strengthen management control of the project..
The licensee responded with detailed plans to accomplish this work in essentially three phases, later described as Tasks I, II, and III.
Resident and Regional inspectors continue to monitor licensee progress on these commitments.
The efforts to fulfill these commitments have constituted the bulk of licensee work activities during this appraisal period.
2.
"Orders None 3.
"Confirmation'of'Action Letters One Immediate Action Letter was issued on Ju)y 18,
- 1980, as a result of the investigation discussed in item E. above confirming that the licensee had directed the prime mechanical contractor to stop installation activities pending the licensee's.re-evaluation of detailed work methods, controls and standards of performance.
The order remained in effect until May 31, 1981 when the NRC was able,to conclude the licensee's re-evaluations and corrective action plan would provide requisite quality for the project.
G. 'anaqement Conferences Held'Durin A
raisal Period A management meeting was held at the request of HPPSS Senior Management at the NRC Region P office on October 21, 1980.
Qt this meeting, the licensee presented the main features of the revised management system developed by the mechanical contractor and the key interfacing Project Management Systems.
The licensee's Restart Program Plan was also outlined at this meeting.
22
ATTACHMENT IV-3 Functional Area
'III IIIIV Y
YI Vio.
Inf.
Def.
Dev.
NUMBER AND NATURE OF NONCOMPLIANCE ITEMS - CONSTRUCTION REACTORS Inspection.
Noncompliances ft
'5
i
'L
Classification*
l.
Ouali ty assurance 187 2
2 2.
Substructure founda tions, concrete
& liner (containment others) 3.
Safety-rel a ted structures (incl.
welding) 4.
Piping
& hangers--
reactor coolant others--(incl.
welding)
'15
'64 5.
Safety-rel a ted components (vessel, internals,
& HVAC)
63" 6.
El ectrical equipment, tray
& wire 7.
Ins trumenta tion 8.
Fire Protection 9.
Preservice inspection 10.
Corrective actions repot ting 11.
Procurement 12.
Design changes 13.
Training
""65'1' 10' 2247
'10 QO'Complete this column for noncompliances issued under the old categorization.
23
If the facility is in the preoperational test phase, also include:
Functional Area 14.
Plant Operations 15.
Fuel loading preparation 16.
Maintenance Inspection
'Manhours
'38"
42 Noncompliances
~Si .l
'1 ifI
'II III IY 'V'I'
'Vio.'nf.
Def.
Dev.
17.
Security 8
safeguards 18.
Surveillance 8
preoperational testing 19.
Emergency planning 20.
Audits, reviews, 5
committee activities TOTALS
'2'
'16 2952 4
3 8
5 24'
UNIT LJNP-2 ENFORCEMENT ACTIONS DURING PERIOD OF INTEREST PERIOD May 1, 1980 - June 30, 1981 25 ITEM OIL NUMBER TYPE OR SEVERITY REPORT DATE
RESPONSE
LTR.
DATE NO./
REPLY REPORT ADE UATE CLOSED DESCRIPTION 80-08/01 2
80-08/02 3
80-08/07.
4 80-08/09 5
80-08/1 1 6
80-08/16 7
80-08/22 8
80-08/40 8-15-80 8-15-80 8-15-80 8-15-80 8-15-80 8-15-80 8-15-80 8-15-80 G02-80-209 9-19-80 G02-81-54 3-10-81 G02-80-209 9-19-80 G02-81-54 3-10-81 602-80-209 9-19-80 G02-81-54 3-10-81 G02-80-209 9-19-8Q 6(}2-81-54 3-10-81 G02-80-209 9-19-80 G02-81-54 3-10-81 G02-80-209 9,-19-8Q G02-81-54 3-10-81 G02-80-209 9-19-80 G02-81-54 3-10-81 G02-80-209 9-19-80 G02-81-54 3-10-81 Yes Yes Yes Yes Yes Yes Yes Yes Failure to maintain organizational freedom of the quality assurance function from cost.and schedule Failure to maintain a survey document of a vendor-failure to document inspection findings relative to incorrect amperage settings for MT probes Failure to maintain records for temporary wel d attachments Piping support clearance in excess of requirements Failure to use filler metal specified in procedure Incorrect acceptance standards used to evaluate results of liquid penetrant examinations Failure to comply with procedure revision requirements Enclosure (1)
Page 1 of 2
UNIT LJHP-2 ENFORCEMENT ACTIONS DURING PERIOD OF INTEREST
. 26 PERIOD May 1, 1980 June 30, 1'981 ITEM OIL NUMBER TYPE OR REPORT DATE SEVERITY
RESPONSE
LTR.
DATE NO./
REPLY REPORT ADE UATE CLOSED DESCRI P TION 9
80-08/29 10 80-08/36 11 80-08/37 12 80-08/38 13 80-16/07 14 81-03/01 15 81-03/03 16 81;05/05 8-15-80 8-15-80 8-15-80 8-15-80 11-4-80 5-7-81 5-7-81 4-24-81 G02-80-209 9-19-80 G02-81-54 3-10-81
$02-80-209 9-]9-80 G02-81-54 3-10-81 G02-80-209 9-19-80 G02-81-54 3-10-81 G02-80-209 9-19-80 G02-81-54 3-10-81 G02-80-269 11-26 G02-81-122 5-28-81 G02-81-122 5-28-81 G02-81-109 5-19-81 Yes Yes Yes Yes Yes Yes Yes Yes 81-03 Calculations not provided to support deletion or redesign of support welds Failure to provide a procedure and/or checklist for documer review of work packages Failure of gA Manager to review records of rework performed after document package acceptance revie~
Failure to perform weld inspection as required by procedure Failure to promptly report 10 CFR 50.55(e) construction deficiency Failure to update drawinqs in accordance with procedures Lack of control of storage conditions and incomplete implementation of maintenance procedures Failure to record magnetic particle indication Enclosure (1)
Page 2 of 2
27 ENFORCEMENT HISTORY WNP-2 SALP Period 4/79 - 4/80 5/80 - 6/81 Insnection Hours 1068 2952 Number of Items of Noncom liance 29 16 Inspection Hours
'Hours of Noncom liance 32 184 Enclosure (2)
Page 1 of 1
50.55(e) 1980 1JNP-2 EoclPre (3)
Page 1 of 5 ITEM DESCRIPTION ISSUE
RESPONSE
RESPONSE NOTIFIED RE/.
DATE RECEIVED
' 'ATE RESP.
LTR.
REPORT NO./DATE CLOSED 6-23-80 Gaps and voids in sacrificial 6-23-80 shield wall 7-23-80 7-25-80 G02-80-161 7-23-80 7-24-80 Borg-Warner values with 1 imitorque operators 7-24-80 8-24-80 8-25-80 G02-80-184 81-09
'-20-80 7-24-80 Failur e of battery charger 7-24-80 capacitors 8-24-'80 '-21-80, G02-80-185 81-12 8-21-80 Not Reportable 8-12-80 Large bore piping with less 8-12-80 than required minimum wall thickness 9-12-80 9-18-80 G02-80-202 9-16-80 8-20-80 6-10-81 Sway brace brackets HS-142 by 8-20-80 power piping with poor weldments General Item Date - Sheet 9--t9-80 Issued General Item Date - Sheet Issued 9-20-80 9-22-80 Interim 2-9-81 Interim 6-5-81 Final G02-80-208 9-19-80 G02-81 -19 2-5-81 G02-81-124 6-1-81 80-17 81-12 8-22-80 Incorrect Identification of Electrical Conduit 8-22-80 9-22-80 9-29-80 G02-80-213 9-26-80 8-27-80 Primary Containment Pressure 8-27-80, moni tori ng i ns trument sens ing line routing 9-27-80 9-29;80 G02-80-211 9-24-80 9-5-80 Lack of installation docu-9-5-80, mentation for class IE cables in main control room raceways 10-5-80 9-29.-80 G02-80-213 9-26-80 10-3-80 Limitorque valve operators cannot meet envir. qual.
requirements of IEE-382 Generic Issue Data Sheet 1 1-14-8A tJestinghouse DEH cabinet located adjacent to GE control room benchboard 11-14-8B Diesel Gen.
Switchgear DG-1-7 and DG-2-8 located closer together than designed 10-3-80 11-3-80 12-29-80 11-14-80 12-15-80 11-'14-'80 12-15-80.
12-22-80 Interim G02-80-289
]2-15-80 12- ] 5-80, G0,2-80-282 12-10-80.
11-3-80 602-80-237 10-30-80 6-26-81 G02-81-0158 Final Peport 81-12 81-12 28
losure (3)
Page 2 of 5 50. 55 ( e )
1980 llNP-2 ITEM DESCRIPTION ISSUE
RESPONSE
RESPONSE NOTIFIED REQ.
DATE RECEIVED "DATE RESP..LTR.
NO./DATE REPORT CLOSED 11-14-8C Concrete and Concrete Grouting (Potential) Contract 215 11-14-80 Special doors and hatches by (Potential)Ray Proof Inc.
11-14-8E Spray pond piping supports (Potential)developed using wrong. seismic load data ll-14-8F Torque wrenches out of (Po tenti al )Ca 1 ibration 11-14-80 Contract 213A gA program (Potential)Breakdown 11-17-8G Bolting not meeting AISC (Potential )Requirements-Control Room Ceiling 11-17-8H Design verification of gC-1 (Potential)HVAC hangers not properly accomplished 11-17-81 IEEE qualification (Potential)Rosemount transmitters 11-17-8J Main steam tunnel support (Potential)beams See Item 80-08/13 11-14-80 12-15-80 11-14-80 12-15-80 11-14-80 12-15-80 11-'14-80 15.-80 11-14-80 12-'15-80 11-14-'80 12-15.-80 11-14-80 12-,15-80
.11-14-80 12-15-80 Not Reportable 11-14-80 '2-15-80 12-22-80 Interim 12-22-80 interim 6-15'-81 Interim 12-22-80 Interim 2-26-81 Final 12-22-80 Interim 12-22-80 interim 5-20.-81 final 12-22-80 Interim Final 12.-22-80
'Interior 3-16'-81 Interim 12-22-80 Interim Final 2-9-81 12-22-80 Interim 4-1-81 final G02-80-302 12-15-80 G02-80-292 12-15-80 G02 F0135 6-10-81 G02-80-290 12-15-80 G02-81-30 2-23-81 602-80-295 12-15-80 G02-80-299 12-15-80, G02-81-98 5-15-81 G02-80;297 12-15-80 G02-81-05 1-8-81 G02-80-293
.]2-15-80 G02-81-52 3-10-81 G02-80-298 12-15-80.
G02-81-22 2-5-81 G02-80;296 12-15-80 G02-81-66 3-27-81 81-12 81-10 81-12 ll-17-8K Air operated valves with (Potential)improper unit switches 11-14-80 12-15-80 12-11-80 Not Reportab)e 81-12 29
- 50. 55(e) 1980 MNP-2 losure (3)
Page 3 of 5 ITEM DESCRIPTION ISSUE/
RESPONSE
NOTIFIED REQ.
DATE DATE
RESPONSE
RECEIYED RESP.
LTR.
NO./DATE REPORT CLOSED ll-17-8L Non-documented repairs-(Potential)contract 215 11-14-80 12-15-80 12-22-80 G02-80-300 Interim 12-15-80 5-22-81
'02-81-106 Not Reportable 5-18-81 ll-17-8M HPCS and LPCS pipe spool (Potential) 11-14-80 12-15-80 11-17-SN Procurement of safety-related 11-14-80 12-15-80 (Potential)equipment to less than IEEE 323 requirements 12-22-80 Interim 12-22-80 Interim G02-80-294 12-15-80 G02-80-291 12-15-80 11-17-80 NF supports - possible non-(Potential)conformance with NF 3691 one sided clamp loading 4
E 11-14-80 12-15-80 12-22-80 Interim 2-9-81 Final G02-80-301 12-15-80 G02-81-20 2-5-81 12-8-80 Limitorque wiring interface 12-8-80 1-7-81 (Potential )probl ems 1-12-81 Inter im 3-27-81 Final G02-81-04 1-7-81 G02-8] -61 3-20-81 12-22-8A Effect of annulus pressuri-(Potential)zation on piping systems 1-29-81 Interim 6-1-81 Interim 12-22-80 1-21-81 Final report to NRR under questi G02-81 -13 1-22-81 602-81-119 5-'6-81 on 110.019 12-22-8B Lack of procedure for (Potential)cleanliness requirements following hydrotest-inadequate layup after hydrotest 12-22-80 1-21-81 1-26-81 Interim G02-81-15 1-23-81 12-22-8C Cathodic protection attached 12-22-80 1-21-81 (Potential)to ASME Class 3 pipe with thermite process Not Reportable Interim 5-22-81 Final G02-81-14 1-22-81 G02-81-112 5-20-81 12-30-80 Design tor pipe whip supports 12-30-80 inside containment 1-29-81 2-2-81 Interim G02-Si-iS 1-29-81 2-9-8A Relay interference condition 2-9-81 (Potential)in suppression circuitry of Class 2 portion of supervisory system 3-11-81 3-9-81 N/A Not Reportable 30
50.55(e) 1980 WNP-2 Encure (3)
Page 4 of 5 ITEM DESCRIPTION ISSUE/
RESPONSE
RESPONSE RESP.
LTR.
REPORT NOTIFIED.
REQ.
DATE RECEIVED NO./DATE CLOSED DATE
2-9-8B Contract 218-failure to (Potential )incorporate 10 CFR 21 into subcontracts 2-9-81 3-11-81 3-9-81 N/A Not Reportable 2-9-8C
'60 GPH leak in spray (Potential) pond 'A'-9-81 3-11-81 3-9-81 Interim
- 6-15-81 Interim G02-81-51 3-5-81 902-81-138 6-10.-81 2-24-81 Incorrect all owabl e wel d 2-24-81 (Potential)stress values used in. small bore pipe design verification 3-26-81 3-23-81 tIot Reportable 3-5-81 Diesel Generator air intake
( Potential) ductwork possible collapse under tornado load and loss of offsite power 3-9-8A Contract 215-Failur'e to comply (Potential)with temporary installation program 3-5-81 3-9-81 4-4-81 Il 4-8-81 4-10.-81 G02-.81-72 Interim 4-7-81 6-1-.81 C>02-81-120 Not 5-27-81 Peportable 3-9-8B Possible localized over-(Potential)stressing cond'ition on piping which bears on flat plate 3-9-81 4-8-81 4-17-81 G02;81-76 Interim 4-13-81 Final 6-26-81 3-9-8C Possible installation of (Potential)defective pipe 3-9,-81 8-81 4-27-81 Interim G02-81-82 4-21-81 3-19-81 Fillet welds used on shear (Potential) lugs by contract 220 3-20-81 Questionable soil testing (Potential) data 3-19-81 4-18-81 3-.20-81 4-19-81 4-16.-81 Not Reportable 4-24-81 G02-81-83 Interim
'-22-81 3-27-81 EDR pipe supports with smaller 2-27-81
( Potential) than cope requied weld sizes 3-29-81 3-20-81 Not Reportable 4-16-81 G/C-load capaci ties exceed (Potential)allowable design conditions established as standard design details 4-20-81 Engineering unable to verify (Potential)adequacy of friction clamping devices for conduit and instrument tubing 4-16-81 4-20-81" 5-16-81 5-19-81 5.-22-81 G02-81-111 Interim 5-19-81 G02-81-140 6-12-81 31'
k a
~
50.55(e) 1980 l<NP-2 En+Ure (3)
Page 5 of 5 ITEM DESCRIPTION ISSUE/
RESPONSE
RESPONSE RESP.
LTR.
REPORT NOTIFIED REQ.
DATE RECEIVED NO./DATF.
CLOSED
'DATE'-20-81 Essential BOP control (Potential )room panels designated nonessential by GE on NPC 5-20-81 6-26-81 P
G02-81-148 Interim 6-20-81 5-28-81 Failure of rigid sway brace 5-28-81 (Potential)clevis drilled for lube fitting 6-28-81 6-12-8A Possible defect in HPCS (Potential)diesel air start system 6-12-8B 215 procedures for QC-I coating appl icati ons di d not meet ANSI N101.4 6-12-8C Part 21 from GE of CR 2940 control switches 6-12-81 7-12-81 6-12-81 7-12-81 6-12-81 7-] 2'-81 6-23-81 Stiffening of base plates may 6-23-'81 (Potential)affect concrete anchors 7-23-81 6-29-81 Hanger engineering drawing (Potenti al ) Documentati on 6-30-81 Mfg. catalog data on PSME (Potential)Sec. III Class 1 not conservative 6-29-81 7-29-81 Interim G02-81-159 6-26-81 6-30'-81 7-30-81 32
VI.
NRR PERFORMANCE EVALUATION
~Faci 1 it:
WNP 2 R. Auluck A
raisal Period:
July 1, 1980 to.June 30, 1981 A.
Performance Elements 1.
ualit of res onses'and submittals:
The quality of responses and submittals by the applicant was found acceptable.
- 2. Efforts re uired to obtain an acce table res onse or submittal
~includin:
a.
Timeliness:
As a result of our continuing review of the WNP-2 FSAR, we.have asked the applicant over 20 sets of "Request for Additional Information" since October 1980.
So far the applicant has responded to very few of these requests.
b.
Effort:
Effort in preparing these responses was found to be acceptable.
C.
d.
Res onsiveness to'staff're uests:
The applicant is quite responsive to our requests.
Antici ates'or reacts'to NRC needs:
In most cases, the applicant reacts to our needs.
3.
'Morkin knowled e of re ulations, uides standards and eneric 1ssues:
The applicant and the contractors have fairly good knowledge of the regulations and the standards.
4.
Technical com etence:
Technical competence is considered good.
5.
Conduct'of meetin s at'NRR:
The applicant is usually well prepared for the meetings with NRR.
33
6.
Lon -standin o en items:
Applicant is quite slow in closing long-standing open items.
This has been especially true in the area of load definition methodologies (SRV load methodology, chugging load methodology and condensation oscillation load methodoloqy).
7.
Or anization and mana ement:
During most of this review period, it appears insufficient management attention was given to licensing inquiries.
This resulted in delays in responding to NRC requests (see item l.b(l) and l.f).
8.
N.A.
9.
See item l.f.
B.
Observed trends in erformance:
WPPSS management has been completely reorganized since June 1980.
It appears that they have more control over the project now and are giving WNP-2, an adequate level of management attention.
As a result, a fair amount of. progress has been made recently in the licensing process.
C.
Notable Stren ths and Weakness:
~Sh: Thy'ill dth i
f 11k geoscientists and consultants to resolve open issues in the geosciences area.
2.
Weaknesses:
They have been slow in responding to NRC requests for information in most of the review areas.
~011 S
The performance in resolving and responding to NRC:.concerns has improved in recent months, however, for reasons stated
- above, the overall performance for the appraisal period is rated as Category 3.'