ML19292D069
| ML19292D069 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/30/1984 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| REF-10CFR9.7 M840323A, NUDOCS 8404110480 | |
| Download: ML19292D069 (8) | |
Text
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IN P.ESPONSE, PLEASE
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UNITED STATES
, ',j NUCLEAR REGULATORY COMMISSION
REFER TO:
M840323A WASHIN GTON. D.C. 20555 g
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( D %. e ACTION - Keppler March 30, 1984 Cys: Dircks OFFICE OF THE Roe SECRETARY ggg Stello Denton
' MEMORANDUM FOR:
William J. Dircks, Executi Director DeYoung for Operations y
uCunningham.
i FROM:
Samuel J. Chilk, Secretary g
SUBJECT:
STAFF REQOIREMENTS - DISCDGS: JN/POSSIBLE VOTE ON FULL POWER OPERATING LICENSE FOR LASALLE-2, 10:00 A.M., FRIDAY, MARCH 23, 19 84, COMMISSIONERS ' CONFERENCE ROOM, D.C. OFFICE (OPEN/ CLOSED--EX. 5)
The Commission was briefed in closed session on a status report on allegations regarding LaSalle-2.
The Commission, in open session, unanimously authorized staff's issuance of a full power operating license amendment for LaSalle-2.
(NRR)
% WM p The Commission requested additional information from staff on the QA program severity level four violations at Byron.
The Commission asked staff to include a report on construction
.QA in each future FPOL presentation.
(Region III)
(SECY Suspense:
4/6/84) g The Commission requested that staff make public the March 21 memorandum on QA at LaSalle.
(Region III)
The Commission also heard from C. Reed, Vice President-Nuclear, Commonwealth Edison.
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Chairman Palladino Commissioner Gilinsky Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Commission Staff offices PDR - Advance
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(.%U ENCLOSURE:.
BASES FOR THE STAFF'S CONFIDENCE IN THE Oll"_ITY OF.THE CONSTRUCTION OF~
LASALLE UNIT 2 The staff is. confident of the quality of construction of LaSalle County Unit 2.
The reasons for this confidence are as follows:
1.
LaSalle County Unit I has operated for two years with only one major failure attributable to the Quality Assurance Program. That failure was a composition naterial seal on the Feedwater.5ystem check valve.- The problem appears to be generic to the industry and is being addressed py the licensee.
2.
Region III has expended over 30,000 man-hours of inspection time on the LaSalle County site. The number of inspections is sunnarized as follows:
Number of Year Inspections 1973
,3 1974 4
10 1975 1976 12 1977 13 1978 34 1979 44 1980 56 1981 42 1982 57 1983 57 Totals 372 There were no' Severity Leyel III or above items of noncompliance identified for construction inspections at LaSalle Units 1 or 2.
3.
Region III has closely scrutinized activities on site as can be seen from the above data and is confident of the quality of construction.
4.
Based on numerous allegations prior to licensing of both Unit 1 and Unit 2 Region III has conducted reinspections of numerous construction activities.
In each case, the plant was constructed as required per design reports with few exceptions.
5.
The special NRC inspection conducted in 1982 at the Byron Station did not identify significant construction problems.
The reinspection program conducted as a result of this inspection was performed because of concerns regarding the qualifications of quality control inspectors.
This reinspection program did not identify any hardware problems which required rework.
This gives the staff further confidence in the company's quality assurance program.
2 As a part of the operational readiness review for Unit 1, HRC required an independent review of Sargent and Lundy's design methods and design 5.
Teledyne Corporation was selected by the HRC staff.for this controls.
independent review which used a randomly selected plant riping system as This review established that proper design
- a vehicle for the review.
methods and positive design controls were utilized by the Architect Engineer and Ceco for LaSalle project piping and structural designj As a result of various allegations relating to the installation of HVAdi.
systems at LaSalle, the NRC required an independent review of HVAC~
7.
The review, This was performed by C. F. Braun Company.
although identifying some deficiencies, concluded that the design and systems.
installation of LaSalie HVAC systems was adequate.
All deficiencies identified as open at the time of C. F. Braun's report have been closed and corrective actions verified by Ceco site QA Since Unit 2 was in large part complete at the time surveillance 82-708.
of C. F. Braun's site activitias, the results are felt to apply equally Further, the results of_ additional inspections by CECO site to Unit 2.
CA.on Unit 2 systers were consistent with the results report by C. F. Braun.
During the course of construction at LaSalle, CECO Site Quality Assurance has initiated numerous special inspections (overinspections) to monitor 8.
work activities and to further verify proper compliance with the QA These overinspections were in program and specification requirements.They ranged from independent excess of the normal QC inspection,s.
testing agency (Conam) personnel assigned to perform random visual weld inspections of the vhrious contractors, to formalized programs of The following complete overinspection prior to acceptance of the work.
is a tabulation of the types of activities performed by Ceco LaSalle Site QA to further assure the adequacy of plant construction and, were above and beyond those required by the CECO QA program or project specifications.
Assignment of a Conam inspector to monitor safety-related cable a.
pulls to assure procedural requirements were met.
Assignment of a Conam inspector to nonitor housekeeping and cable,
b.
pan cleanliness during the cable pulling activities.
Special CECO Site QA surveillances to verify proper cable routing This consisted of checks at various nodes in cable trays and risers c.
to assure that the proper cables were at the location.
After problems were identified'in Unit 1, special CECO Site QA d.
surveillances were performed in Unit 2 to assure that MCC breaker settings were correct.
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3 For. Unit 2, a new inspection program was instituted by Ceco Site QA, e.
and titled the L' nit Concept Inspection Program. -The purpose of this program was to provide an additional level of assurance in the quality of the facilities and equipment installed at the LaSalle County Nuclear Station.
The inspections were perfomed using the basic design documents to assure that the completed work confomed to design requirements.
During the period of September 1982 to Octobar 1983, fourty-four (44) Unit Concept Inspections were performed by the Independent Inspection Agency (Conam) un' der t.he guidance of CECO Site QA..
f.
A trend analysis was performe'd.
The nature of the deficiencies and the frequency of their occurrence particular to-the inspected items, indicated that no adverse trends existed. The Unit Concept Inspection Program has provided another level of assurance.that LaSalle County Unit 2 is constructed in accordance with the design
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requirements.
For safety related coating work, CECO's Level III Coating Inspector g.
from the Operational Analysis Department performed bi-weekly surveillances of' Category I coating work in addition to nomal site QA surveillances.-
h..
As a result.of NRC concerns during -Unit 1 startup, Ceco purchased t
a digital torque wrench tester which has been used by Canam to independently spct-check site contractor's torque wrenches for adherence to calibration requirements.
This over check has shown that torque wrench calibration activities were being properly carried out for the various site contractors.
i.
100% overinspection by the independent testing agency (Conam) of all safety related HVAC hanger welding performed prior to August 1980.
Reduced levels of ove.rinspection continued until completiron of all safety related HVAC hanger work.
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A mandatory hold point was established requiring Conam to inspect all HVAC ductwork moved into the building from May 1980 through early 1982.
This action was taken to assure adequacy of inspections and quality of ductwork stitch welds.
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Mandatory hold points were established requ' iring 100% verification.
of the safety related calibration documentation for station instru-ments calibrated by Cataract, the Site calibration contractor.
The verification was performed by Ceco Site QA'for 6 months to assure acceptable documentation of caTibration activities.
1.
A special program was initiated to assure the conformance of
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purchased ASME Section III vaYves to minimum wall thickness requirements.
This program was. completed by Conam under the direction of CECO Site QL
t, m.
In addition to random inspection of welds, Conam inspectors were assigned to perfom general surveillance activities.- The surveillances consisted of monitorir.g varicus Site cbntractor field work activities for conformance to specification.
This activity uns
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in addition to the surveillance activities of CECc Site QA.
9.
The Ceco Quality Assurance Department has authority to stop work independent of the Production Department and has not shown a reluctance to do so when conditions warrant this,,actiori. The following sumarizes "
stop work actions initiated by Comonwealth Edison.
Reason Period of Year Orcanization for Stoo Work Stoo Work 1976 Foley QA Program Inadequacies 2 Months 1977 Zack QA Program & QA Inspection Inadequacies 2 1/2 Months
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1978 Ceco-Production Inadequate Procedures Maintenance 4 Weeks
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Foley Welding QC Problems 3 Weeks 1979 Midway QC Inspection Inadequacia.s 1 Week Zack.
Inspection & Installation Procedures (CEA) 15' Months B. F. Shaw Procedures (Coa i gs) 6 Months Rockwell Engr.
Procedures (Coatin 3 Months Comercial Concrete Procedures (CEA's)gs)
Permanent Inryco Shop Inspection Problems 1 Month MCC Powers Hold Points Regulator Passed 2 Months hnson Controls Personnel Qualification 4 1/2 Months Mid City Inspection & Installation Procedures (CEA) 11 1/2 Months Walsh Ir.spection & Installation Procedures (CEA) 6 Months Reactor Controls Inspection & Installation Procedures (CEA) 16 Months Reactor Controls Welder Qualification Documentation 2 Weeks Zack Welding Inspection I-6 Months.
1980 Reactor Controls Design Control &
Installation Drocedures (Hanger Design) 5 Months G. E. Startrec QC Inspections & Material Control 2 1/2 Months Tech-Sil QC Procedures & Inspections 2 Months 8
5 Reason
' Period of Year Organization for Stop Work Stoo Work
. Tech-Sil Design & Manufacturer Control 2 1/2 Months Morrison, S&L; Hanger Design Control
'3 Weeks MSC
. '1982 Walsh Tech Engrs. ~ As buil.t measur.ements 2 Days Sargent & Lundy Whip. restraint design changes 6 Days-Cataract Incorp.
QA procedures implementaticn 3
(Limited scope stop. work) 2 Months 10.
The Comonwealth Edison Company ccrporate Quality Assurance Department has conducted routine on site audits of LaSalle County Site Construction independent of its onsite Quality Assurance Organization.
A sumary of the results of these audits is as follows:
Number-Year of Audits Findinos1 Observation 2 Totals 1975 2
-11 l0 21 1976 2
1-
'6 7-1977 2
16 3
19 1978 2
20 12 32 1979 2
21 8
29 1980 2
14 6
20 1981 2
4 5
9 1982 5
15 8
23 1983 3
7 5
12 Totals 22
, 109 63 172
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11.
Com:nonwealth Edison Company onsite Quality Assurance Department conducts routine onsite audits and surveillances of LaSalle. County Site construction independent of its contractor Quality Control inspe. tors.
A sumary of the results of these audits is as follows:
a.
Audits of Site Construction Activities
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Humber Year Of Audits Findinos1 Observation 2 Totals 1974 2
2 0
2 1975 46 55 35 91 1975.
46 106 65 171 1
Finding - Item of noncompliance or' deficiency to established documents or requirements which recuires clarification or corrective action.
2 Observation - An item for discussion but not considered to be a.
noncompliance or vioT& tion.
S, Number Year Of Audits Findings 1 Observation 2. ~
Totals 1977 53 69 134 203 1978 71 114 92 206 1979*
97 156 131 287 1980 124 155 118 273 1981
' 53 48 50 98 1982 58 60 44 104 1983 50 76 100 176 1984 (thru 2/15) 1 0
3 3
Totals 611 841 772 1614 b.
Surveillance of Site Construction Activities Number of Year Surveillances
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1974 9
1975 f-52 1976 222 1977 458 1978 646 1979 581 1980 728
- 1981 B31 1982 255 1983 755 1984 (thru 2/15) 19 TOTAL 5076 12.
Commonwealth Edi. son Company's onsite Quality Assurance Department has
- retained an indgendent testing agency to perform inspections and tests for many years. A summary of these inspections and tests is as follows:
AREA 0F WORK Concrete Expansion Anchors Bolting 33824 Inspection Reports Welding General Construcht1n. -
1 Finding - Item of noncompliance or deficiency to established documents or requirementrwhich requires clarification or corrective action.
- 2 Observation - An item for discussion but not considered to be.a noncompliance or violation.
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NON-DESTRUCTIVE EXAMINATIONS Magnetic Particle Penetrant Testing
' Radiography 25,242 Examination Reports Leak Testing.
U. T.
44 Inspection Reports UNIT CONCEPT INSPECTIONS
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13.
Comnonwealth Edison Contractors have performed many audits. of their construction activities. A sumnary of the audits performed by the major site contractors is as follows:
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Contractor Number of Audits Morrison 632 Foley 303..
-Totals 1057 e
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