ML19207B702

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Order Confirming Suspension of Const Due to Concern Over Adequacy of Licensee QA Program & of Concrete Placement Requiring Escalated Enforcement Action
ML19207B702
Person / Time
Site: Marble Hill
Issue date: 08/15/1979
From: Stello V
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML19207B699 List:
References
NUDOCS 7909050107
Download: ML19207B702 (10)


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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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PUBLIC SERVICE COMPANY OF INDIANA

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Docket Nos. 50-546 (Marb.le Hill Nuclear Generating

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50-547 Station, Units 1 and 2)

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ORDER CONFIRMING SUSPENSION OF CONSTRUCTION The Public Service Company of Indiana (PSI or licer ee) is the holder of Construction Permits, Nos. CPPR-170 and CPPR-171, issued on April 4,1978.

These permits authorize in accordance with their provisions construction of tne Marble Hill Nuclear Generating Station, Units 1 and 2.

Over the past few months, serious. problems have been identified at the Marble Hill facility con-cerning the adequacy of the licensee's quality assurance program and, in carticular, the adequady of concrete placement which requires escalated enforcement action.

II As a result of an inspection conducted on April 3-6, 1979, a Notice of Violation was issued to the licensee on May 4,1979.

One item in the Notice identified noncompliance with Criterion X of Appendix B to 10 CFR Part 50 related to poor control of the quality of concrete placement activities at the site.

During another inspection conducted on April 30 through May 3,1979, acditional items of noncompliance were identified.

Another Notice of Violation was issued on May 29, 1979, which included an additional citation agains:

riterien X related to inadecuate control of the cuality of concrete olacement ac itities as well as a citation agains: Criterion XVI of Aprendix B to 10 CFR
1-: 50 :n the basis of improcer curing of concrete in the containment wall.

On.une 12,1979, Thcmas Cattilo, at:ceney for Save :ne Valley /Save "arble woe o w' 7

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. Hill, sent the Director of Nuclear Reactor Regulation a copy of.an affidavit by a fomer construction worker at the Marble Hill site who alleged that several honeycombed areas in the concrete had been improperly repaired. Upon its okn investigation of these allegations, the licensee discovered and reported on June 21, 1979, defective repairs of honeycombed concrete areas at the site.

Representatives of the Offi~ce of Inspection and Enforcernent's Region III office were sent to the site on June 21, 1979, to investigate the licensee's findings as well as the former construction worker's allegations.

Region III's investi-9ation identified additional areas where concrete had been improperly repaired and identified continued inadequacies in the licensee's quality assurance program.

On June 26, 1979, representatives of the NRC's Region III office met with the licensee's management to discuss the findings of the NRC's and the licensee's investigations of concrete-related problems at the Marble Hill facility and to discuss the licensee's corrective action with respect to concrete olac rent activities.

As confirmed in an Immediate Action Letter dated June 27, 1979, the licensee agreed at this meeting to stop work on safety-related concrete, to test additional areas for the soundness of concrete repairs and not to resume work on safety-related concrete until the NRC was satisfied with the licensee's upgraded quality assurance controls.

Despite the licensee's efforts to improve its quality assurance program, representatives of the NRC and the licensee identified major problems in the preparation for the planned resumption of placement of safety-related concrete on July 10, 1979, such that the placement was not ber;un. When the licensee

larned to attempt resumption of work on safety-related concrete on

-__ ; 17, 1979, the licensee again found inadecuate ore::aration of the placement atea, even after One contractor had accepted the area as ready for concrete

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- placement, such that the concrete was not placed until July 18.

During the NRC's continuing inspection efforts at the site during July, additional items of noncompliance were identified with Criteria II, V, IX, X,: and X'.".

of Appendix B to 10 CFR Part 50. The nature of noncompliance with these Criteria is set forth in Appendix A to this Order.

These items of noncompliance

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further indicate serious in' adequacies in the licensee's quality assurance program for concrete-related construction activities.

On July 20, 1979, representatives of Region III and licensee's management again met at the site.

It was agreed that the licensee would not allow place-ment of additional safety-related concrete until the licensee prepared and the NRC a: proved a comprehensive program covering implementation of contractor's cuality assurance programs and the licensee's oversight activities to assure that such quality assurance programs could be carried out properly. This agreement was confirmed in an Immediate Action Letter dated July 23, 1979.

III On July 24, 1979, the fUtC's Region III office learned that a team from the N'ational Board of Boiler and Pressure Vessel Inspectors had conducted an inspection c June 12-14, 1979, at the Marble Hill site durina which numerous items of noncompliancr witn the ASME Code were found. As a result of its inspection, the National Board reccrended that the licensee's ASME Certificate of Authorization should be withdrawn and that the licensee should cease acting as a supplier of ASME Code material to its subcontractors without ASME authorization. The NRC staff

ncuc e: an inspection curing the period July 26-25, and July 31-Augus: 3, 19T,

'cicr included the areas reviewed by the National Board of Boiler and pressure

'~ esse' I scectcrs. While recognizing -hat some errors in identifica icn of 1:arial nere ccntained in the National Scard's report, the NRC's inspection 9)1350

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indicated that problems in the quality assurance program previously identified in concrete construction activities extend to the other construction areas as well.

At the request of PSI, representatives of Region III and the licensee's management met again on August 1,1979, to discuss PSI's planned actions to correct the programmatic quality assurance problems at the Marble Hill site.

The meeting included a discussion of the desirability of stocoinc all safety-related construction activities at the Marble Hill site until such time as the licensee demonstrates that it has a quality assurance program acceptable to the NRC.

The licensee issued a stop work order on August 7,1979, for all safety-related construction.

It is desirable to confirm by order the licensee's action.

IV In view of the forecoing, IT IS HERESY ORDERED THAT, ::ursuant to 10 CFR Parts 2 and 50, the licensee shall not resume safety-related construction activities on the Marble Hill Units 1 and 2 nuclear power station until such time as (1) th': licensee submits in writing ander oath to the Director, Office of Inspection ard Enforcement, a description of its revised quality assurance program and the steps taken to assure that safety-related construction will be conducted in accordance with Appendix 3 of 10 CFR Part 50 of the Comission's re:ulations and (2).the Director has confirmed in writing : hat reasonable assurance exists that safety-related construction activities will be conducted

'n a:ccrdance with such recuire ents. Such confirmation ma; extend in whole or ir ra-: :: the suscenced construction activities.

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In reaching his determination the Dire: tor will consider whether and the extent to which the Licensee has:

(1)

Reviewed the work completed as cf the date of this order to determine whether the Li:ensee's quality assurance program was adequate to assure such work was properly performed, and described what repairs, if any, are required.

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(2)

Conducted a revieg using independent management consultants where appropriate,of the licensee's project management and cuality assurance programs to detertiine whether these are adequate to exer-cise fell control over all aspects of the Marble Hill project, and submitted the results of that review, the recommendations for revision to the axisting programs, and the schedule for implementing the recommendations.

(3)

Described the number, qualifications, and experience of the Licensee's quality' assurance, qua'ity control, and engineering and construction management staff broken down by const.uction activity, the degree to which contract staff will be utilized for these activities, and the relationship between the quality assurance and quality control staffs and their respcasibilities.

(4)

Reviewed al' contracts of contractors and subcontractors doing safety related work to assure the adequacy of the'r cuality assurance and cuality control responsibilities and programs including conditions of such con-tracts tha; may im act negatively on cuality,

identifiec the s?ecific sters c be taken to assure such condi:icns :o

.c recu:e the cuality cf safety -ela:ed worr., and sub.mitted One s:nedule ;c implemen; sucn

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(5)

Described the mechanism for assuring timely identification and evaluation of construction deficiencies including conflicts in specifications, drawings, procedures, and directions released for use in construction and described the system for assuring corporate management's awarenass of site problems on a timely basis and input into the evaluation and correction of these problems.

(6) Described the, system for promptly halting construction due to nonconforming circumstances or unacceptable work including criteria for defining unacceptable work and for assuring instructions explicitly describe how work is to be performed so that both production and inspection personnel understand what is not acceptable.

(7)

Described the system for assuring inspections cn a timely basis including ccmplete inspection procedures and preolanning of activities to assure availability of trained inspectors.

(S)

Described how the Licensee intends to manage the program covered by Section III of the ASME iluclear Componencs Code including the technical responoibility for all design efforts of the f!SSS and A/E and the administrative control of design and manufacturing efforts of all ccmponent manufacteers.

(9)

Described the system to train all levels of construction personnel in the need and inccrtance of satisfying cuality requirements and to enccurage all personnel to cc=unicate, wi:ncut -ecrimination en the

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cf the licensee or its contractors, their concerns or knowledge cf imcro;er ccnstruction oraccices to crecer lev 11s of Tanagemen:

for evaluation anc -esolution.

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. V Any person whose interest may be affected by this Order may request a hearing within twenty days of the date of this Order.

If a hearing is requested, the Commission will issue an Order designating the time and place for hearing.

In the event a hearing is requested, the issues to be considered at such hearing shall be:

(1) Whether the facts set forth in Parts II and III of this Order are true; (2) Whether this Order should be sustained.

The filing of a request for a hearing need not s:ay resumotion of all or part of construction if authorized by the Director in acc rdance with this Order.

Resumption of all or part of ;onstruction activities en terms consistent with this Order need not be stayed by the pendency of any proceeding on this Order.

In the event that a need for further enforcement action becomes apparent, either in the course of the hearing or at any other time, aparcoriate action will be taken by the Director.

This Order is effective upon issuance.

FOR.THE i;UCLEAR REGULATORY C0ft11SSION gl Y

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. /x' Victor Steiic, Jr.,

Di rector Office of Ins:ection and Enforcement 23:ed a; Be:nesda, "arvland tris \\shkray of August,'1979.

Ent::sure:

1::endix A

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APPENDIX A As a result of investigations by the NRC during the period June 21-July 27, 1979, the following items of.noncompliar.ce have been identified thbs far:

1.

Contrary to 10 CFR Part 50, Appendix B, Criterion II, (a) many of the licensee's and contractor's personnel who are assigned to implement quality assurance responsibilities did not have appropriate experience or training in the placement of concrete for nuclear reactors such that they were suitably proficient to perform their quality assurance responsibilities; (b) the licensee did not assure that its contractor had provided adequate indoctrination and training to craft personnel in order to perform repairs to defective concre^'

as indicated by numerous improper repairs discovered during the inspection, the use of improper materials for repair, and the imprcper storage of cement used for dry-pack material; and (c) the licensee did not provide adequate controls over in-process activities affecting the quality of structures in that PSI-inspection personnel have insufficient authority to immediately stop or prevent non-conforming in-process work.

2.

Contrary to 10 CFR Part 50, Appendix S, Criterion V, the licensee does not have or has not followed its procedures, in that:

(a) the licensee did not have a procedure for repair of defective concrete using dry-pack materials; (b) the licensee did not assure that its contractor followed its procedure for identification and tagging of defective concrete areas for recair; and W

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(c) the licensee did not have a detailed procedure for evaluating repetitive nonconformances.

3.

Contrary to 10 CFR Part 50, Appendix B, Criterion IX, the licensee has not established appropriate measures to control and accomplish certain special processes, in that:

(a) for micro-seismic t ' crete examination, the licensee did not provide ror certifica:1on of testing equipment performance and does not document the qualification of test personnel to perform such tests; and (b) the licensee's procedures for welding only provide for performance of vertical and overhead welding techniques.

a.

Centrary to 10 CFR Part 50, Appendix B, Criterion X, the licensee and the contractor did not perform adequate inspections of preplacement and placement of concrete, in that:

(a) with regard to preplacement inspection, the contractor's inspection on July 10 and 17,1979, of Lategory I concrete work did not identify im roper horizontal and vertical preparation of construction joints, inadequate cleanliness of reinforcement steel, and inadequate clearance of reinforcement steel; and (b) with regard to placement of concrete, the licensee's and contractor's inspection on July 18, 1979, o# Category I work did not identify imor per use of concrete vibrator;, imprecer concrete lift thicknesses, and excessive lateral movement of concrete using vibrater; 5.

Ccr.trary to 10 CFR par: 50, A:pendix E, Criterion XVI, the licensee cid ac::

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(a) identify or take corrective action with respect to approximately 170 unacceptable concrete patches; (b) take actior, to resolve noncompliance with ASME requirements related to the licensee's activitier u a snoplier of materials to its site contractors, even though these noncompliances were identified approximately two years ago.

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