ML19323D655

Responds to NRC Re Violations Noted in IE Insp Repts 50-546/80-03 & 50-547/80-03.Corrective Actions: Responsibility for Storage & Maint of Reactor Vessels Has Been Retained by Util

ML19323D655
Person / Time
Site:	Marble Hill
Issue date:	04/11/1980
From:	Shields S PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19323D645	List: ML19323D655
References
NUDOCS 8005220089
Download: ML19323D655 (13)

Text

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PUBLIC SERVICE i

INDIANA

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iprit 11, 1980

' 4 S. W. Shields

- Vice President - Electr,c System Mr. James G. Kep pl e r Docket Nos..

STN 50-546 U.S. Nuclear Regulatory Commission STN 50-547 Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Dear Mr. Keppler

SUBJECT:

Marble Hill Nuclear Generating Station - Units 1 and 2 In accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, Public Service Company of Indiana, Inc., (PSI) of fers the following information in response to the items of noncompliance identified in Inspection Report 50-546/80-03; 50-547/80-03.

Item of Noncompliance (50-546/80-03-01; 50-547/80-03-01) 1.

10 JFR 50, Appendix B, Criterion IV states in part that, " Measures shall be : stablished to assure that applicable regulatory requirements, design bas :s, and other requirements which are necessary to assure adequate quality are suitable and included or referenced in the documents for procu-ement of mate rial, equipment, and services, whether purchased by the applicant or by its contractors or subcontractor."

The Marble Hill Preliminary Safety Analysis Report, (PSAR) Chapter 17, Section 17.1.4.1 established the same basic criteria as Criterion IV and in addition states that, "a technical re fiew.

shall be conducted by the PSI Project Engineering Group to assure.

technical requirements

.. and "a quality assurance review... by PSI Quality Assurance De sign and Procurement G roup.

.", it should be noted that such reviews were conducted on a " selected basis".

The Marble Hill PSAR Chapter 1, Section 1.7 also cormaits to the intent of Reguiatory Guide 1.38 (March 16, 1973) and therefore to ANSI N45.2.2 (1972); including Section 6 relating to storage and preservation of equipment and material.

Contrary to the above, Public Service of Indiana failed to assign the responsibility to a site contractor for the storage and preservation of the reactor vessels in a pmcurement document.

Therefore an effective program in this area was not established.

It should be noted that during this inspection, field extra work authorizations were issued by PSI to assign this responsibility and control this activity.

APR 141980 1000 East Main Street, Plainfield, Indiana 46168 317. 839.9611 8 0 05 220 64A

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PUBLIC SERVICE WGANA Mr. J. Keppler April 11, 1980

-ii Corrective Action Taken and Results Achieved

' 'F 1.

Responsibility for storage and maintenance of the reactor vessels has been retained by PSI.

Actual performance of storage and maintenance is now being performed by Nuclear Installation Services Company (NISCO) as authorized by Field Extra Work Letter Number One under Purchase Orders 1484-89Q-1 for Unit I and 2182-89Q-1 for Unit 2.

This direction to NISCO further clarified by PSI letter to them dated January 31, 1980.

was Corrective Ac tion to Prevent Recur re nc e 1.

In order to assure that other Safety Category I on-site equipment has been assigned storage and maintenance responsibility, PSI is currently reviewing on-site equipment and assuring assignment.

Date When Full Compliance will be Achieved 1.

This activity is expected to be complete by July 15, 1980.

Item of Noncompliance (50-546/80-03-2; 50-546/80-03-02) 2.

10 CFR 50, Appendix B, Criterion V in part requires that, " activities af fecting quality shall be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

The Marble Hill Preliminary Safety Analysis Report Chapter 17, Section 17.1.5.1 states in part that, " PSI requires each contracting organization to develop and implement written instructions, procedures, or drawings for performance of all quality related activities.

Clear delineation of the sequence of action to be accomplished in the preparation, review, and cont rol of instructions, procedures, and drawings is provided by a PSI quality assurance procedure and is required of all PSI contractors."

It further states that, " PSI shall verify the existence and satisfactory implementation of required instructions, procedures, and drawings through its audit and surveillance programs (internal and external).

Contrary to the above, approved and controlled procedures were not available relative to the storage and preservation of equipment such as the Reactor Vessel Heads, Reactor Vessels, and Reactor Vessel Internals, i

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[.hl PUBUC SERVICE INDIANA Mr. J. Keppler April 11, 1980

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Corrective Action Taken and Results Achieved

. g 2.

Detailed instructions for storage and maintenance of the reactor vessels per CMP 4.2 were issued January 29, 1980.

(CMP 4.2 superseded by PMP 6.03).

These instructions included manufacturer recommendations.

Maintenance on the reactor vessels was performed on Feb ruary 4 and 5, 1980, using these inst ructions.

NISCO's procedures for storing and maintaining the reactor vessel lower internals were approved on February 5,1980.

NIS00's procedures for storage and maintenance of the reactor vessel heads is currently being reviewed by PSI.

In the interim, maintenance is being performed by NISCO

'l at PSI's direction.

Cor rective Action to Prevent Recur renc e 2.

A new procedure for the development and distribution of Storage and i

Maintenance Instructions, Project Management Procedure (PMP) 6.03 was j

developed and issued on March 8,1980.

This PMP is currently being 1

implemented, and the first set of Storage and Maintenance Instructions developed under this procedure was transmitted to site contractors on Ma rch 24, 1980.

Date When Full Compliance will be Achieved 2.

This activity should be complete by July 15, 1980.

Item of Noncompliance (50-546/80-03-03, 50-547/80-03-03) 3.

10 CFR 50, Appendix B, Criterion X in part requires that, "A program for inspection of activities af fecting quality shall be established and executed by or for the organization performing the activity to conformance with the documented instructions, procedures, and drawings for accomplishing the activity".

The Marble Hill Preliminary Safety Analysis Report Chapter 17, Section 17.1.10.1 states in part that, " Inspection programs shall be established and implemented by or for contractors performing activities affecting the quality of safety-related products or materials.

. Inspections or tests are performed for each work operation as necessary to verify quality...

PSI shall verify adherence to procedures and instructions by construction contractors for inspection through surveillance.

Surveillance of storage and storage maintenance is required to be in accordance with Marble Hill Generating Station Construction Management Manual Procedure CMP 3.4.

-d fi sts' pusuc SERVICE INCHANA Mr. J. Keppler April 11y 1980 1

Contrary to the above, Public Service of Indiana failed to implement an

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adequate inspection program in that:

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a. Inspections were not conducted on a periodic basis as required by CMP No. 3.4, Section 4.1 and/or on a scheduled basis as required by Section 4.2.

b. Inspections conducted did not include observation of special storage conditions as required by CMP No. 3.4, Section 4.1; i.e., nitrogen purges; desiccants. This includes equipment / material stored by PSI and contractors.

Several surveillance reports and checklists were reviewed and the applicable sections for desiccant and purges were 1

noted and were marked ("NA" not applicable).

c. Th e inspections (surveillances) that were conducted failed to address j

the full scope of the inspection activity, for example, the surveillance reports related to storage of the reactor vessels and steam generators only reported conditions of the laydown areas in which this equipment was being stored and did not include inspection of the actual equipment.

Corrective Ac tion Taken and Results Achieved

3. a.

PSI Quality Assurance has increased surveillance of storage and maintenance of storage of safety-related items in PSI and the contractors custody.

Surveillance of the Reactor Vessels, Vessel Heads and Internals has been perfonmed by PSI to approved checklists since January,1980.

Cherne Contracting Company has performed continuing surveillance of the Steam Generators for Unit I using approved procedures.,

b. Generic checklists for surveillance of items in storage and their maintenance, and storage and laydown areas have been prepared by PSI Quality Engineering for use by Inspection personnel. These checklists were issued March 11, 1980, and are being used for the surveillance described in 3.a. above.

c. The generic checklists referred to above provide more detail as to the scope, and level of surveillance of storage and storage maintenance.

Corrective Ac tions to Prevent Re currence

3. a.

PSI Quality Engineering Section, in accordance with PNT 3.05 will prepare detailed surveillance plans and checklists for surveillance of storage and storage maintenance.

These checklists will reflect the requirements of the Storage and Maintenance Instructions which were issued to contractors March 24, 1980, and refered to in Item 2 of this re sponse.

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j Pusuc SERVCE INCHANA Mr. J. Keppler April 11 1980 z

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b. The storage and storage maintenance checklists will define the specific characteristics to be verified based on the Storage and Maintenance

_ gp Inst ructions provided to contractors.

The acceptance criteria will be identified by the checklists.

c. A review of the NISCO Quality Assurance Program relative to storage inspection plans and procedures will be conducted prior to the implementation of NISCO's storage and maintenance programs.

Dates When Full Compliance will be Achieved 3.

a. - 3. c.

PSI Quality Engineering is commencing preparation of storage and storage maintenance checklists based on the Storage and Maintenance Instructions to be issued by Material Controls.

The PSI Storage and Storage Maintenance Surveillance Program will be fully implemented based on the full implementation of the Material Management Program which is scheduled for July 15, 1980.

Item of Noncompliance (5-546/80-03-04; 50-547/80-03-04) 4.

10 CFR 50, Appendix B, Criterion XIII in part requires that, " Mea su re s shall be established to control the handling, storage, shipping, cleaning, and preservation of material and equipment in accordance with work and Inspection Instructions to prevent damage or deterioration.

Marble Hill Preliminary Safety Analysis Report Chapter 17, Section 17.1.13 states that, " PSI Quality Program Manual includes procedures governing the handling and storage of owner furnished materials at the construction site.

Instructions will be developed by the PSI Marble Hill Construction Organization to supplement special procedure and requirements issued by the suppliers and principal contractors. The PSI Quality Assurance specification governing principal contractors and contractors provides for passing applicable requirements on to their subcontractors and suppliers as appropriate.

The Marble Hill Generating Station Construction Management Manual Procedure Number 4.2, " Storage and Handling of PSI Purchased Materials" establishes storage and handling requirements.

Contrary to the above, Public Service of Indiana failed to comply with these requirements relative to storage and preservation in that:

'1[i' PUBUC SERVICE INDANA Mr. J. Keppler April 11,1980

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a. Storage instructions were not provided for all equipment.

Those which

- er were prepared were not completed in a timely manner, as required by Procedure Number 4.2, Section 4.1.6 for the equipment with special storage and preservation requirements. Adequate and timely procedures for Units 1 and 2 Reactor Vessels, Reactor Vessel Heads, and Unit 1 Steam Generator and Pressurizer were not available and are examples of this finding.

b. Storage instructions required by Procedure Number 4.2, Section 4.1.6 were deficient in that the equipment manufactorer's requi rements,

recommendations, and inspection plane were not included.

This is exemplified by the procedures for the Units 1 and 2 Reactor Vessels and Reactor Vessel Heads and Unit 1 Steam Generators and Pressurizer.

c. Procedure CMP 4.2 does not clearly establish how Storage and Handling Instructions are transmitted or communicated to the site contractors responsible for storage and preservation activities.

d. The storage instructions written in accordance with Procedure Number 4.2, Section 4.1.6 for Unit 2 Reactor Vessel were deficient in that the applicable " Additional Storage" attributes were not identified.

Corrective Action Taken and Results Achieved

4. a.

Storage instructions will be provided for all owner furnished equipment per PMP 6.03 to responsible Site Contractors who, in turn, will develop their own storage and maintenance procedures.

PSI issued the majority of the instructions for Safety Category I equipment to Site Contractors on March 24, 1980. This issue included the Reactor Vessels, Reactor Vessel Heads, Pressurizers, and the Residual Heat, Removal Heat Exchangers. Instructions for the Chemical Volume Control Tanks and the Steam Generators are under development.

b. PMP 6.03 requires PSI Engineers to use the manufacturers' recommendations in developing the Storage and Maintenance Ins t ruc t ions.

This procedure was issued for use March 8,1980 and t raining on its implementation has been held.

c. PMP 6.03 addresses how distribution is made to the Site Contractors.

d. The training held on PMP 6.03 emphasized the need for all storage instructions prepared under this new procedure to be clear and explicit.

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pusuc SERVIC:E lNQANA Mr. J. Keppler April 11:, 1.980 Corrective Action to Prevent Recurre nc e

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. 4. a. - d.

In order to prevent recurrence, PSI has completely revised its storage and maintenance program.

CMP 4.2 has been replaced by PMP 6.03.

PMP 6.03 covers the problem area of the old procedure as follows:

1.

Instructions are to be prepared prior to off-loading equipment.

2.

Manufacturer's instructions are to be used in preparing Storage and Maintenance Instructions 3.

The Materials Manager is responsible for issuing Storage and Maintenance Instructions to the organizations responsible for storage and maintenance.

Date When Full Compliance will be Achieved 4 a. - d.

This activity is currently under going implementation.

The Material Management Storage and Maintenance Program is expected to be fully functional by July 15,1980.

Item of Noncompliance (50-546/80-03-05; 50-547/80-03-05) 5.

10 CFR 50, Appendix B, Criterion XV and the Marble Hill Preliminary Safety Analysis Report, Chapter 17, requires in part that, " Measures shall be established to control materials, parts, or components which do not conform to requirements.

. These measures shall include, as appropria t e, procedures for identification, documentation, segregation, di s pos it ion, The Marble Hill Preliminary Safety Analysis Report Chapter 17, Section 17.1.15 also states that, "The PSI Quality Assurance Program provides for control of nonconforming items discovered by PSI."

The Marble Hill Generating Station Construction Management Manual Procedure 3.1, " Control of Field Nonconformances", establishes measures for control of the subject documents.

Contrary to the above, Public Service of Indiana failed to comply with these requirements in tha t:

PUBUC SERVICE INDIANA Mr. J. Keppler April 11, 1980

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Procedure CMP 3.1 provides a dual system for reporting field a.

nonc onfo rmanc es.

Section 4.2 addresses use of Field Corrective Action W

Request (FCAR) for those " Discrepancies or concerns...

that are not significant in nature.

." Section 4.3 addresses the use of Deviation Control Record (DCR) to report... a deficiency or nonconformance relating to a construction phase.

." However, nonconformances of a significant nature were reported on a FCAR in lieu of a DCR; as re quire d.

FCAR Number 253 and Number 290-79 are examples of this misapplication.

b. The description of the Discrepancy / Deviation on the FCAR's and DCR's failed to accurately identify the nonconformance substance as required by Procedure CMP 3.1, Sections 4.2 and 4.3.

Therefore, proper Corrective Action was compromised.

For example, FCAR Number 253 was inaccurately reported leading to ineffective Corrective Action.

c. FCAR's were not being processed as required by Procedure CMP 3.1, Section 4.2.3 thereby compromising the PSI Construction Engineering, Design Control Supervision and Quality Engineering Departments ability to perform engineering and quality evaluations.

The responsibility of

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these organizations was not clearly stated in this procedure.

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numerous cases, the same individual (Quality Control Inspector) was the FCAR Initiator, Corrective Action Initiator, and Quality Control Representative verifying Corrective Action. Many of these Corrective Actions were inadequate.

Corrective Action Taken and Results Achieved 5.

a. The PSI Quality Assurance Program was revised and issued as the Marble Hill Project Quality Assurance Manual, Revision 0, in February,1980.

This program change reduced the number and types of PSI forms used to document deficiencies from four (4) to two (2) - a Correction Action Request (CAR) and a Nonconformance Report (NCR).

The use of these two forms is dependent upon the type of inspection being performed and not on the significance of the finding.

b. The Main Coolant Loop Stop Valves (FCAR Number 253) have been moved from outdoor, Level D Storage into indoor Level B Storage, uncrated as necessary, and dried out as reported in PSI's letter of March 10, 1980.

c. PSI has reviewed Nonconformance Reports (Field Corrective Action Requests, Deviation Control Records, etc..) issued by or submitted to

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PSI at the Marble Hill Site prior to the date of the NRC Confirmh.s Order. The Nonconformance Reports on file were reviewed by :. embers of PSI's Project Engineering, Construction, and Quality Assurance Staff.

PUBUC SERVK:E mKMANA Mr. J. Keppler April 11,1980

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Further details of this review are contained on Page III-A-6 of PSI's,"

Description of Licensee Ac tivities Addressing Order Confirming

'y Suspension of Construction" dated February 28, 1980.

Corrective Ac tion to Prevent Re cur re nc e 5.

a. In addition to revising its Quality Assurance Program to reduce the number of forms used to document discrepancies, PSI has also modified its Quality Assurance Program to require Nonconformance Reports (NCR) and Corrective Action Requests (CAR) to be reviewed by an appropriate discipline Quality Engineering Group headed by a Superintendent.

This provides a review of discrepancies initiated by Inspection personnel by technically trained and experienced Quality Engineers.

b. To assure documentation of deficiencies accurately reflect conditions not met, a Quality Engineering Section has been established within the PSI Quality Assurance Department.

Quality Engineering is responsible for development of inspection and surveillance plans or checklists.

The plans and checklists shall contain detailed acceptance and/or rejection criteria for characteristics to be inspected.

In addition, PSI Inspection personnel have been trained in the use of surveillance / inspection checklists and are qualified in accordance with the requirement of ANSI N45.2.6 prior to assignment to inspection or surveillance activities.

PSI is also developing a Material Management Program as described in PSI's letter of March 29, 1980.

The Material Management Program will assure maintenance instructions are prepared to specify appropriate storage and maintenance criteria.

These defined criteria together with prepared checklists will assure more detailed descriptions of requirements are available to inspection personnel for purpose of verifying adequacy and documenting discrepancies.

c. PSI's revised Quality Assurance Program as implemented by PMP 1.07,

" Control of Nonconformance" which requires review of PSI Nonconformance Reports and Corrective Action Requests by the newly established Quality Engineering Organization.

The purpose of these changes is to assure adequate review of Corrective Actions by qualified personnel.

Date When Full Compliance will be Achieved 5.

a. PSI Quality Assurance Program changes to reduce the number of discrepancy forms is complete.

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PUBUC SERVICE INDIANA Mr. J. Keppler April 11, 1980

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b. The PSI Quality Engineering Section has been established and is preparing Inspection Surveillance Checklists. As reported in PSI's

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letter of March 29, 1980, the PSI Material Management Program should be

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fully implemented by July 15,1980.

PMP 1.07 has been issued for use and training has been conducted on its c.

PMP 1.07 may be revised, as necessary, during its implem,entation uses.

to assure ef fective control of nonconformances.

Item of Noncompliance (50-546/80-03-06; 50-547/80-03-06 6.

10 CFR 50, Appendix B, Criterion XVI requires that, " Measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, d.ficiencies, defective material, equipment, and nonconformances were promptly identified and corrected.

In case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and Corrective Action taken to preclude repetition.

The identification of the significant condition adverse to quality, the cause of the condition and the Corrective Action taken shall be documented and reported to appropriate levels of management.

The Marble Hill Prelimincry Safety Analysis Report Chapter 17, Section 17.1.16 states that, "Canditions adverse to quality may be identified through PSI review of do uments, conduct of surveillance, performance of audits, and conduct of prioperational and startup testing. Failures, malfunctions, deficiericies, deviations, defective materials and equipment, and nonconformances identitied by PSI shall be documented on PSI Deviation Control Records by the cognizant PSI Reviewer, Auditor, or Inspector.

Corrective Action measures are required by Marble Hill Generating Station Construction Management Manual Procedure CMP Number 3.1, " Control of Field No nc onfo rmanc'e s".

Contrary to the above:

a. Reporting of significant nonconformances, in accordance with Procedure Number CMP 3.1, Section 4.2, (issuance of the Field Corrective Action Request, FCAR) was inadequate in that a mechanism was not available to (1) identify the cause of the condition; (2) provide action to preclude repetition, and (3) report to appropriate levels of management.

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i PUBUC SERVCE INEMANA Mr. J. Keppler April 11,, 1980

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b. Corrective Action taken in response to Field Corrective Action Requests c,y (FCAR's) as required by Section 4.2.3, failed to adequately address the subject of the nonconformance, i.e., FCAR 190-79 dated August 15, c

1979. Moreover, neither Project Engineering Departments were involved in the Corrective Action process.

c. Numerous Nonconformance Reports (twenty-five) were found wherein the Corrective Action was not timely or expeditious as is required by Proceda e Number CMP 3.1, Section 1.0.

Considerable time passes with no actions taken or the actions taken were incomplete.

Some of these issues were "open" for four to twelve months for no apparent reason.

For example, FCAR Number 364-79 dated September 11, 1979 anc FNR Number 083 dated October 17, 1978 has not been resolved.

Corrective Action Taken and Results Achieved 6.

a. As described in 5.c. above, PSI has reviewed Nonconformance Reports issued by or submitted to PSI at the Marble Hill Site prior to the date of the NRC Confirming Order.

Results of this review are described in PSI's, " Description of Licensee Activities Addressing Order Confirming j

Suspension of Construction," dated February 28, 1980.

Documentation of deficiencies on a Field Correction Action Request was suspended with issuance of the Marble Hill Project Quality Assurance Manual in i

Feb ru ary, 1980.

b. The Unit I Reactor Vessel desiccant indicator "as changed and the desiccant replaced in February,1980 (FCAR 19G-79). As reported in PSI's letter of March 10, 1980, NISCO has been assigned the storage and maintenance scope for thest components although PSI currently retains responsibility as set forth in Item 1 above. Manufacturer's recommendations have been transmitted to NISCO, and a detailed physical reinspection of the reactor vessels for both units has been completed.

Also, as described in 5.c. above, PSI's revised Quality Assurance Program and procedures requires review of PSI initiated CAR's and NCR's by the PSI Quality Engineering and Project Engineering organizations.

c. FNR Number 083 of October 17, 1978 was closed on February 18, 1980.

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FCAR Number 364 was closed on February 16, 1980. FCAR Number 425-79 was closed on April 7, 1980 and FCAR 1505-79 was closed on March 5, 1980.

To assure timely close out of past deficiencies PSI is arranging for the assignment of personnel whose primary responsibility is the follow-up of deficiency reports.

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y PUBUC SERVICE Mr. J. Keppler April 11;, 1980 Corrective Action to Prevent Recurrence s'

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a. As described above, the revised PSI Quality Assurance Program reduced the number of forms used by PSI to document deficiencies to a Corrective Action Request (CAR) and a Nonconformance Report (NCR).

Both of these forms require documentation of cause of deficiencies and action to prevent recurrence. The revised PSI Quality Assurance Program and implementing PMP 1.07 will require review of CAR and NCR forms by the Quality Engineering organization.

This review assures technically trained and experienced personnel review such reports,

b. To assure documentation of deficiencies accurately reflect conditions not met, a Quality Engineering Section has been established within the PSI Quality Assurance Department. Quality Engineering is responsible for development of detailed inspection and surveillance plans or checklists to be used by PSI Inspection Personnel. These plans and checklists shall contain acceptance and/or rejection criteria for characteristics to be inspected.

Training shall be given to inspection personnel on the proper methods of documenting deficiencies.

Quality Engineering additionally reviews NCR's and CAR's for completeness of description and approves the adequacy of Corrective Actions taken.

c. A quality Tracking and Trending Program was developed and reports issued to Quality Assurance and construction personnel in March, 1980.

This program provides status lists which assist in follow up of overdue responses to deficiency reports. Training on the use of the reports j

for deficiency report follow up was completed in April, 1980. Proposed modifications to the program to make the use of status reports more effective are being considered and will be developed as necessary.

As described above PSI is arranging for the assignment of personnel with the primary duty of follow-up on overdue responses and close outs of deficiencies.

Date When Full Compliance will be Achieved

6. a.

The revised PSI Quality Assurance Program and PMP 1.07 have been issued for use and will be revised as necessary during implementation.

b. The PSI Quality Engineering Section has been established.

Ij Pusuc SERVICE INDIANA Mr. J. Keppler April 11, 1980 6-I

c. PSI will provide an updated status of modifications to the

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nonconformance Tracking and Trending Program and completion of report close outs by May 30, 1980.

Sincer ly, 1

S.W. SHIELDS 4

i CEC /dks cc:

J.J. Harrison E.R. Schweibinz, P.E.

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