ML19305E615
| ML19305E615 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 04/28/1980 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19305E612 | List: |
| References | |
| REF-10CFR9.7, TASK-IR, TASK-SE SECY-80-213, NUDOCS 8005200114 | |
| Download: ML19305E615 (5) | |
Text
- - -_______ _ _ _ ___ _________ _
v.
8005200 i.
UNITED STATES NUCLEAR REGULATORY COMMISSION
.h WASHINGTON, D. C. 20555 IEFORMAT10E REPORT SECY-80-213 April 28, 1980 For:
The Commissioners From:
Victor Stello, Jr., Director Office of Inspection and Enforcement Thru:
Executive Director for Operations
Subject:
NRC INSPECTION PROGRAM RELATED TO THE MAR 8LE HILL NUCLEAR PROJECT Puroose:
To inform the Commission of the status of the licensee's program for correction of the quality assurance deficiencies that resulted in a Commission Order confirming suspension of safety-related construction at the Marbie Hill Project and the NRC's program for confirming that the licensee has taken appro-priate corrective action.
Discussion:
The Public Service Company of Indiana (PSI) is the holder of Construction Permits, Numbers CPPR-170 and CPPR-171 issued on April 4, 1978.
These permits authorize, in accordance with their provisions, construction of the Marble Hill Nuclear Generating Station, Units 1 and 2.
On August 15, 1979, the U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, issued an Order confirming suspension of safety-related construction at the Marble Hill Station.
A copy of the Order is enclosed as Appendix A.
This Order was issued as a result of serious problems which had been identified at the facility during inspections conducted during early 1979.
The problems associated with the suspension of safety-related construction are specifically identified in the Order.
In summary the problems are related to the Licensee's inability to effectively manage the construction of the nuclear project due to:
1.
A lack of sufficiently experienced staff.
2.
A need for an improved quality assurance / quality centrol program and its implementation.
3.
An inability to direct the stopping of construction work
(
by its contractors when work was being done improperly.
l CONTACT:
H. D. Thornburg, IE 49-28484 l
t 4.
An inability to recognize nonconformances to ASME Section III Code requirements.
Since the issuance of the Order, the Licensee has devoted considerable effort to correcting the problems identified with the project.
One of the first efforts undertaken was to secure the assistance of an outside independent firm, Management Analysis Company (MAC), to perform a diagnostic evaluation of the Marble Hill Project.
This effort was completed with a report issued on October 2, 1979.
This report summarizes the recommended corrective actions needed to rectify the probh.is identified.
The findings of MAC are, in general, consistenc with those identified by the NRC inspections.
Upon completion of the study PSI engaged in the recruitment of additional experienced staff to enable upgrading of the quality assurance program and its implementation.
These steps were intended to improve the construction, project and quality assurance capabili-i ties of PSI's management organization and were considered prerequisites for resumption of construction.
Considerable effort is also being devoted towards the review and examination of existing safety-related construction work.
This is being done to confirm the acceptability of the structures and materials which are in place.
PSI has also reviewed its quality assurance program to make it more effective.
Current efforts include the rewrite of quality assurance / control procedures, as well as the review of its contractors' QA/QC programs, personnel quali-
.fications, and their controls.
A detailed discussion of the efforts undertaken by the licensee is documented in the licensee's report entitled " Description of Licensee Activities Addressing Order Confirming Suspension of Construction" dated February 28, 1980.
This report, enclosed as Appendix B, is currently undergoing review by the NRC staff.
In addition to prog *ammatic related efforts the licensee has continued con-struction work related to non-safety systems and structures.
The Office of Inspection and Enforcement (IE) and the Office of Nuclear Reactor Regulation (NRR) have reviewed the licensee's i
efforts to upgrade his quality assurance program and its imple-mentation.
The licensee's upgrading efforts have resulted in reorganizing and increasing the QA staff with more experienced parsonnel and more firmly asserting its authority and responsi-bility in day-to-day activities including quality control, step work authority, and corrective action.
Although the staff review is still underway, a sufficient upgrading of the docketed QA program has taken place which leads us to conclude that this program can be found acceptable when complete.
In addition, a Public Meeting was. held r, car the site (in Madison, Indiana) on the evening of March 25, 1980 with representatives of IE and NRR and the licensee to discuss the changes that the licensee has made in his quality assurance program.
It was indicated at the public meeting that the NRC would retain a technically f
i.
. qualified consultant to assist the staff in its review of the information generated by the licensee and his contractors regarding the integrity of existing Class I structures.
Selection of the consultant will be made with input from T. Dattilo, counsel for Save-the-Valley Group, provided that the input is available on a timely manner.
The proposed program for restart of construction activities at Marble Hill is described in Appendix C.
Basically, the program requires the completion of all project management hatters before any construction activity can resume.
The first construc-tion activity the licensee wishes to restart is receipt inspec-tion of material received subsequent to the issuance of the Order confirming suspension of safety-related construction.
The restart of safety-related construction would follow, but not before all material verification and all construction verification has been completed and evaluated in accordance with a documented program.
The restart of actual construction activities would be done in stages following the completion of the above prerequisities.
No safety-related construction activity will be permitted to start without the appropriate NRC reviews confirming that the licensee's corrective actions are proper and appropriate.
Also, in accordance with the Commission's Memorandum and Order, dated March 13, 1980, the staff will review statements from the Sassafras Audubon Society and the Knob and Valley Audubon Society to determine if they contain information not already considered or any other information relevant to our decision to lift the order.
The NRC's initial inspection program effort will include a review of the licensee's organization, staff and quality assurance programs.
Prior to allowing receipt inspection the qualification of personnel, the existence of proper procedures, and the establishment of management controls related to that effort will be reviewed.
Close surveillance of these activi-ties will be performed by Region III to measure the adequacy of PSI's revised management program.
Likewise, prior to allowing actual safety-related construction to start, the NRC will review special process procedures, QA/QC controls, the licensee's findings associated with its review of its contractors' programs, as well as its findings related to material and construction verification.
It is intended that the restart of construction would be approved in steps providing the NRC finds that the licensee's corrective actions are judged to be acceptable at J
each stage.
The NRC's step-wise review of the licensee's 1
corrective actions and identified hold points are noted in Appendix C.
j i
The licensee is currently engaged in putting in place the corrective actions discussed in his response to the Order.
The NRC has been engaged in the inspection followup of activities
. related to civil construction and management controls.
The
~
ifcensee has committed to obtaining an ASME Certificate of Authorization ("N" stamp).
The issuance of this "N" stamp is contingent on whether an implementation survey to be conducted By the ASME survey team is found satisfactory.
==
Conclusion:==
From our review of the licensee's response to the Order we have concluded that the licensee has identified the factors that caused the deficiencies in his quality assurance program and its implementation that resulted in the Order.
Based on PSI's improvements in organization and work control measures, planned programmatic corrective actions yet to be made and PSI's attitudinal changes, we believe that sufficient progress has been made by the licensee to consider permitting the licensee to resume safety-related construction activities at the site in a step-wise fashion, beginning with receipt inspection of equipment and materials already located on site.
A number of NRC holdpoints have been established and the licensee will be required to meet all of the prerequisities for each holdpoint.
Upon satisfactory finding that each of the issues are properly implemented, we will permit resumption of construction.
In addition, the services of a highly qualified technical consultant will be retained to assist in the evaluation of integrity of Class I structures.
This approach is based on demonstration of the licensee's ability to effectively imple-ment his revised program, and does not rely on program revision only.
Coordination:
The Office of Inspection and Enforcement and Nuclear Reactor Regulation are in agreement with the licensee's proposed orogram.
The Office of the Executive Legal Director has no legal objection to this matter.
I Victor Stello,/Gr.
Director Office of Inspection and Enforcement
Enclosures:
As stated l
l l
DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations ACRS l
Secretariat
I e
O O
l t
I APPENDIX A I
Appendix A UNITED STATES '0F AMERICA NUCl. EAR REGULATORY COMMISSION OI o l'O / a7 In the Matter of
)O a a
j PUBLIC SERVICE CCMPANY OF INDIANA
)
Docket Hos. 50-545 (Marble Hill Nuclear Generating
)
50-547 Station, Units 1 and 2)
)
j
,D OJDER CONFIRMING SUSPENSION OF CONSTRUCTION 7[ Q U gs 7
I The Pubite Service Company of Indiana (PSI or licensee) is the holder cf Construction Famits, Nos. CPPR-170 and CPPR-171, issued cri April 4,1978.
Tnese pemits authorize in accordance with their provisions. construction of the 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 adeotacy o' the licensee's quality assurance program and, in particular, the adequacy of concrete placement which r.equires escalated enforceir.er.t acticn.
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 nor.ccepliance 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, additional itsas of r.oncompliance were identified.
Another Notice of Violation was issued on May 29,1979, which Criterien X related to inadequate DUPLICATE DOCUMENT
[
detiVities a.s well as a citatior. a Entire document previously entered into system under:
Ear! 33 cr. th! basis of improper C 0.- Jer.e 12, 19 73, The:nas Dat:
No. of pages:
fO e
9
e e
,I
-2 Hill, sent the Director of Nuclear Reactor Regulation a copy of an affidavit by a for::er construction worker at the Marble Hill site who alleged that several honeycombed areas in the concrete had been improperly repaired.
Upon its own investigation of these allegations, the licensee discovered and reported i
on June 21, 1979, defective repairs of honeycombed concrete areas at the site.
Representatives of the Office 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-r gation identified additional areas where concrete had been improperly repaired and i,dentified continued inadequacies in the l'icensee's quality assurance progr'am.
On~ June 26, 1979, representatives of the NRC's Region III office met with the licensee's management to discuss the findings of the'NPC'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 plabe ent 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 prograrp, 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 begun. When the licensee planned to attempt resumption of work on safety-related cencrete on July 17, 1979, the licensee again found inadequate preparation of the placement area, even after the contractor had accepted the area as ready for concrete n
l I
i APPENDIX B e -
A
Appendix B A
, m.:
D O
k O
v s
B:
g/
l r
M PUBLIC SERVICE INDIANA rehruary 2s, 1980
~~
S. W. Sh; elds Vice Prescent E'e:tre System Mr. Victor Stello, Jr., Director Docket Nos.:
STN 50-546 U.S. Nuclear Regulatory Commission STN 50-547 Office of Inspection and Enforcement Construction Washington, D.C. 20555 Permit Nos.:
CPPR-170 CPPR-171 Marble Hill Nuclear Cenerating Station, Units 1 and 2 Order Confirming Suspension of Construction r
Dear Mr. Stello:
On August 15, 1979, the U.S. Nuclear Regulatory Co= mission, Office of Inspection and Enforcement, issued an order confirming suspension of safety-related construction at the Public Service Cocpany of Indiana, Inc.
(PSI) Marble Hill Station.
That order required, as a condition to the i
restart of construction, that PSI submit in writing under oath to the f
Director, Office of Inspection and Enforcement, a description of its revised Quality Assurance Program and the steps taken to assure that u
safety-related construction will be conducted in accordance with 10 CFR
{
Part 50, Appendix 3.
PSI has revised its Quality Assurance Program to be more effective.
PSI has also prepared a report entitled " Description of Lie nsee Activities Addressing Order Confirming Suspension of Construction" dich is appended to this letter.
That report addresses each of the nine points in the Confirming Order, and includes a description of the revised Quality Assurance Program.
PSI has taken positive steps to improve its organization and management capabilities, and t! e number and experience level of i.ts on-site personr.e1.
I PS! has started a review and examination of the work in-place. Results to date indicate such work is sound and acceptable.
Further examination and testing are continuing as described in the atecched report and if any
~
deficiencies in such work are detected, they will be documented, evaluated and properly dispositioned.
f
F PUBUC SERVICE INDIANA Mr. V. Stello, Jr., Dir. February 28, 1980 PSI is confident that w.6u the improvements in its organization and management capabilities, the Marble Hill Project will be completed in accordance with its own high standards of quality and the regulations of the Nuclear Regulatory Commission.
[~
PSI hereby respectfully submits the attached report in response to the i
Comnission's Confirming Order. PSI will promptly submit a request for permissior. to resume the first phase of safety-related work, along with its f
plan for doing sc.
Please advise me if you have questions or need additional information.
Sincere}y, S. W. Shields JB/kss t
Attachment ec: Mr. J. G. Keppler, Director l
U.S. Nuclear Regulatory Commission l
Regioe III 799 Room-~*1t *.:sd Glen Ellen, IL 60137 E. R. Schweibinz, P.E.
m.
J. J. Harrison k.
.e I
h.
/
AFFIDAVIT I, Seth W. Shields, hereby affirm that the materisi contained in this report " Description of Licensee Activities Addressing Order Confirming Suspension of Construction", is true and complete to the best of my knowledge and belief.
l SETH W. SHIELDS i
Vice President - Electric System PUBLIC SERVICE COMPANY OF INDIANA, INC.
STATE OF INDIANA
)
)
SS:
COUNTY OF HENDRICKS)
Subscribed and sworn to before me this M.[ N day of
/ ', 1980.
/ h w?). gX eb,'
Notatp Public y-p My County of Residence: 74 rbe-1 My Commission Expires:
//- 9-M s
e O
4 h
(
l l
l
\\
3
,s n
~
., d O
(QO } ) f, ' 3 [~}
l l
r DESCRIPTION OF LICENSEE ACTIVITIES ADDRESSING ORDER CONFIRMING SUSPENSION OF CONSTRUCTION t
i MAR 3LE HILL NUCLEAR GENERATING STATION PUBLIC SERVICE COMPANY OF INDIANA, INC.
DOCKET NOS. STN 50-546 AND 50-547 p
5 1
d h
P t.
f l
L DUPLICATE DOCUMENT Entire document previously under:
entered into system M
d ANO l,
No. of pages:
/
TABLE OF CONTENTS Page I.
Introduction.
1-1 II.
Revised Quality Assurance Program.
11-1 1
III.
Steps Taken to Assure Safety-Related Work III-l A.
Review of Work Completed.
III-A-1 B.
Results of Independent Audit III-B-1 C.
Description of Staffing and Qualifications.
III-C-1 i
D.
Review of Safety-Related Contracts.
III-D-1 E.
Description of Deficiency Identification and Evaluation.
III-E-1 F.
Description of System to Halt Construction.
III-F-1 G.
Description of Inspection Planning.
III-G-1 H.
Description oi PSI ASME Code Program.
III-E-1 I.
Description of System of Indoctrination.
III-I-l
/
I
%6 1
1 I
w seen 6
I
0 4
, O 9
e n
APPENDIX C
\\
APPENDIX C RESTART PROGRAM MARBLE HILL UNITS 1 AND 2 WITH NRC HOLD POINTS A.
Generic activities which Public Service of Indiana (PSI) must accomplish before any new safety-related construction can occur.
1.
Respond to the specific concerns expressed in the NRR questions relative to the upgrading action and provide a Consolidated Quality
~
Assurance Program description that includes these responses.
2.
Develop Project Quality Assurance Manual (PQAM).
(NRC review currently in progress.)
3.
Develop ASME Quality Assurance Manual (AQAM).
(Completed.
NRC to review for consistency with PQAM.)
4.
Increase project staff and experience levels.
(Essentially complete.)
5.
NRC will review adequacy of PSI program and project staffing actions.
B.
Receipt Inspection - first activity that would be resumed.
1.
PSI has developed project management procedures and qualified its staff for receipt inspection.
1 NRC HOLD POINT 2.
NRC will review PSI's program, procedures, and staffing for receipt inspection.
LIFTING OF ORDER 3.
Assuming results favorable, the " Order Cenfirming Suspension of Safety-Related Construction" would be pa"tially lifted, specifically for receipt inspection, but with provisions to allow restart of actual construction consistent with future satisfactory findings by the NRC.
4.
PSI will start receipt inspection and retain custody of the equipment and materials.
5.
Each contractor is to make adjustments to its QA program, procedures, and staffing for receipt inspection activities.
6.
PSI management would review the above adjustments for receipt inspection activities for each contractor.
l
e' NRC HOLD POINT 7.
By contractor, NRC will review the adequacy of the adjustments noted in item 8.5 and B.6.
8.
Assuming satisfactory finding, each contractor would be allowed to start receipt inspection, and storage and maintenance of PSI equipment and materials.
C.
Material Verification Program (currently in progress and is to be accomplished in parallel with Receipt Inspection).
1.
PSI will complete appropriate project management and special procedures and conduct a Material Verification Program for all disciplines.
The four main disciplines are:
Civil / Structural; Mechanical; Electrical; and Piping.
2.
PSI management will review the Material Verification Program results and inform the NRC.
NRC HOLD POINT 3.
NRC will review the material verification efforts of PSI and confirm adequacy of the program.
D.
Construction Verification Program - Currently in progress and will be accomplished in parallel with Receipt Inspection.
1.
PSI will complete appropriate project management procedures and conduct a Construction Verification Program for all disciplines.
2.
PSI management will review the Construction Verification Program results and inform the NRC.
NRC HOLD POINT 3.
The NRC will review the construction verification efforts of PSI and confirm the adequacy of the program.
E.
Contractors Program Adjustments 1.
Each contractor is to adjust his QA program, procedures, and staffing to be consistent with PQAM, AQAM, and other PSI program requirements for each discipline activity.
2.
PSI management will review the above adjustments of each discipline.
o
,~
~'
. NRC HOLD POINT 3.
The NRC will review the program adjustment for each discipline.
LIFTING OF ORDER (See Item B.3) 1 4.
Assuming satisfactory findings of items (A) through (E), PSI would
)
be allowed to demonstrate their capability to resume construction in each discipline.
(Note:
NRC reviews and construction restarts i
would be done sequentially by discipline).
F.
Unconditional Lifting of the Order After PSI has demonstrated their capability to resume construction in all disciplines, PSI would request a total lifting of the Order.
/!
-