ML19254B375
| ML19254B375 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 08/03/1979 |
| From: | Hart G, Randolph J, Stafford R SENATE, SENATE, ENVIRONMENT & PUBLIC WORKS |
| To: | Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19254B343 | List: |
| References | |
| NUDOCS 7909270402 | |
| Download: ML19254B375 (40) | |
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WASHINGTON. D.C. 20510 August 3, 1979 Mr. Joseph M. Hendrie Chairman U.S. Nuclear Regulatory Commission h'as hington, D. C.
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Dear Mr. Chairman:
Recent disclosures of construction deficiencies in safety-related structures and systems at the Marb1c Hill Nuclear power pl. ant in Indiana raise serious questions about the safe coa:truction of the facility, h'e are also concerned that the problems encountered at Marble Hill may raise major issues regarding nuclear power plant construction generally, h'e, therefore, wish to be kept fully and currently informed of the facts surrounding construction at Marble Hill so that the Subcommittee on Nuclear Regulation of the > Committee on Environment and Public t'orks can conduct a thorough review of the matter.
In addition to the Commission ensuring that our staff is regularly briefed by the Commission staff on new developments, particularly before any regulatory action is taken by the Commission, we request that you provide us with the follo' wing information:
1.
The extent to which the Commission reviewed the quality-assurance / quality-control organizationa3.
procedures of the licensee at the pre-docketing
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stage and at the construction-permit s t ag;e, and U
the Commission's assessment of these procedures at the time the construction permit was issued.
- 2. The extent to which the Commission reviewed, prior to issuance of the construction permit, the g [.(
capabilities of the utility to manage the construction of the plant, and the findings of that review.
- 3. The Commission's present assessment of the utility's J & jIgA construction-management capabilities.
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- 4. The extent to which the Commission reviewed the Marble Hill construction company's capabilities anc qualifications to build a nuclear plant prior dfg to issuing the construction permit, and the findings of that review.
- 5. The frequency and the nature of the Commission's inspection of construction in progress at Marble Hill.
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- 6. The reason the Commission did not place a resident g
inspector at the Marble Hill site when the utility requested one.
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- 7. Present Office of Management and Budget guidance to the Commission on the subj ect of resident
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E c,y inspectors, and how this guidance may have affected J
I the decision not to place an inspector at the Marble Hill site.
- 8. The extent to which the Commission reviewed contractural arrangements between the Marble Hill
-(f )f) f b licensee and its contractors, and an assessment of the impact these arrangements have em the quality
- ~I and the safety of the plant, including the affect any fixed-price contracts have had on the quality of construction.
- 9. The extent to which the Commission examines the construction practices of a utility during its
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review of an operating license application.
- 10. The remedies available to the Commission when it uncovers deficiencies of the kind disclosed at h.-
Marble Hill,
- 11. The role of the National Board of BoileT and Pressure Vessel inspectors in the Commission's
,_9p proceedings and clarification of the extent to i~
p which the Commission accepts their inspections or duplicates them.
- 12. All documents relating to criminal allegations
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regarding construction deficiencies at. Marble Hill.
- 13. The reason construction was allowed to continue into July even though honeycombing was known to j(l[d be occurring as early as April.
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. The apparent reasons for the breakdown in the j( dp 14.
quality-assurance / quality-control procedures at the site.
15.
Any affidavits i-the possession of the Commission from Marble Hill construction workers relating Ic/Olg (
to information about construction problems.
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The hiring practices of Marble Hill construction
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contractors and the extent to which workers l'
experienced in nuclear facility construction were sought out and utilized by the contractors.
17.
The inspection practices used by the contractor and the utility and the extent to which the NRC
}/p trains non-Commission inspectors and approves inspection methods used by them.
We ask that your response to this request for information be forwarded to us within two weeks of the date of this letter.
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Robert T. Stafford !
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Enclosure Information Relative to Construction and Quality Assurance Program Deficiencies at The Public Service of Indiana Marble Hill Nuclear Facility August
, 1979 1046 158
The basic approach is to repeat each question and follow it with the appropriate response.
In some instances questions interrelate to the point where an integrated response appears to be more practical.
This approach is used for Questions 1, 2, 4 and appears immediately below.
Question No. 1.
The extent to which the Commission reviewed the quality assurance / quality control organizational procedures of the licensee at the pre-docketing stage and at the construction permit stage, and the Commission's assessment of these procedures at the time the construction permit was issued.
Question No. 2.
The extent to which the Commission reviewed, prior to issuance of the construction permit, the capabilities of the utility to manage the construction of the plant, and the findings of that review.
Question No. 4.
The extent to which the Commission reviewed the Marble Hill construction company's capabilities and qualifica-tions to build a nuclear plant prior to issuing the con-struction permit, and the findings of that review.
Response
The NRC expects each applicant (and holder) of a construc-tion permit to have in effect at all times a quality assurance (QA) program consistent with the status of the project.
In the early stages of the project, the nucleus of the future organization and the plans for future expan-sion should be in place.
When Public Service of Indiana (PSI) originally filed its application for a Construction Permit (CP), the Office of Nuclear Reactor Regulation (NRR) and the Office of Inspection and Enforcement (IE) found that both the program description and program mple-mentation were unacceptable and that NRC should do no 104o 159
-g-further application review until both aspects of the QA program were significantly improved.
PSI went back and worked over its program, and filed a new and expanded program description.
NRC/NRR, after review, decided that the revised program provided what generally appeared to be a sufficiently detailed and explicit description to warrant more detailed review.
NRC/IE inspectors found that the program in place conformed to the description submitted and that the program implementation was consistent with work in progress.
Based on these findings the Application was docketed in September 1975.
s After the application had bean docketed (formally accepted for review) NRR, as part of its total technical and program-matic review, examined in greater detail the proposed QA program for construction.
Guidance for preparation of the QA part of a CP application is contained in Section 17.1 of Regulatory Guide 1.70.
A copy is attached as Enclosure 1.
Criteria for NRR review of the Application is contained in Section 17.1 of the Commission's " Standard Review Plan," a copy of which is attached as Enclosure 2.
This document is available to the public and provides some additional guidance to applicants.
During the NRR review it became apparent that, although the QA program was acceptable for the limited work in 1946 160
. progress, the plans for the future were in various areas inadequate or inadequately described.
Several exchanges of correspondence occurred as the applicant revised and expanded the QA section of the application.
Ultimately NRR concluded that PSI had described in sufficient detail a QA program that, if implemented, should provide acceptable QA control over the project.
IE verified that application of the QA program to work in progress was acceptable and that representative procedures had been developed and were being implemented.
Section 13.1.1 of the Standard Format, and of the Standard Review Plan (Enclosure 3) provides guidance to the applicant and the NR'l staff for description and examination of the proposed organization for overall management of the project.
After some changes in the application as a result of NRR questions, the description of the organization was found to be acceptable.
The application addressed the applicant's organization for overall management of the program, and identified the two principal engineering contractors, Westinghouse for the nuclear steam supply system, and Sargent and Lundy for design of the balance of plant.
1046 161
. The organization of Sargent and Lundy for the Marble Hill project, and how it relates to interface: with Westinghouse and with PSI was described in considerable detail.
The Westinghouse management organization and quality assurance program have been previously described in a generic document and have been found acceptable by NRR.
The organization described by PSI in the application satisfied NRR criteria.
When the CP was issued and PSI had negotiated construction contracts and started work, initially the work appeared to be under good control.
However, as the volume of work and the number of contractors employed has increased, it has become increasingly apparent that the number and variety of PSI employees on site is not adequate to control the contractor's work.
We believe that existence of this situation to the aggravated degree that we have found is a serious reflection on corporate management, and on the functional adequacy of the QA staff in performance versus promise.
We believe that extensive corrective action by PSI is needed.
Question No. 3.
The Commission's present assessment of the utilities construction management capabilities.
1046, I62
. Resocnse:
The NRC staff believes that in the recent past the manage-ment organization for the Marble Hill project has not functioned acceptably.
This is the fundamental reason for the confirmatory stop work order. (A copy of which is enclosed - Enclosure 3A).
The staff also believes that there is no reason why the organization cannot be strengthened to function acceptably.
This will require that the utility consider the use of management consultants or contractors or expand its inhouse capability.
Questicn No. 5.
The frequency and the nature of the Commission's inspection of construction in progress at Marble Hill.
Response
The following text tabulates the date, the scope and the summary findings of each NRC inspection conducted through May 1979.
More recent inspections have not yet been documented.
Initial contact with PSI was made on July 10-11, 1975 to examine the current status of the quality assurance program to assist in determination whether the Marble Hill applica-tion should be accepted for docketing.
The conclusion wa:
reached that the program needed improvement.
An inspection was conducted on September 3, 4, 1975 to determine whether the program had been improved to a level which warranted acceptance of the application for review.
' :1 0 4 6 1 6 3 The inspection results indicated that the program, and its implementation were acceptable and consistent with the work then in process.
An information meeting was held with PSI on January 22, 1976, and the first post-docketing inspection was conducted on March 10-12, 1976.
This inspection indicated that as of that time, PSI had developed and was implementing appropriate procedures for the work then in progress.
A follow-up inspection conducted on June 15-18, 1976, led to the conclusion that the QA program as it then existed was acceptable.
Another inspection was conducted on November 9-10, 1976 and a special investigation of an allegation of unauthorized construction was conducted on November 19, 1976.
Neither of these latter actions disclosed any unacceptable conditions.
A Limited Work Authorization (LWA) was issued to PSI on August 14, 1977, by authority of the NRC Atomic Safety and Licensing Board.
This authorized site clearing and grading, foundation excavation, establishment of construction facilities and construction of a 10.5 mile section of railroad to the site.
No safety related work was authorized.
1046 164 The inspector found that work in progress was within limits of the LWA, and that at that time the ratio of PSI staff to contractor staff was 29/200.
On October 11-12, 1977, an inspection was conducted of the environmental protection compliance with the conditions of the Work Authorization.
No apparent items of noncom-pliance were identified.
On November 8-10, 1977, an inspection was conducted to examine work performance procedures, and conformance to the procedures.
Some deficiencies in procedures and deviations from procedures were noted.
In retrospect the most significant finding was that the major contractor and one subcontracter had insufficient QA/QC staff.
On November 29 - December 1, 1977, an inspection was performed to examine the licensee's corrective action on previous items of concern, and procedures prepared for work expected to start in the near future.
All corrective action appeared to be acceptable.
In particular, con-tractor QA/QC current and projected staff were judged to be acceptable.
1046 165 On January 25, 1978, an inspection was conducted.
Work procedures were examined.
Due to inclecent weather, construction work had been halted, therefore work performance was not examined.
No problems were identified.
On February 15-17, 1978, an inspection was conducted to examine procedures, work performance and records for concrete work and for prefabrication of the steel liners for the containment building.
Two minor problems were identified related to welding for the liner.
In one instance a needed procedure requirement did not exist.
In the other instance an existing procedure requirement was not being followed.
On May 10-12, 1978 an inspection was corducted to examine work perfermance under the construction permit issued on April 4, 1978.
In general, preplanning appeared to be satisfactory.
Three instances were identified where work performance did not conform to program requirements.
These related to:
1.
Segregation of nonconforming material.
2.
Control of drawings to assure consistent use of only the latest version.
3.
Weather protected storage for items requiring such storage.
1046 166 An inspection was conducted on June 20-22, 1978 to examine procedures and work performance.
Recurrence (in different areas) of items 1 and 3 above were identified.
Also lack of training and documentation of competence of inspection personnel were found.
An inspection was conducted on August 15-17, 1978.
No problems were identified.
An inspection was conducted on September 6-8 and 19-20, 1978.
No new problems were identified.
Corrective action for two previous concerns was found to be acceptable.
Corrective action on drawing control was found to be unacceptable.
An inspection was conducted on October 11-12, 1978 to followup on previously identified concerns, and to examine preparations for receipt and handling of the reactor vessel and other heavy loads.
Two items remained open from previous inspections; segregation of accepted and non-accepted piping material, and control of superseded drawings.
An inspection was conducted on November 6-9, 1978 to examine records related to receipt and handli,,g of the reactor pressure vessel and its head, and two stean generators.
The components were successfully transferred 1046 167 reactor pressure vessel and its head, and two steam generators.
The components were successfully transferred to storage, but it appeared that the lifting equipment had not been proof tested as required.
In another area, "Cadweld" reinforcing steel splices had not been properly inspected.
Observation of the inspector showed that he had not been properly trained and was accepting splices which should be rejected.
An inspection was conducted on November 15-16, 1978 to examine the ongoing environmental monitoring program.
No problems were identified.
Inspections were conducted on December 12-14, 1978 and January 10-12, 1979 to examine licensee actions on previous find (ngs and observe. radiography in prcgress.
Three of four items had not been acceptably resolved.
No problems were identified related to radiography.
An inspection was conducted February 27 thru March 3, 1979.
One infraction related to improper storage and two unresolved items, one on handling defective equipment, one on adequacy of QA program were identified.
1046 168 An inspection was conducted April 3-6, 1979 to examine radiographic procedures for containment liner welds, and to observe work performance in concrete placement, tendon hardware installation and "Cadweld" splice records.
Problems were identified in all areas inspected except "Cadweld" inspection.
Concrete preplacement inspection problems, concrete placement problems (honeycomb) and improper repair and curing of repaired areas were identified.
This is the first real evidence of a serious QA/QC breakdown.
First line inspection was ineffective, and upper levels of the program did not detect it.
An inspection was conducted April 30 - May 3, 1979 to examine the licensee.'s program for reporting pursuant to 10 CFR 50.55(e) (Reporting of Construction Deficiencies),
concrete placement, and record review.
It was determined that PSI in two instances failed to conform to require-ments of 10 CFR 50.55(e), and that control of concrete quality had not improved.
allowup meeting was conducted at the On May 15, 1 m 4
PSI corpora's oft 1cc During that meeting, PSI agreed to suspend concrete placement pendinC correction of concrete placement problems.
1046 169 Subsequent inspection activities have not yet been documented.
Question No. 6.
The reason the Commission did not place a resident inspector at the Marble Hill site when the utility requested one.
Question No. 7.
Present Office of Management and Budget guidance to the Commission on the subject of resident inspectors, and how this guidance may have affected the decision not to place an inspector at the Marble Hill site.
Response
The "present" guidance from the Office of Management and Budget with regard to the assignment of resident inspectors dates back to the fall of 1977.
At that time the NRC had requested from OMB enough additional people to allow the assignment of resident inspectors to all nuclear reactor sites.
The resources approved by the OM8 were less than those needed to station a resident at each site.
Early construction sites were not to be staffed with resident inspectors because the additional manyears associated with such assignments were determint.c by OMB not to be cost beneficial.
The resource level approved by OMB allowed the NRC to initiate a program that would, when fully implemented in FY 1981, station a resident inspector at all sites having che or more reactor units in preopera-tional testing, startup, or in operation as well as at most can'struction sites having units in the later stages of construction.
This policy has been adhered to from that time until the present.
(See Enclosure 4 for present and projected assignment of resident inspectors.
Note:
1046 170 This projection is subject to change based upon FY 81 budget deliberation.)
Construction was in the early stages at the time the utility made the request for a resident inspector at Marble Hill.
Therefore, the site did not meet the controlling criteria for the assignment of a resident inspector.
Current planning includes provisions for assigning residents at four early construction sites.
Marble Hill is now receiving inspection coverage equiva-lent tc a Resident Inspector pending selection and relo-cation of an assigned Resident Inspector.
Question No. 8.
The extent to which the Commission reviewed contractual arrangements between the Marble Hill licensee and its contractors, and an assessment of the impact these arrange-ments have on the quality and the safety of the plant, including the affect any fixed price contracts have had on the quality of construction.
Response
NRR does not review the contractual arrangements between the Marble Hill licensee and its contractors.
Question No. 9.
The extent to which Commission examines the construction practices of a utility during its review of an operating license application.
Resoonse The NRC program review at the operating license stage is specifically directed towards the applicant's plans and organization for the operation of the facility.
Generally, these activities are distinctly separate from those involved 1046 171 in the construction cf the facility, therefore, the construc-tion practices of a licensee are usually not relevant and are not examined during review of an operating application.
The NRR Quality Assurance Branch evaluates the IE inspection reports related to the design and construction of the plant under review.
The objective is to determine if there are substantive QA program deficiencies which require corrective action to preclude similar deficiencies during the operation phase.
Question No. 10.
The remedies available to the Commission when it uncovers deficiencies of the kind disclosed at Marble Hill.
Response
Several levels of enforcement acticas are available to the Commission to assure.that appropriate remedial action is taken to correct deficiencies.
Actions taken in problem cases will generally escalate in steps depending upon the importance to safety and the scope of a specific case.
Rapidity of escalation is also dependent upon importance to safety.
The following lists in the order of severity the seqcence of actions normally taken.
(These actions are not n.utually exclusive.)
1.
Upon identification of a problem, the inspector will attempt to obtain an acknowledgement from the licensee 1046 172 that the problem exists and a commitment for a course of corrective action.
The problem and the licensee's commitment is documented in the NRC inspection report /
Notice of Violation including specific identifica-tion of items of noncompliance.
Written response from the licensee is required on each identified item of noncompliance.
Follow-up is made during the next inspection.
2.
If the problem persists and remains uncorrected, IE management will call a formal meeting with the licensee's corporate management, either at the site or at the NRC Regional Office to obtain higher level management commitment.
Items of noncompliance will remain open until corrected.
Meetings may result in issuance of an "Immediate Action Letter" confirming that the licensee has committed to an agreed action, including a licensee's stop work order as appropriate.
Resumption of work is usually contingent upon NRC's review and approval of agreed-upon corrective action.
3.
Subsequent actions are formal and are set forth in the Commission's regulation, 10 CFR Part 2, Subpart B
" Procedure for Imposing Requirements by Order, or for Modificaticn, Suspension, or Revocation of a License, or for Imposing Civil Penalties".
A copy of Subpart B is enclosed (Enclosure 5).
1046 173 Question No. 11.
The role of the National Board of Boiler and Pressure Vessel inspectors in the Commission's proceedings and clarification of the extent to which the Commission accepts their inspections or duplicates them.
Response
The National Board of Boiler and Pressure Vessel Inspectors (National Board) does not have a direct, routine or unique role in the Commission's proceedings.
Any information relevant to NRC licensee activities and having public safety significance that is received from the National Board or from any other organization performing inspection, survey or audit functions within the scope of the American Society of Mechanical Engineer's (ASME) code system, will
.be considered and acted upon as appropriate by the Commission.
Prior to its use however, the Commission will verify the accuracy of that information in the same manner as informa-tion received from any independent source.
To explain the extent to which the Commission accepts or duplicates ASME code system inspection activities requires an understanding of the over-all government-licensee-supplier relationships.
A fundamental premise of the Nuclear Regulatory Commission's nuclear facility licensing and inspection program is that the licensee is responsible for the proper construction and safe operation of his nuclear power 1046 174 plant.
The total government-industry system for the inspection of nuclear facilities has been designed to provide for multiple levels of inspection and verifica-tion.
The licensee and his contractors and vendors each participate in the inspection process in accordance with requirements prescribed in the NRC rules and regulations.
The NRC inspects independently to determine whether its requirements are being met by the licensee and his con-tractors.
The total nuclear inspection activity is pyramided, with each layer of activity verified, inspected or audited by those above.
The NRC's position is at the apex, while the great bulk of the inspection activity is performed by industry within the base.
The NRC does not at this time formally accept or rely upon inspections, audits or surveys conducted under the ASME code system as a substitute for direct NRC inspection activities.
We do however require use of the ASME inspec-tion / survey system by NRC licensees for the design, fabrica-tion, installation, testing, or inspection of certain Class I components and for in-service examination of other defined components.
These rules are covered by 10 CFR 50.55a (Enclosure 6).
Exception to these requirements may be authorized if a license applicant proposes to utilize an alternate inspection or survey system and obtains NRC approval of that alternate system.
To date no license 1046 175 applicant has made such a proposal, thus in effect the ASME inspection / survey system is applicable to those activities within the scope of the ASME nuclear codes at all domestic facilities.
The NRC has been engaged for several years in a comprehensive effort with the ASME and the National Board to negotiate an arrangement whereby the ASME code quality assurance certification activities could be formally recognized and utilized to supplement equivalent NRC efforts.
To achieve an acceptable arrangement requires that the '-fo systems utilize equivalent standards and compatible procedures.
While considerable progress has been made in achieving changes in ASME code rules and procedures, additional modifications are necessary before formal recognition and reliance upon the ASME code system can be granted to supplement direct NRC inspections.
All three organizations are devoting priority attention to this effort.
Final resolution however is not anticipated before late 1980 or 1981.
Question No. 12.
All documents relating to criminal allegations regarding construction deficiencies at Marble Hill.
Question No. 15.
Any affidavits in the possession of the Commission from Marble Hill construction workers relating to information about construction problems.
1046 176
Response
Attached are copies of affidavits and other written statements obtained during our investigation which relate to construction deficiencies at Marble Hill made by the following individuals:
1.
Charles Edward Cutshall (Enclosure 7) 2.
Jewel Rogers (Enclosure 8) 3.
Stanley Mortenson (Enclosure 9) 4.
Michael Walston (Enclosure 10) 5.
Stephen Gayso (Enclosure 11) 6.
James A. Cutshall (Enclosure 12) 7.
Carl E. Turner (Enclosure 13) 8.
Gary Hutsell (Enclosure 14)
Some of these documents indicated the possibility of criminality being involved, so NRC Region III staff performed a limited investigation of tnis aspect.
A draft investigation report was prepared and has been referred through the NRC Office of Inspector and Auditor to the Department of Justice.
Justice has advised us that they intend to pursue the subject, and has requested that the draft report be kept privileged, so as not to compromise their efforts.
1946 177 Recognizing the Committee's proper interest in the subject, we are sending a single copy of the report under separate cover to the Chairman, noting Justice's request for privilege.
Question No. 13.
The reason construction was allowed to continue into July even though honeycombing was known to be occurring as early as April.
Response
The occurrence of honeycombing during the construction of heavy concrete structures, like those utilized in nuclear facilities, is not an unusual condition.
The cause is generally due to the severe congestion of reinforcing steel which inhibits the ficw of concrete into "hard to reach" areas during placement.
Most honeycombing occurs near outside surfaces or behind embedments or obstacles in localized areas.
When repaired properly, honeycombing does not affect the structural integrity of a building.
When concrete placement and honeycombing repair problems were initially identified in April and May 1979 at Marble Hill, sufficient informaU on had not been developed to support stop work action.
On the basis of early information, it appeared that the problems were localized and confined to the honeycombing. With increased surveillance by the NRC of site activities and from information supplied by sub-contractor workmen, the scope of ti.e oroblem broadened to the extent that stop work action became justified.
The honeycombing problem, per se, was considered correctable; 1046 178 however, with iacreased information it became apparent that the real problem related to the licensee's and his sub-contractor's management of their quality assurance systems.
This was and is the NRC's primary concern and was the basis for proceeding to escalated enforcement action.
Question ha. 14.
The apparent reasons for the breakdown in the quality assurance / quality control procedures at the site.
Response
There.roear to be several reasons why the QA/QC systems implemented by PSI and its contractors have not provided adequate control of the work and identification of noncom-forming conditions.
They are as follows:
a.
PSI did not adequately identify the scope and authority of its own QA/QC function relative to site construction activities.
This is demonstrated by the high reliance PSI olaced upon the performance of their contractor's QC and by the mini,aal level of surveillance exercised by their own personnel.
The PSI QA/QC organization should have a greater involvement in site activities.
b.
PSI did not adequately staff its site QC organization.
As construction forces at the site increased from about 150 in 1977 to 1650 in 1979, PSI failed to increase its own QA/QC staff proportionately.
Failure to increase the site QA/QC staff was a corporate management decision.
1046 179 c.
The PSI site QA/QC staff lacks sufficient work experience.
For the 29 persons assigned to the PSI site QA/QC organization only 4 had previous experience which totalled less than 15 nian years in QA/QC and nuclear construction prior to their employment by PSI.
Two of the QC engineers are included in the 4 personnel with prior experience.
d.
In the opinion of NRC regional personnel, the PSI /
Newberg Construction Company contract (fixed price contract) failed to establish adequate independence for the Newberg QC organization.
This resulted in giving priority to production considerations rather than to quality matters.
e.
The PSI QA/QC s.ite organization does.iot have unilateral "stop work" authority.
Nonconforming work can not be stopped without multiple reviews and concurrence by QA/QC supervision, engineering, and site construction management.
f.
In the case of the concrete honeycombing repair, preliminary evidence suggests that certain contractor individuals may have failed to act responsibly.
This matter has been referred to the Department of Justice.
1046 I80
. Question No. 16.
The hiring practices of Marble Hill construction contractors and the extent to which workers experienced in nuclear facility construction were sought out and utilized by the contractors.
Response
This question cannot be fully addressed since NRC inquiries have not and do not normally include such detailed assess-ments.
Some related issues however, are discussed as follows:
1.
Two of the site contractors and subcontractors have not had significant prior nuclear construction experience.
Most of the other site subcontractors have had varying amounts of prior experience.
Examples of contractors who have had extensive prior experience are the Chicago Bridge & Iron, the American Bridge and the Newberg Construction companies.
CB&I is fabricating and erecting the containment liner, A-B performing the structural steel work and Newberg the civil (concrete) work.
2.
With the exception of certain staff management and special process personnel, most construction craftsmen are provided by local union halls.
This is a standard practice in the United States.
When the local union halls are unable to furnish sufficient trained 1046 181
. personnel, workmen are recruited "off the street" or from any other aveilable source.
They may or may not be hired through the union halls.
These personnel are usually unskilled, and thus must undergo some training.
In the Marble Hill case, the local concrete finisher's union is small (about 50 men) and was unable to supply all the craftsmen requested by the site concrete contractor.
The contractor consequently hired and attempted to upgrade unqualified laborers to perform concrete finishing work.
With respect to workmen having prior experience in nuclear construction as a requisite for employment at a nuclear site, such a requirement is probably not necessary and in any case is not recognized by cra't unions.
Unions supply craftsmen who are qualified as journeymen in specific trades or job classifications, i.e., carpenters, electricians, cement finishers, etc.
As a journeyman, the worker is expected to be able to produce whatever quality of work that is required for the job.
Since nuclear work requires conformance to higher standards and because of localized shortages of skilled personnel, it is necessary that licensees and their contractors provide appropriate indoctrination and training. 'This training includes coverage of QA/QC matters.
At Marble 1046 182 Hill, as evidenced by the concrete honeycombing and other identified problems, the training and indoctrination efforts were minimal and ineffective.
Question No. 17.
The inspection practices used by the contractor and the utility and the extent to which the NRC trains non-Commis-sion inspectors and approves inspection methods used by them.
Response
Contractors are generally required to have their own QA/QC organization which is independent of the activities inspected.
The inspections are coneicted in accordance with documented instructions, procedures or checklists which must receive prior approval from the licensee (utility).
Licensee practices include some form of inspection, surveillance (overview), and audit of subcontractor activ.i-ties.
For example: the contractor's inspection checklists may be required to have inspection hold points beyond which construction activities may not proceed until a member of the licensee's staff has inspected the in pro-cess activity to determine if the activity has been com-pleted in accordance with specified requirements.
The licensee's surveillance and audits of contractor activities are also planned, scheduled and cenducted in accordance with his own documented instructions, procedures or check-lists.
The results of the surveillance and audits are documented and distributed to management for appropriate use.
In those cases where conditions are found to be adverse to quality, the contractor responsible for the 1046 183
- 2 6-construction activity is required to take the necessary corrective action to.; solve the unsatisfactory condition and take action to prevent recurrence.
The licensee must determine if the corrective action is satisfactory.
The NRC reviews in detail the licensees QA/QC program (see responses to Questions 1, 2, 4, 8).
Further, the NRC's program of inspection provides for some observation of the licensee's implementation of the approved program.
The NRC's efforts do not provide for the training of licensee or licensee contractor inspection personnel by NRC staff.
Licensees / contractors are expected to provide necessary training for their own personnel to assure conformance to required standards.
If the question refers to inspections conducted by third parties, such as the ASME code system inspectors, (Question 11), the NRC is knowledgeable of the procedures used and the qualifications of the inspectors.
Third party efforts are independent of both the licensee and the NRC.
Therefore, the inspectors do not receive training by the NRC nor are their procedures subject to direct NRC review and approval.
Should the NRC/ASME/ National Board agreement be completed (see Question 11), provision will be made for NRC audit of all third party activities.
1046 184 Occasionally the NRC will utilize special censultants for the inspection or examination of highly technical subject areas, i.e., stress analyses, metallurgical investigations, special laboratory analyses, etc.
In these cases the NRC will provide overall guidance and supervision on the scope of such an investigation but will rely upon the consultant to exercise whatever methods are necessary to arrive at an acceptable resolution.
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