ML20041D714
| ML20041D714 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 02/12/1982 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Hamilton L HOUSE OF REP. |
| Shared Package | |
| ML20041D715 | List: |
| References | |
| NUDOCS 8203090010 | |
| Download: ML20041D714 (3) | |
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NUCLEAR REGULATORY COMMISSION g4
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PE82519822-Ei The Honorable Lee H. Hamilton 8gm.um eng, United States House of Representatives
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Dear Congressman Hamilton:
This is in response to your November 6, 1981 letter which posed questions related to the NRC decision to allow safety-related construction wcrk to resume at the Marble Hill nuclear facility in Madison, Indiana.
We do not believe that insufficient information was used in allowing safety-related construction work to resume at the Marble Hill nuclear facility.
The Commission has reviewed the June 26, 1981 decision and December 2, 1981 supplemental decision by the Director of the Office of Inspection and Enforcement, that denied a petition submitted by Save the Valley.
The petition requested withdrawal of the authorization to Public Service Company of Indiana to resume concrete work at the Marble Hill project.
As part of the Commission's review of the decisions, the comments of Dr. Michael Cassaro, consultant to Save the Valle'y, were reviewed.
We agreed with Dr. Cassaro's contention that the sequential sampling plan devised by Sargent and Lundy to evaluate the quality ~of concrete in structures at Marble Hill was in fact, in error; however a more stringent plan was implemented.
The staff's review of the decisions is presented in Enclosures 1 and 5.
The results of the more stringent plan, no observed defects in over 1400 tests conducted in 60 locatio'ns, met the acceptance criteria.
We have concluded that, in spite of the error in the sampling plan,.the results of the testing program provided the desired assurance (95 percent confidence of 95 percent reliability) that the concrete.
quality meets requirements.
Your letter also included several questions which we have chosen to group together in supplying the following answers:
1.
Question:
"...what is wrong with the ultrasound tests which NRC reviewed...
Please include in your discus-sion a clear and concise explanation of both the testing procedures themselves and the mathematical insufficiency described by Dr. Cassaro."
8203090010 820212 PDR COMMS NRCC CORRESPONDENCE PDR
The Honorable Lee H. Hamilton 2
1 Answer:
We have found nothing wrong with the ultrasound (ultrasonic) tests reviewed or with the conclusions thet have been drawn from those tests.
Details of Dr. Cassaro's mathematical concern and a description of the testing procedures are provided in Enclosures 1 and 2.
1 II.
Question:
"How is it that this insufficiency _was not recognized immediately?
Who was responsible for the failure to recognize it?
Was there any abuse of discretion in the decision which allowed safety-related construction to move forward?"
Answer:
The error was not discovered during our initial review of the sampling plan.
The error was brought to our attention by Dr. Cassaro in September 1980.
Remedial action was not taken at that time since a more stringent plan was implemented.
We accept responsibility for failure to discover the error during our initial review of the sampling pian.
All decisions to allow resumption of work were in ahcordance with the document, " Graduated Rescission to the August 15, 1979 Order" issued by the Director of Inspection and Enforcement on May 15, 1980 (Enclosure 3).
These decisions were based on extensive and well-documented inspection activities and multiple level reviews by the NRC staff.
We find no abuse of discretion in any decisions made during this process.
III. Question:
"What options are open to the NRC to rectify the problem?
Will more tests have to be performed to ensure that the facility is safe?
Will different kinds of tests be ordered?
Will a decl.aration that the tests were sufficient address the objection that the facility is unsafe because prior standards were not met?"
Answer:
We find that no standards were changed and that the nondestructive (ultrasonic) tests, destructive examinations, surface examinations, and concrete quality control records provide adequate assurance that the concrete structures at Marble Hill meet NRC requirements.
Therefore, no further testing is necessary.
Region III's inspection efforts regarding this matter are summarized in IE inspection reports.
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.(Enclosure 4).
1
6 The Honorable Lee H. Hamilton 3
If you have further questions on this matter, please do not hesitate to contact me.
Sincerely, dbek'
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liunzio J. Palladino
Enclosures:
1.
Memo f ra F. Remick to Comm, dtd 9/10/81 2.
Supplemental Decision under 10 CFR 2.206 (DD-81-22) 3.
Graduated Rescission of 8/15/79 Order 4.
Inspection Rpt Nos. 50-546/
81-18 and 50-547/81-18 5.
liemo fm F. Remick to Comm, dtd 12/18/81
, Enclosure i
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September 10, 1981 MEHCPJ,fiDui FOR:
Chairman Palladino Commissioner Gilinsky>
Commissioner Bradfordi Commissioner Ahearne Commissioner Roberts
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Forrest J. Remic e
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SU3 JECT:
REVIEW OF DIRECT 0P'S DENI AL; 0F 2.206 PETITI0ft (SECY-81-445)
As requested by Comissioner Bradford 15 his memorandun, of August 21, OPC has reviewed Pro # esso-Cassaro's September 26, 1980 and March 4, 1981 comments and the staff's response:.
Based:en the following corxnents, we recommend that, before reachinD a decision on your review of the Director's denial, the matter be referred to the staff for further study
'of certain questions we have identified'concerning the test and evaluation program for assuring that the concrete. placement at Harble Hill meets liRC requirements.
Statistical Methodology for Sampling Profer.sor Cassaro is correct in his mathematical argument that the assurance inherent in Sargent and Lundy's ($&L) ' acceptance sampling plan, which formed the statistical basis for testing the quality of concrete in structures at Marble Hill, is not compatible with the "95 percent confidence
[of] 95 percent reliability" criterion (denoted < henceforth as 95/95 assurance criterion; this is equivalent to having 95 percent confidence that no more than 5 percent of the concrete < areas are defective) that the staff specified on June 27, 1979 (Enclosure 1). Apparently, S&L mistakenly applied calculations suitable.only for single-stage sampling (see S&L's procedure and stated reference (Ang and Tang) on page 5 of Volume I of the S&L report).
To satisfy.fiRC's criterion, sample sizes for each of the four stages in the sarrpling plan should have been larger
--perhaps by as much as 10 or 20 test areasiper stage, depending on the exact schemt chosen.
As verified independently by MPA calculations, S&L's sequential sampling plan (pages 5-8 of Volume 1, SL-3753, Revis. ion 1, November 21,1980),
which would have allowed as many as 3 defectives, m ld provide only about 90 percent confidence of 95 percent reliatility.
In comparison C0i;T ACTS:
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Commission 's with single-stage plans, a multiple-stage sampling approach requires a potentially larger total sample size.
However, since actual observations may lead to early termination of the plan, sequential sampling plans on an average result in smaller numbers of observations than comparable single-stage plans.
It is important to note that had a single-stage plan instead been implemented, the cbserved results (no defectives in 60 tests) would have provided 95/95 assurance. Mnreover, we note that "a substantial amount of engineering judgment was used to conservatively bias the sample selection." Sll took a stratified random sample with observations weighted heavily to
, strata with a higher potential for fai. lure, where half of the 60 observations were drawn as representative of areas which are congested by reinforcing steel and the embedment arrangement, and which have greater potential for discontinuities.
Hence, if an appropriate.4-stage sample had been used, 95 percent reliability could have been assured w1th a confidence actually
~greater than 95 percent--particularly in view of measurement replication and follow-up measurements.
In any case, NRC made no apparent specific allowante for test error on top of sampling error when it set the 95/95 criteria.
Accounting for Huma'n and Instrument Error A principal concern of Professor Cassaroiwas that NRC's 95/95 criterion could not have been satisfied by SLL's' methodology because their calculations did not includ. the effects of residual human error and instrument error in the test program.
Note that in Professor Cassaro's letter of March 25, 1981 (Enclosure 2) he stated, "It appears that no written qualification exists in the record at Marble Hill."
2" The staff's response of March 20, 1981 along this line appears to accurately reflect the microseismic testing program described in S&L's report-.
particularly in regard to how to identify, categorize.and evaluate the test areas as being solid, explainable'or questionctle.
Procedures included specific steps to detect the presence, if 'ry, of unacceptable discontinuities in the 60 areas tested (i.e., applying pulse-echo testing; review of drawings and construction records'for correlation with pulse-echo test data; and follow-up coring, as needed). The staff's letter 6f July 22, 1981 (Enclosure 3), furthermore, elaborated substantially on SLL's measurement technique and evaluation methodology--including the fact that a qualification test and record for the microseismic testing technique does exist at Marble Hill, as documented by an NRC inspection
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report.
Qualification tests are also documented in the S&L report.
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Co cission 4 Accordingly, a substantial ef fort was made to minimize human and instrument error.
Professor Cassaro's reservations could have been justified only if the procability of misclassificatico (in this case, failure to recognize a defective area as such) was not negl<igible.
(For a non-negligible test error, which is apparently not the case, the probability of misclassification would have otherwise been, in Professor Cassaro's words, " conjoined with the probability of finding defective concrete in the S&L plan."
Finally, we understand that, with regard to another of Dr. Cassaro's concerns, a copy of the final report of the.fRC consultants, Ham and Parme, dated June 25, 1981, was received by IE in time for consideration in the Director's. Denial on June 26, 1981.
Ham and Parme supported the SLL report conclusions.
(Enclosure 4 is a. copy of the consultant's final report, which was forwarded to Public Service of Indiana on July 1, 1981.)
Possible flext Steps The staff's conclusion in its letter of' March 20, 1981 to Professor Cassaro, "that the required reliability and confidence can be demonstrated by the methodology described in the S&L revised. report," is not fully suppertable, since S&L's statistical methodology for selecting the number of rcndom sampics in a stepwise approach was. incorrect. S&L's sequential
'snpling plan could provide only about 90/95 assurance.
We' considered whether S&L should be required to correct its documented sempling plan and draw corresponding. additional samples.
Arguing against such a step is the fact that NRC staff.did approve the 4-stage S&L sampling plan and, with that approval, it in effect (unwittingly) changed the-assurance criterion to 90/95.
In any event, the sample appeared to be appropriately collected and treated and no significant defects were found.,Therefore, in spite of an apparent shortcoming in S&L's 4-stage, sampling plan methodology, NPC's best estimat.e today--based on available information and in the ccntext of a 1-stage sampling plan--is that there is 95 percent assurance that no more than 5 percent of in-place concrete units are defective (or, in the staff's terminology, 95 percent confidence of 95 percent reliability).
Thus, although 55L apparently made a mistake in its sampling plan, it is not, clear to us that that mistake is significant enough to justify altering the Director's Denial.
The Comission itself could decide, for example, that results from the S&L sample nevertneless provide, as discussed above, sufficient confidence and reliability on the basis (retrospectively) of a single-stage sampling approach.
However, it could be that we have not identified all relevant factors, and it seems to us better to let j
the staf f attempt to deal with and clarify the matter before the Comissic, takes a position.
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Cor:r ission
-4 5-P.ecommendat io_n i
OGC believes it is arguable whether the cited problem with the decision-requires Co1 mission review under the usual Indian Point standard in light of the indication above that the~ difficulty is not significant'.
However, the Coccission, if it chooses; couldipursue this matter in exercising its supervisory authority over staff. See 10 CFR 2.206 (c) (1).
On balance, we recomend that you exercise this supervisory authority and (1). hold up your decision on the Director's Der.ial; and (2) refer to staf f for ixamination with all parties, in light. of STV's July Addendum, the.~ confidence level achievable by S&t.'s; documented sampling plan.
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Enclosures:
As; stated cc:E Samuel Chilk..
. William Dircks
- Victor Stello i' Harold Denton Harold Bassett 3
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00-81-22 UNTTED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Richard C. DeYoung, Director In the Matter of
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PUBL.IC SERVICE COMPANY
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Docket Nos. STN 50-546 0F INDIANA
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STN 50-547 (Marble Hill Nuclear
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Generating Station, Units 1 & 2)
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SUPPLEMENTAL DECISION UNDER 10 CFR 2.206 On June 26, 1981, a decision was issued under 10 CFR 2.206 (DD-81-10,13 NRC
)
that denied a petition filed by Save the Valley which requested withdrawal of the authorization to Public Service Company of Indiana (PSI) to resume concrete work on the Marble Hill project.
After considering the bases for Save the Valley's request and other information related to the examination of the quality of concrete in the project as well as the improvements made in PSI's construction pror, ram, Save the Valley's petition was denied.
As part of the Commission's review of the decision, the Office of Policy Evaluation (OPE) was asked to review the comments of Dr. Michael Cassaro, a consultant to Save the Valley, regarding the statistical model which Sargent and Lundy had used in establishing a sampling plan for testing the quality of concrete in structures at the Marble Hill project.
Dr. Cassaro stated that the sampling plan contained an error which had not been identified by the staff.
In its review, OPE confirmed that
.the sequential sampling plan devised by Sargent and Lundy was in fact in error.
The staff concurs in OPE's analysis of Sargent and Lundy's sequential sampling plan.
However, in effect a far more stringent sampling plan was implemented, with the result that the test findings (over 1400 readings in 60 areas with no observed defects) more than achieved the stated criterion.
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OPE has therefore, determined that the results of the testing program performed t
i achieved the desired assurance (95% assurance of 95% reliability) that the j
concrete quality meets NRC requirements.
Because the Sargent and Lundy l
sequential sampling plan could have affected the staff's conclusions regarding the quality of the concrete, the Commission asked "whether the assurance achievable from the test and evaluation program at Marble Hill meets NRC critoria in light of Save the Valley's July Addendum [to its petition] and OPE's memorandum of September 10, 1981".1 i
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This supplemental decision reflects the results of the staff's review in 5
response to the Commission's request.
In conducting this review, the Staff has
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also considered, in addition to the two documents ment _ioned above, a letter dated August 5,1981, from Save the Valley's counsel to the Commission.
In response to the Comrrission's request, copies of the OPE evaluation and the Commission decision were transmitted to Save the Valley, and to PSI, soliciting j
their comment.
PSI responded by letter dated November 2, 1981.
Save the Valley provided a response dated November 4, 1981.
The content of these submissions has been considered in developing this supple-mental decision.
The conclusion is that had a single-stage sampling plan been implemented, the observed results would have provided the required 95% assurance of 95% reliability.
Therefore, for the reasons stated in this supplemental 2 Memorandum for W. J. Dircks, Executive Director for Operations, from S. J.
Chilk, Secretary (Oct. 5,1981).
A copy of this memorandum and all other documents referred to in this decision are available for public inspection in the Commission's public document room in Washington, D.C., and the local public document room in Madison, Indiana.
..s
, decision, additional concrete sampling is not necessary or warranted to assure acceptable confidence in the quality of concrete in the Marble Hill structures.
Sarg'ent and Lundy developed the testing program for PSI.
PSI had committed to provide assurance through statistical sampling that the concrete's quality was acceptable.
Region III had confirmed PSI's commitment in a'n Immediate Action The Immediate A' tion Letter did not specify a Letter dated June 27, 1979.
c particular sampling method or program, but asked that the testing demonstrate adequate quality of the concrete by achieving 95% assurance of 95% reliability.
As stated above, the sample tested has verified that the concrete quality does achieve the stated goal.
The test results more than achieved the stated criterion.
The Sargent and Lundy sequential sampling plan required a first stage of 59 statistically independent readings, a second stage (if necessary) of,34 additional readings, etc.
As the plan was implemented 60 sample areas were tested at several overlapping locations for a total of over 1,400 separate microseismic tests for the 60 areas.
Even though not all these may be statistically independent readings, there were clearly far more than the equivalent of 60 independent readings.
Hence, with no observed defects, the acceptance criteria of 95% assurance of 95% reliability has been far exceeded.
In Save the Valley's July Addendum and its. August letter to the Commission, Save the Valley argues that Sargent and Lundy's testing program is unable to achieve the required confidence level because the effects of instrument error
and human error are not included in the test program.
Region III has previously I
respon'ded to this concern in letters dated March 20 and July 22, 1981, to Dr. Cassaro, Save the Valley's consultant.2 The measurement techniques and methodology for performance of the microseismic testing provided adequate safeguards against human or instrument error to the extent that, if errors were present, they would have had negligible af fects on the test results.
Each of the test locations within the 60 areas was usually tested at least twice before they were accepted for record.
Each test that indicated a reflector was independently analyzed to determine whether the reflector could be attributed to a planned as-built condition:
e.a., to the presence of rebar, conduits, or pipe sleeves which would be detected as discontinuities in the concrete by the microseismic testing technique.
If available data and drawings were inconclusive, the area was tested destructively, by coring or line drilling, for evaluation.
Cores were also taken from at least four areas which had been reported to be homogeneous concrete.
Three different organizations participated in the evaluations with separate responsibilities to minimi:e error during acquisition and evaluation of data.
Equipment performance tests were conducted at the beginning and end of each testing day.
Qualification tests fo.r the 3
program are documented in the Sargent and Lundy report and in NRC Inspection Report No. 50-546/79-07--50-547/79-07.iated September 18, 1979.
An NRC inspector observed qualification of the tasting procedure prior to its implementation.
Moreover, 21 additional destructive tests (cores and/or line drilling) were 2See Attachment A, 53, of letter from J. G. Keppler to Dr. M. A. Cassaro (March 20, 1981); Attachment A, 051 & 3, of letter from J. G. Keppler to Dr. M. A. Cassaro (July 22; 1981).
3 Report SL-3753 Rev. 1, dated November 21, 1980.
. performed at the request of the NRC's independent consultants.
These additional tests did not identify any errors in the results that the previous microseismic testing had established.
The NRC consultants also requested a test of the tran'sducer (the equipment used in the microseismic testing).
The test was performed on a one foot cube of concrete on February 9, 1981.
After the instrument indicated a discontinuity in the concrete cube,'the cube was sawed and the discontinuity was found.
Dr. Cassaro as well as the NRC's independent t
consultants witn6ssed this test.
Since adequately conservative procedural safeguards were implemented to preclude instrument and human error during the microseismic testing, errors that could be present would have had a negligible affect on the testing results.
In view of the foregoing information regarding the results of the tests that-were actually performed, additional testing of the concrete quality is not necessary.
The 60 areas that were tested were appropriately selected to include a large number of potentially defective areas, and the tests were performed in an appropriate manner.
The NRC's independent consultants reviewed-the test results and had additional destructive. tests performed to confirm the results found in the Sargent and Lundy program.
The consultants found as a result of their investigation that the concrete. quality was acceptable at Marble Hill.4 Other efforts to evaluate concrete quality have included rigorous examination of exposed concrete surfaces and repair of any defects.
Special constraints were imposed on continued cons.truction work to ensure that surface areas were examined and repaired before they were covered by additional
- See Parme~& Hamm, Review of the Evaluation of Concrete at Marble Hill Nuclear Generatino Station Units 1 and 2, Report No. IE-124 (June 25, 1981).
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construction work.
Upon consideration of the results of the tes' ting that has been conducted, additional testing is not required.
On the basis of available information, the concrete quality.does provide the required assurance of 95%
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, assurance of 95% reliability.
ased on the results of the described program, and information known to the st'af, no furtner action is warranted at this time to assure that the Marble Hill structures contain concrete of acceptable quality.
l In its July Addendum and its August letter to the Commission, Save the Valley asked that a hearing be held before the Commission concerning the acceptability of Marble Hill's concrete.
The Commission is not required to hold a hearing to determine whether it should review a decision under 10 CFR 2.206 or should grant a section 2.206 petition.5 The holding of heari.ngs on a section 2.206 petition would be an extraordinary action and is not warranted in this case.
The Commission has before it a substantial amount of information concerning the quality of Marble Hill's concrete.
Save the Valley's views have been presented in it filings before the Commission and the technical analyses prepared by its consultants, Dr. Cassaro and Dr. Alexander.
The licensee has submitted its comments on the OPE memorandum.
The NRC Staff's views are set forth in this decision and in 00-81-10, and in its correspondence with Dr. Cassaro.
The Commission also has the benefit of OPE's analysis and the report of the NRC's independent consultants.
These various documents form a comprehensive basis 9 People of the State o' Illinois v. NRC 591 F.2d 12 (7th Cir. 1979).
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from which the Commission can judge whether to review my determination not to require further concrete testing and my decision not to withdraw the a'uthoriza-tion for PSI to resume' construction.
In light of these circumstances, I do not-recommend that the Commi sion hold the requested hearing.
Richard C.
eoung,[J' rector Office of n pectio Fand Enforcement-Dated at Bethesda, Maryland, this 3 Oday of November 1981.
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Enclosure 3_
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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PUSLIC SERVICE COMPANY OF INDIANA
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Dockit Nos.
50-546 (Marble Hill Nuclear Generating
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50-547 Station,' Units 1 and 2
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GRADUATED RESCISSION OF ORDER DATED AUGUST 15, 1979 I
The Public Service Company of Indiana (PSI or licensee) is the holder of Construction Permit Nos.
CPPR-170 and CPPR-171 issued on April 4, 1976.
These permits authorize in accordance with their provisions construction of the Marble Hill Nuc1 car Generating Station, Units 1 and 2.
II NRC inspection findings during the spring and summer of 1979, which were based in part on allegations by construction workers at the site and the results of inspections by the National Board of Boiler and Pressure Vessel Inspectors, raised 'ignificant questions as to the adequacy of the ifcensee's quality s
essurance program at the Marble Hill facility.
As a result of these' findings, the licensee stop' ped wrk August 7,1979, on all safety related construction at the site.
This action was confirined by an Order confiming Suspension of Construction issued by the NRC on August 15, 1979.
The Order provided that the licensee shall not resume' safety related construction activities on the Marble Hill Units 1 and 2 nuclear power station until such time as (1) the licensee submits in writing under oath to the Director, Office of Inspection and pl t[
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Enforcement, a description of a revised cuality assurance program and of the steps taken to assure that safety related construction will be conducted in accordance with Appendix B of 10 CFR Part 50 of the Commission's regulations and (2) the Director has confirmed in writing that reasonable assurance. exists that safety related construction activities will be conducted in accordance with such requirements.
Such confirmation may extend in whole or in part to the suspended construction activities.
Nine different areas were identified as matters to be considered by the Director in reaching a determination concerning the licensee's proposed corrective actions.
III Since the issuance of the Order, numerous meetings and discussions have been held between the licensee's management and the NRC staff regarding the licensee's planned corrective action.
A public meeting concerning the licensee's proposed corrective actions was held in Madison, Indiana on Ma'rch 25, 1980.
The licensee formally replied to the Order with a report entitled " Description of Licensee Actions Addressing Order Confirming Suspension of Construction" dated February 2E, 1980.
This report addresses the appropriate matters identified in the Order of August 15, 1979.
The staff has concluded that the report properly addresses the matters identified in the Order, and that it provides an adequate basis for partial resumption of the construction program.
To assure that the licensee's corrective actions are implemented and effective, it is appropriate that construction activities at the Marble Hill site resume in a graduated, step-wise f ashion with review by the hRC at apptcpriate stages.
Accordingly, the
- attached schedule (Appendix) provides for the completion to the satisfaction of tre Director, Of fice of Inspection and Enforceme'nt, of a numbb'r of items before construction may resume in its entirety at the Marble Hill site.
IV In view of the foregoing, and pursuant to the provisions of my Order of August 15, 1979, t'his is to confirm that the graduated rescission process prescribed in the Appendix hereto afforcs reasonable assurance that safety related. construction activities will be conducted in accordance with requirements. -
FOR THE NUCLEAR REGULATORY COMMISSION Y
Victor Steito, Jrf. )/
Director I /
Office of Inspection and Enforcement Effective date: MAY 15 1980
Enclosure:
Appendix O
APPENDIX RESTART PROGRAM FOR FARELE HILL UNITS 1&2 WITH NRC HCLD POINTS 1
At each point in this schedule identified as an NRC hold point, NRC will conduct a special inspection or series of inspections to review t.he ac-propriate procedures ano practices for the particular operation.
If the NRC cetermines that the licensee has met satisfactorily all the necessary requirements, a letter of approval will be written by the Director of the Office of Inspection and Enforcement (IE) to the licensee to state that the r,atter has been resolved satisfactorily and to confirm the types of activities which may be restarted.
A.
Revised QA Program 1.
Public Service of Indiana (PSI) will accomplish the followin actions' before any new safety related construction can occur:g (a) Respond to the specific concerns expressed in the Office of Nuclear Reactor Regulation's April 1,1980 and April 28, 1980 questions relative to the upgrading of the quality assurance program and provide a Consolicatec Quality Assurance Program description that includes the licensee's responses.
(b) ' Develop a Project Qu lity Assurance Manual (PQAM).
(c) Develop an ASME Quality Assurance Manual (AQAM).
(d) Increase project staff experience levels in accordance with the licensee's submittal dated February 28, 1980.
2.
NRC HOLD POINT:
NRC will review the adequacy of items b, c and d above, and if the adequacy is confirmed, the Director of IE will issue a written statement to that effect to PSI.
w B.
'=teipt Inspection l.'
PSI will develop project management and other related procedures and will qualify its staf f for receipt inspection.
2.
NRC HOLD POINT:
NRC will review PSI's. program, procedures, and staf fing for receipt inspection.
3.
If the results of the NRC's review are satisfactory, PSI may resume receipt inspection upon written notification from the Director of IE.
i 4.
PSI will start receipt inspection and retain administrative custody of the equipment and materials.
5.
Each contractor will make adjustments as necessary to its QA program, procedures, and staffing for receipt inspection
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activities.
6.
PSI management will review and approve the above adjustments for receipt inspection for each contractor as required by planned activities and inform the Director of NRC Region III in writing of the adjustments.
7.
NRC HOLD POINT:
NRC will review the adequacy of the adjustments noted in item B.5 and B.6.
8.
If the r,esults of the NRC's review are satisfactory, contracters within the subject discipline may start receipt inspection, and storage and maintenance of PSI equipment and materials upon written notification from the Director of IE.
The four main disciplines are:
Civil / Structural; Mechanical; Electrical; and Piping.
C.
Material verification Program - Currently in progress and ray be accomplished in parallel with Receipt inspection..
1.
PSI will complete appropriate project management and special process procedures and conduct a Material Verification Program for all disciplines.
2.
PSI management will review and appr've the Material Verifica-tion Program results and inform the Director of NRC Region III in writing of the results.
3.
NRC HOLD POINT; NRC will review the material verification l
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HRC HOLD PDINT:
The NRC will review the construction verification efforts of PSI and confirm the adequacy of the program in each discipline.
E.'
Resumption of Cons.truction 1.
HRC HOLD POINT:
NRC will review PSI's progran, and its implementation as discussed in B, C, and D above for all disciplines.
If the adequacy is confirmed, the Director of IE will issue written notifica-tion to proceed as described in Item 2 below.
2.
Contractors' Program Adjustments Each contractor will adjust its QA program, procedures, and a.
staffing to be consistent with PQAM, AQAM, and other PSI pro-gra,e requirements for each discipline, b.
PSI management will review and approve the above adjustments for each discipline and inform the Director of NRC Region III in writing of the adjustments.
3.
HRC HDLD POINT:
The NRC will review the program adjustments for a particular discipline and the Director of IE will provide written notification that construction activities in a particular discipline may proceed in whole or in part if the adjustments are acceptable.
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NUCLEAR REGULATORY cot.1f.11SSION Enclost+e-4
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799 ROOSEVELT ROAD g,.....f GLEN ELLYN,ILUNOls 6o137 OCT 2 61991
. Docket No. 50-546 Docket No. 50-547 Public Service of Indiana ATTN:
Mr. S. W. Shields Senior Vice President Nuclear Division Post Office Box 190 New Washington, IN 47162 Gentlemen:
This refers to the special safety inspection conducted by Messrs.
C. C. Williams, W. S. Little and other staff members of this office on September 8 and 9, 1981, of activities at Marble Hill Nuclear Generating Station, Units 1 and 2, authorized by hTC Construction Permits No. CPPR-170 and No. CPPR-171 and to the discussion of our findings with Mr. A. Barker, you and others of the PSI staff at the conclusion of th.e inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and in-terviews with personnel. Specifically, the purpose of this inspection was to review, evaluate and summarize your implementation of the instructions and corrective actions set forth in the U. S. Nuclear Regulatory Commission document entitled " Graduated Recission of Order Dated August 15, 1979" (document dated May 15, 1980).
No items of noncompliance with NRC requirements and no areas of regulatory concern were identified during the course of this inspection.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
If this report contains any information that you.or your contractors believe to be exempt from disclosure under 10 CFR 9.5(a)(4),
it is necessary that you (a) notify this office by telephone within seven (7) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five (25) days from the date of f
Public Service of Indiana '0CT 2 61981 this letter a written application to this office to withhold such inforcation.
Section 2.790(b)(1) requires that any such application must be accompanied by an affidavit. executed by the ovner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons which are the bases for the claim that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4).
The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed inspection report will be placed in the Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, James G. Keppler Director
Enclosure:
IE Inspection Reports No. 50-546/81-18 and No. 50-547/81-18 cc w/ encl:
W. M. Petro, Executive Director Nuclear Project Management C. Kammerer, CA J. H. Sniezek, IE DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII LeBoeuf, Lamb, Leiby & MacRae Dave Martin, Office of Attorney General John R. Galloway, Staff Director, Environment, Energy and Natural Resources Subcommittee E. P. Martin, Wabash Valley Power Association
U.S. NUCLEAR REGULATORY CO.T!ISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Reports No. 50-546/81-18; 50-547/81-18 Docket Nos. 50-546; 50-547 Licenses No. CPPR-170; CPPR-171 Licensee: Public Service of Indiana Post Office Eox 190 New Washington, IN 47162 Facility Name: Marble Hill Nuclear Generating Station, Units 1 and 2 Inspection Conducted:, Sept;qmber 8 and,9, 1981
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Inspectors:',
sident Inspector
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r F'.hawkins
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Accompanied By:
W. S. Little, Chief Reactor Projects Section 2C C. C. Williams, Acting Chief Engineering Inspection Branch C'. e t r A ~ ~
C C. Williams, Acting Chief
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Approved By:
Engineering Inspection Branch Inspection Summary Special Inspection on September 8 and 9, 1981 (Reports No. 50-546/81-18; 50-547/81-18)
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Ar as Inspected: Review and observation of all active areas of construction:
Examination of Project management organizations; interrogation of principal project management personnel; review and examination of principal concitments status pursuant to August 15, 1979 order confirming suspension of construction.
The inspection consisted of 64 inspector-hours onsite by four (4) members of the Region III inspection staff.
Results: No items of noncompliance or deviations were identified.
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DETAILS A.
Persons Contacted Public Service of Indiana (PSI)
- A.
Barker, PSI Chief Executive Officer
- D. Menscer, President
- W.
Shields, Senior Vice President, Nuclear Division
- L. Ramsett, Executive Director, Nuclear Quality Assurance
- W. Petro, Executive Director, Nuclear Project Management
- W. Wogsland, Executive Director, Operaticos
- W. Boshear, Executive Director, Personnel
- T. Burns, Project Engineering Manager
- J. Bott, Nuclear Safety and Licensing Manager Hartford Steam Boiler Insurance Co.
Allen Clark, Authorized Nuclear Inspector (Certification No. N-2456)
- Denotes those attending the exit interview Otber members of the licensee's and contractor staff were contacted as a matter of routine during this inspection.
B.
Functional or Program Areas Inspected This special inspection consisted of a summary review and final assess-ment of the licensee's response to the Order Confirming Suspension of Construction dated August 15, 1979, in conjunction with the May 15, 1980
" Graduated Recission of Order dated August 15, 1979" (Attachment "B" to this report).
1.
Principally, the actions required by the order and the associated Region III inspection reports were as follows:
a.
Revise and provide acceptable quality assurance programs in response to 10 CFR Part 50 Appendix B, and the requirements of the American Society of Mechanic 1 Engineers.
b.
Reorganize the project management, construction, engineering and QA organizations, and provide adequately qualified staff in sufficient numbers to support PSI and its contractors' construction efforts.
c.
Develop and implement material and construction verification 4
programs to assess t'.e degree of conformance to all pertinent requirements for all existing areas of safety related con-struction and associated materials.
Provide a program for the resolution of all discrepancies noted.
d.
Implement a comprehensive receipt inspection program and.
c.
Successfully r:eume construction and probicm rasolution in conformance with the revised cod cpproved org:nizations, programs, and materials.
2.
Based on the numerous NRC inspections and investigations since August 15, 1979, as outlined in Attachment "A" to this report, the licensee has satisfactorily accomplished each of the correc-tive actions and commitments established by the order and subsequent NRC/ PSI correspondence.
Attachment "A" to this report is a tabulation of all Region III inspection reports regarding the licensee's performance in response to the Order beginning with Reports No. 50-546/79-11; 50-547/79-11; including subsequent and relevant reports to date.
These inspection records demonstrate the region's review and evaluation of each principal corrective action taken by the licensee in response to the order.
By way of summary, only the ' ajor actions and the inspectors' m
current evaluations will be discussed in the following paragraphs.
The result of personnel interviews with PSI principal site management is also summarized herein.
3.
General Background The following is a summary and status of the Quality Assurance Programs at Marble Hill beginning with the Stop-Work-Order to the present time:
On August 15, 1979 the Nuclear Regulatory Commission (NRC) issued an order to Public Service of Indiana confirming suspension of construction at. Marble Hill. Earlier on August 7, 1979 PSI had voluntarily halted all safety related construction activities. On February 28, 1980 PSI responded to the Confirmatory Order, letter S. W. Shields (PSI) to V. Stello (NRC), subject was " Description of Licensee Activities Addressing Order Confirming Suspension of Construction." Included in this document was a " Revised Quality Assurance Program." On May 15, 1980 the NRC responded to PSI with a document entitled " Graduated Rescission of Order Dated August 15, 1979." This document contained an Appendix (schedule) outlining specific points requiring action with NRC approval (Hold Points) prior to proceeding to the next step. This document is shown as Attach;aent B to this report.
4.
QA Program Consideration.,
At each point in the schedule identified as an NRC hold point, NRC was to conduct a special inspection or series of inspections to review the appropriate procedures and practices for the particular operation.
If the NRC determined that the licensee had met satisfactorily all the necessary requirements, a letter of approval was to be written by the Director of the Office of Inspection and Enforcement (IE) to the licensee to state that _
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the catter. hsd been resolvzd satisfactorily cod to confirm the types of activities which could be restarted. The schedule provided for a revised QA program and hold point as follows.
a.
Revised QA Program j
Public Service of Indiana (PSI) will accomplish the following actions before any new safety related construction can occur:
(1) Respond to the specific concerns expressed in the Office of Nuclear Reactor Regulation's April 1,1980 and April 28, 1980 questions relative to the upgrading of the quality assurance program and provide a Consolidated Quality Assurance Program description that includes the licensee's responses.
(2) Develop a Project Quality Assurance Manual (PQAM).
(3)' Develop an American Society of Mechanical Engineers (ASME) Quality Assurance Manual (AQAM).
(4) Increase project staff experience levels in accordance with the licensee's submittal dated February 28, 1980.
b.
NRC HOLD POINT: NRC will review the adequacy of Items (2),
(3) and (4) above, and if the adequacy is confirmed, the Director of IE will issue a written statement to that effect to PSI.
5.
Licensee's Actions The following addresses the historical and current status of each point by corresponding letter / number designator:
a.
Revised QA Program (1) On April 28, 1980 PSI submitted the revised Chapter 17 to the Preliminary Safety Analysis Report (PSAR) entitled the " Consolidated Description of the Marble Hill Quality Assurance Program" to the NRC (letter S. W. Shields to H. R. Denton dated April 28, 1980).
The NRC approved this document by letter B. J. Youngblood to S. W. Shields dated May 23, 1980. This acceptance is also attested to in NRC Reports No. 50-546/80-24 and No. 50-547/80-24.
Since that approval, two changes have taken place affecting organization.
NRC notifica-tion was via letters to H. R. Denton from S. W. Shields (PSI) dated February 27, 1981 and August'21, 1981. NRC approval was denoted in letter B. J. Youngblood to S. W. Shields dated May 6, 1981 and the more recent notification is currently under evaluation (NRR advised Region III that these changes are acceptable and that they are in the process of responding to PSI). _
(2) A Project Quslity Assurance Manusi (PQAM) was developed in early 1980, reviewed by the NRC staff as statused in NRC Reports No. 50-546/80-17; 50-547/80-17 and 50-546/80-22; 50-547/80-22. Final acceptance by NRC is documented in Reports No. 50-546/80-24; 50-547/80-24.
Further acknowledgment attesting to satisfactorily meeting this requirement was also provided by V. Stello letter to S. W. Shields dated July 7, 1980. Four sub-sequent revisions to this program have been required due to reorganization and modification to implementing requirements. Each of these revisions was reviewed and accepted by the NRC as documented in NRC Reports No. 50-546/80-37; 50-547/80-37, 50-546/80-43; 50-547/80-43; 50-546/81-04; 50-547/81-04, and 50-546/81-16; 50-547/81-16.
(3) An ASME (American Society of Mechanical Engineers)
Quality Assurance Manual (AQAM) was developed in late 1979.
This manual was reviewed by an ASMI survey team (NRC participated) and found acceptable in December, 1979.
Following the survey an ASME Interim-Letter was issued endorsing QA Program approval. The NRC also reviewed the AQAM for content and compatability with the PQAM, this was documented in NRC Reports No. 50-546/80-24; 50-547/80-24.
An ASME survey team (NRC participated, Reports No. 50-546/80-43; 50-547/80-43) performed an AQAM review and an implementation survey on November 10-12, 1980.
The survey, results were positive and PSI was awarded.their "N" Certificates on January 13, 1981. Since the certificate issuance the AQAM has been revised three times (January 27, March 11, and August 10, 1981), each revision was reviewed and approved by the Authorized Inspection Agency. The NRC has also been performing inspection of ongoing code activities at the site.
(4) PSI has reorganized the project considerably, and effectively. This includes:
(1) Moving the entire Nuclear Division to the Marble Hill Site; (2) re-structuring the organization to manage by contracts; (3) building a team concept of responsibility and performance; (4) increasing staff by numbers, experience and education, and nuclear experience.
Initial staffing was accomplished utilizing contracted personnel (40% of total staff).
Currently, approximately 19% of total staff are con-tracted personnel. This percentage of contracted personnel will probably remain at this level until the job is complete.
Most key management positions have been filled with permanent PSI personnel. The contracted people remaining in these positions (five) are expected to continue until completion of construc-tion.
PSI and its contractors verified backgrounds of
all persenn21 (education cnd experienca), this was also verified by the NRC and documented in Reports No. 50-546/80-17; 50-547/80-17 and 50-546/80-24; 50-547/80-24.
The following tabulation compares the present site staff to that which existed prior to the order.
It should be noted that there has been a very significant improvement in the ratio of QA/QC to others, the average experience level and the number of talented personnel presently onsite.
Personnel Data Present Prior to Order Total 2300 1650 PSI 711 78 PSI-Technical 400 78 Craft 1200 QA/QC PSI 126 40 (18 onsite)
QA/QC Contractors 130 41 QA/QC Total 256 81 (59 onsite)
Ratio-QA/QC to total 1:9 1:28 Experience Levels (in years) i Present Prior to Order PSI Div. Ngt.
84 (21 avg.)
0 (4 Professional Personnel)
PSI Proj. Mgt.
1369 (10.9 avg.)
143 (3.8 avg.)
& Staff (125 Professional Personnel)
(37 Professional Personnel)
PSI QA/QC 949 (9.3 avg.)
168.5 (4.2 avg.)
(102 Professional Personnel)
(40 Professional Personnel) 6.
Quality Assurance Implementation i
The overall implementation of the quality program at Marble Hill has been ader.aate to date. PSI and their contractors not only have comph4ely rewritten, retrained, and adopted a new philosophy in the quality program areas, but have successfully utilized this program to cctreet old p:oblems and to control ongoing activities.
This program has not been free of problems, but the problems have been properly identified and corrected. This corrective action
has b:ca c::prah:nsive enrugh to identify tha problem, provide proper disposition, and establish measures to prevent recurrence.
The mechanism for documenting these problems has been through the use of the nonconformance, corrective action and audit programs.
The basic program has required some revision as previously noted.
These changes were necessary to remove program inconsistencies and to improve implementation. These changes were made without com-promising program integrity. The NRC reviewed and approved these changes.
The program's further success is exemplified by the quality of work being accomplished in the construction areas. That is, quality awareness has become a vital work controlling element.
A good example of this is demonstrated in the concrete placed since the resumption of construction in the civil areas. This concrete has been of high quality, free of voids and unsound material, with an excellent surface finish. Any problems that were encountered during this activity (preplacement, placement, and postplace. ment) were identified in process in accordance with the established program. This enabled the goal of a high quality end product.
Also, orientation and retraining of personnel has re-established a sense of pride and regular use of good workmanship.
PSI management has been fully supportive of the Quality Program.
This is evidenced by their involvement in meetings being conducted on a routine and scheduled basis, prompt resolution of differences, and emphasis on training. This dedication is further exemplified by massive restaffing with qualified (educ~ation and related experience) individuals.
And also, in addition to the planned management audits, a number of additional audits by outside firms have been conducted to identify program deficiencies.
Numerous NRC inspection reports issued prior to and during this verification period and following the release for construction activities attest to the program success.
(See referenced reports in Attachment A to this report.)
7.
Civil / Structural a.
Public Service of Indiana was authorized on March 27;, 1981, by the Director of IE, to allow Newberg Construction Company to resume civil / structural construction activities. These construction activities were conducted under the August 15, 1979 KRC Order and were principally confined to chipping out and examining existing concrete patches and repair areas and restoration of these items.
Considerable inspection effort has been expended by the Region III office to monitor the restart of the civil /
structural construction activities. The inspection focused on those areas where deficiencies were identified prior to August 15, 1979; namely, the placement of new concrete and........
rcpnir of existing concrete. The results of these inspec-tions are documented in IE Report Nos. 81-06 cnd 81-12.
The licensee's performance in each area was concluded to be satisfactory. This construction activity was also subjected to the daily surveillance of the resident inspectorc Additionally, the licensee's Construction and Material Ver-ification Program activities have been extensively monitored.
The specific civil / structural verification program procedures which were inspected are SPP-2, SPP-3, SPP-5, SPP-6, SPP-10, and SPP-13. The results of the final acceptance of each of these SPP's are documented in IE Report Nos. 80-39, 80-34, 80-30, 80-44, 80-44, and 80-36 respectively. Additional review of each SPP is documented in inspection reports listed in Attachment A.
Based on these inspections, it was concluded that the licensee had met Verification Program commitments as they relate to the civil / structural program.
As s'tated in the foregoing paragraphs, the licensee has successfully upgraded its construction and QA/QC Programs, personnel qualifications and number. The current staff and organizations are fully capable of successful civil con-struction activities.
b.
Independent Evaluation of Concrete at Marble Hill On March 25, 1980, NRC committed to provide for an evaluation o' the existing concrete structures at Marble Hill Nuclear Generating Station by agents independent of the NRC.
To this end, Hamm Engineers, Inc., in conjunction witt agents from a local public interest group "Save the Valley", performed an extensive evaluation of the safety related concrete structures at the site.
The interim report of this evaluation documented on March 10, 1981, concluded in summary that "...the concrete quality of internal concrete in the structures is acceptable."
The final report entitled " Review of the Evaluation of Concrete l
at Marble Hill Nuclear Generating Station Units 1 and 2, Report No. IE-124," was dated and issued on June 25, 1981.
This final report agreed in summary with the interim report, that the internal concrete quality was acceptable; however, concrete
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placement failed in numerous instances to meet requirements as exhibited by the external condition of the concrete, neces-sitating significant amounts of repair.
(Note: The subject Independent Agents report is presently in the appropriate Public Document rooms.)
Subsequent to the issuance of the subject report major new concrete placement was initiated under the surveillance of Region III inspectors. As stated above, this activity has met all requirements of the construction management and QA l
programs. !
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8.
Marble Hill - American S:ciety of Mzchanical Engineers (ASME) Issues As previously reported, numerous nonconformances to the requirements of the ASME Code were identified at the site as initially reported-in National Board of Boiler and Pressure Vessel Inspector's findings documented in their report dated July 10, 1979. As a result of an enormous effort on the part of the licensee under the regulation of the State of Indiana Boiler and Pressure Vessel Board and the NRC, all of the previously identified nonconformances (programmatic and material) have been successfully and appropriately resolved.
During this inspection, the NRC inspectors interviewed the third party (Authorized Nuclear Inspector - ANI) at the site. He reported in summary, that the lice-aee is currently in full ccm-pliance with the code and that the code related functions at the site are proceeding normally.
The ANI is contracted from the Hartford Steam Boiler Company. The licensee is presently maintaining a valid N stamp as reported in Paragraph 5.a.(3) above.
(See Attachment "A" for historical reports on this matter.)
9.
Finil Review - Construction and Material Verification Program By way of summary the inspectors reviewed the current status of the subject program in terms of the success of the ongoing corrective action. No unaddressed problems or issues were disclosed or reported.
The specific areas of the program addressed were:
a.
SPP Category I Reinforcing Steel (see Attachment "A" Reference Report No's. 81-08, 80-09, 80-11, 80-13, 80-16, 80-20, 00-22, 80-25, and 80-39).
b.
SPP Category I Structural Steel (see Attachment "A"
Reference Report No's. 80-08, 80-15, 80-17, 80-20, 80-22, 80-25, and 80-34).
c.
SPP In-Place Category I Piping and Hangers (see Attach-ment "A" Reference Report No's, 80-15, 80-18, 80-20, 80-22, 80-23, 80-25, 80-28, and 80-35).
d.
SPP Category 1 Concrete Surface Irregularities (see Attachment "A" Reference Report No's. 80-06, 80-08, 80-09, 80-11, 80-13, 80-20, 80-28, and 80-30).
SPP Mechanical (Cadweld) Splices (see Attachment "A" e.
Reference Report No's. 80-16, 80-21, 80-22, 80-25, 80-28, 80-30, and 80-44).
f.
SPP Procedure for Physical Inspection and Verification of Previously Accepted Purchased Items (see Attachment "A" Reference Report No's. 80-17, 80-22, 80-23, 80-24, 80-25, 80-28, 80-31, and 80-40)..
i g.
SPP In-Place Category I Buried and Embedded Piping (see Attachment "A" Reference Report No's. 80-15, 80-23, and 80-35).
h.
SPP Checking of Category I Backfill Data (see Attachment "A" Reference Report No's. 80-06, 80-16, and 80-44).
i.
SPP Document verificatien for centainment liners, fuel and refueling pool liners and miscellaneous field erected tanks (see Attachment "A" Reference Report No's. 80-26 and 80-35).
j, SPP Document Verification Procedure for ASME Section III Piping, Hangers and Materials (see Attachment "A" Reference Report No's. 80-23, 80-26, 80-28, and 80-35).
k.
SPP Category I Concrete Pour Package, Concrete Constituent Materials and Embedded Metals Records Review (see Attachment "A" Reference Report No's. 80-21 and 80-36).
The subject verification program is fully complete and the ongoing corrective actions were found to be adequately supported by the construction and quality organizations.
Revision to the Construction and Material Verification Program Final Report, issued May 15, 1981, were found to be acceptable as documented in IE Report No. 81-12.
Notes: SPP is an acronym for Special Process Procedure. The references in Attachment "A" provide the previous report iden-tification, wherein more details are provided.
10.
Sustained Acceptable Construction Performance The first safety related activity authorized by NRC was Receipt inspection on July 7, 1980. Receipt inspection activity has continued in conformance with the requirements since that time.
On March 27, 1981, PSI was authorized to resume safety related concrete construction and in April 1981, placement of major safety related concrete was initiated. Region III has determined through inspection that all restart activities authorized by the Director, I&E, have been initiated and sustained in substantial conformance to the requirements; and subsequent construction has been accept-able.
11.
Summary of Interviews with Principal Site Management l
During this inspection the Region III Inspection Program managers conducted indepth interrogation of principal PSI site managers regarding their role in the management of their respective site organizations, their relationships'with other site organizations, their plans and expectations regarding their program respon-sibilities, their opinions regarding the effectiveness of the site organization as a whole, and the issues they considered to be currently the most critical relative to ongoing success in their work.
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Tha intervicwers w2r2 very ccndid cnd forthright in their response and indicated that they were encouraged to be so by all senior management officials.
In summary it is the conclusion of the Region III representatives that the site managers have a thoroughly comprehensive commitment to quality construction and engineering, and it is their clear understanding that senior management fully supports this con-sideration. Moreover each of the principal managers demonstrated exceptional personal qualifications for their assigned task and a clear understanding as to their relationship to the whole construction effort. Further, each had clearly identified responsibilities, goals and plans to effectively achieve them.
A salient understanding of the past problems and the current and future issues was demonstrated by each of the interviewees.
The following site managers were individually and privately interviewed:
a.
W. S. Shields, Senior Vice President, Nuclear Division b.
L. Ramsett, Executive Director, Nuclear Quality Assurance c.
W. Petro, Executive Director, Nuclear Project Management d.
W. Boshear, Executive Director, Personnel 12.
Summary Findings of This Special Inspection As a result of this inspection and the extensive inspection (previously documented - see Attachment."A") of the Marble Hill Construction Site, it is Region III's conclusion that PSI has adequately iepiemented its commitments made in response to the August 15, 1979. Order Confirming Suspension of Construction and the related conventions and agreements in accordance with the NRC document entitled " Graduated Recission of Order dated August 15, 1979.
13.
Exit Interview The NRC inspection staff met with the licensee representatives (denoted in Persons Contacted paragraph) during and at the con-clusion of the inspection.
The inspectors summarized the scope and conclusions of the inspection.
During the exit interview the NRC spokesman recounted to the PSI Chief Executive Officer, Mr. A. Barker, the significant degree that PSI Corporate policy contributed to the problems that led to the issuance of the August 15, 1979 Order.
In this regard, Mr. Barker was questioned about changes in general corporate policy to provide continuing support of their nuclear power commitments.
In summary, Mr. Barker responded that his organization is now appropriately sensitive to the needs of their nuclear power objectives as demonstrated by the reorganization, restaffing,....
cnd relocation of principal personnel to the construction site.
Further, he submitted that within the bounds of responsible management, the corporate policy and procedures impacting Marble Hill will be appropriate to the requirements of their nuclear objectives and that his principal site managers are encouraged to identify and correct all such areas of potential conflict.
IE Inspretica R:part No. 50-546/81-18 cnd 50-547/81-18 ATTACEMENT "A" REPORT S'M1ARY OF ACTIVITIES WITH REGARD TO AUGUST 15, 1979 ORDER, NO.
AND MAY 15, 1980 GRADUATED RESCISSION TO THE ORDER.
79-11 Provide basis for the order.
79-12 Observation of compliance with stop work order issued by PSI.
79-13 Observation of work activities regarding compliance with the order.
79-14 Meeting to discuss content of the ORDER.
79-15 Observation of work activities regarding compliance with the order, and concrete patch removal and testing.
79-16 Review of U. S. Testing T.x-catory and field testing procedures, and allegations receives rough Congressman Deckard of Indiana.
79-17 Observation of work activities regarding compliance with the order.
79-18 Followup on items identified in Report No. 79-16.
79-19 Observations of concrete coring work, and issu'es identified by the National Board of Boiler and Pressure Vessel Inspectors.
79-20 Activities with. regard to off-loading the Unit 2 reactor pressure vessel.
79-21 Observation of work activities regarding compliance with the order.
79-22 Observation of work activities regarding compliance with the order.
79-23 Observation of work activities regarding compliance with the order.
Review of licensee actions relative to the control of IE Bulletins and IE Circulars.
79-24 Meeting to discuss the development of the licensee's response to the order and the revised Marble Hill project organization.
79-25 Observation of work activities regarding compliance with the order.
Review of adequacy of storage and maintenance of material and equipment.
79-26 Review of civil QA implementing procedure relative to defective concrete repair.
79-27 Observation of work activities regarding compliance with the order.
Review of storage and maintenance activities.
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79-28 Meating to discuss Construction Verificetien Program, cod a concern raised by Congressman Moffett.
79-29 Seminar concerning past problems encountered at other sites in the electrical, instrumentation, and related QA-areas.
80-01 Observation of work activities regarding compliance with the order.
Followup and closecut of a concern raised by Congressman Moffett and referenced in report No. 79-28.
80-02 Review of licensee report in response to Item 1 of 06-27-79 IAL and observation of preliminary waterproofing work in the Auxiliary Building.
80-03 Observation of work activities regarding compliance with the order.
Review of storage and preservation activities for material and equipment.
80-04 Investigation into allegations of improper practices and falsification of records by site concrete testing laboratory.
80-05 Meeting to discuss the development of the Construction Verification Program.
80-06 Review of activities with regard to SPP-5 and SPP-10.
80-07 Meeting to discuss preliminary response to the nine issues identified in the Order.
80-08 Review of activities with regard to SPP-2, SPP-3, and SPP-5.
80-09 Observation of work activities regarding compliance with the order.
Review of storage and maintenance activities. Observation of activities with regard to SPP-2 and SPP-5.
80-10 Review of electrical installation activities performed prior to the order.
80-11 Observation of activities with regard to SPP-2 and SPP-5.
80-12 Meeting to discuss the licensee's proposed restart program and the proposed method for resumption of receipt inspection.
80-13 Observation of work activities regarding compliance with the order.
Review of storage and maintenance activities. Observation of activities with regard to SPP-2 and SPP-5.
l 80-14 Review of installed safety related piping.
80-15 Observation of activities with regard to SPP-3, SPP-4 and SPP-8.
80-16 Observation of activities with regard to SPP-2, SPP-6, and SPP-10.
80-17 Review of Project Quality Assurance Manual (PQAM), personnel qualifications, and activities witn regard to SPP-3 and SPP-7.
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80-18 Observatien of activities with regard to SPP-4.
80-19 Review of environmental monitoring program.
80-20 Observation of work activities regarding compliance with the order.
Review of storage and maintenance activities.
Observation of activities with regard to SPP-2, SPP-3, SPP-4, and SPP-5.
80-21 Follow-up on June 27 and July 23, 1979 Immediate Action Letters.
Observation of activities with regard to SPP-6 and SPP-13.
80-22 Observation of work activities regarding compliance with the order.
Observation of storage and maintenance activities. Observation of activities with regard to SPP-2, SPP-3, SPP-4, SPP-6, and SPP-7.
Review of the Project Quality Assurance Manual.
80-23 Observation of activities with regard to SPP-4, SPP-7, SPP-8, SPP-11 and SPP-12.
80-24 Review of Project Quality Assurance Manual and its implementation, QA/QC inspection personnel qualifications, and Project Management Procedures to support receipt inspection.
80-25 Observation of work activities regarding compliance with the order.
Observation of storage and maintenance activities.
Observation of activities with regard to SPP-2, SPP-3, SPP-4, SPP-6, and SPP-7.
80-26 Observation of activities with regard t.o SPP-f1 and SPP-12.
80-27 Meetings with independent concrete consultant team.
80-28 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities. Observation of activities with regard to SPP-4, SPP-5, SPP-6, SPP-7, and SPP-12.
80-29 Observation of nondestructive examination activities.
l 80-30 Observation of activities with regard to SPP-5 and SPP-6.
Meeting
[
with independent concrete consultant team.
i 80-31 Observation of work activities regarding compliance with the order.
l Observation of storage, maintenance, and receipt inspection l
activities. Observations of activities with regard to SPP-7.
l l
80-32 Observation of work activities regarding compliance with the order.
80-33 Observation of activities with regard to electrical contractor.
i 80-34 Observation of activities with regard to SPP-3.-
80-35 Observation of activities with regard to SPP-4, SPP-8, SPP-11, and l
SPP-12.
1 l l
80-36 Observatica of cetivitics with regard to SPP-13.
80-37 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities.
80-38 Observation and review of the revised document control system.
80-39 Observation of activities with regard to SPP-2, the civil inspection and testing services laboratory, and the electrical contractor.
80-40 Observation of activities with regard to SPP-7. Management meeting to discuss the following:
Material and Construction Verification Program; the independent concrete consultant team assessment; and the ASME Code Survey.
89-41 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities.
80-42 Review of the QA Program for the Piping / Mechanical Contractor.
80-43 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities.
Review of revisions to the Project Quality Assurance Manual.
80-44 Observations of activities with regard to SPP-6 and SPP-10. Review of Newberg-Marble Hill QA Manual, procedures, and program implementation.
80-45 Management meeting with regard to the Systematic Assessment of Licensee Performance (SALP).
80-46 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities.
81-01 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities, and construction activities by the piping, mechanical and electrical contractors.
81-02 Resolution of NRC questions with regard to the adequacy of inplace concrete.
81-03 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and' receipt inspection activities, and construction activities by the piping, mechanical and electrical contractors.
81-04 Obs-rvation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities, and construction activities by the. piping, mechanical and electrical contractors.
Review of revisions to the Project Quality Assurance Manual..
81-05 Obs2rv: tion of work cetivities regarding complicnca with the order.
Observation of storage, maintenance, and receipt inspection activities, and construction activities by the piping, mechanical, electrical and civil contractors.
81-06 Observation of activities with regard to the resumption of safety-related concrete placement and concrete repair.
81-07 Followup on items reported per 10 CFR 50.55(e) requirements.
81-08 Followup on items reported per 10 CFR 50.55(e) requirements.
81-09 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities, and construction activities by the piping, mechanical, electrical and civil contractors.
81-10 Observation of work related'to the corrective actions for SPP-6, and inprocess concrete repair activities.
Investigation of allegations of improper waterproofing activities.
81-11 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities, and construction activities by the piping, mechanical, electrical and civil contractors.
81-12 Observation of concrete repair activities. Review of the revised Construction and Material Verification.Prograd, Final Report.
81-13 Observation of work activities regarding compliance with the order.
Observation of storage, maintenance, and receipt inspection activities, and construction activities by the piping, mechanical, electrical and civil contractors. Followup on items reported per 10 CFR 50.55(e) requirements.
81-14 Observation of electrical activities.
81-15 Follovup on items reported per 10 CFR 50.55(e) requirements and licensee actions with regard to IE Bulletins and IE Circulars.
81-16 Observation of work activities regarding compliance with -the order.
Observation of storage, maintenance, and receipt inspection activities, and construction activities by the piping, mechanical, electrical and civil contractors.
Review of revisions to the-Project Quality Assurance Manual.
- l 9
IE Inspection Report No. 50-546/81-18 and 50-547/81-18 ATTACHMENT "B"
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jJ UNITED STATES Y,y, 5
NUCLE AR REGULAT ORY COMMISSION
.I wasmeios. o. c. mss g'y l
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EAY 15 1980 o
ket Hos.
50-546 Str-547 Public service Coapato of Indiana r
ATTH: Mr. S. W. Shields Vice President - Electric System 2000 East Main Street Plainfield, Indiana 46168 Gentleoen:
Jease find enclosed a doctment entitled Graduated Rescission of Order Dated eugust 15, 1979, which prescribes a graduated rescission process for irplemen-tation at the Marble Hill Nuclear Generating Station, Units 1 and 2.
Sincerely,
./
9 Yictor St411o, f.
Director l
Of fice of Inspection i
and Enforcement l
Enclosure:
l Graduated Rescission of Drder i
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CERTIFIED MAIL RETURN RECEIPT REQUESTED l
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UNITED ST TE5 0F AMEP,lCA NUCLEAR REGULATORY COMMISSION 2n the Matter of
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Docket Nos.
50-546 PUBLIC SERVICE COMPANY OF INDIANA (Marble Hill Nuclear Generating
)
50-547 Station,' Units 1 and 2
)
GRADUATED RESCISSION OF ORDER DATED AUGUST 15, 1979 I
The Public Service Company of Indiana (PSI or licensee) is the holder of Construction Perwit Nos.
CPPR-170 and CPPR-171 issued on April 4,1976.
These permits authorize in accordance with their provisions construction of the Marble Hill Nuclear Generating Station, Units 1 ar.d 2.
I b
11 NRC inspection findings during the spring and surxner of 1979, which were based in part on allegations by construction workers at the site and the results of inspections by the National Board of Boiler and Pressure Vessel Inspectors, raised 'significant questions as to the adequacy of the licensee's quality essurance program at the Marble Hill facility..As a result of these findings, the licensee step' ped work August 7,1979, on all safety related construction at.
the site.
This action was confirased by an Order Confirming Suspension of Construction issued by the NRC on August 15, 1979.
The Order provided that the licensee shall not resume' safety related' construction activities on the Harble Hill Units 1 and 2 nudiear power station u'ntil such time as (1) the licensee f
subr.its in writing under oath to the Director, Office of Inspection and 6
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1 2-Enforcennt, a description of a revised quality assurance program and of the steps taken to assure that safety related construction vill be conducted in accordance with Appendix B of 10 CFR Part 50 of the Comission's regulations cnd (2) the Director has confirmed in writing that reasonable assurance.txists that safety related construction activities will be conducted ir,accordance with such requirements.
Such confirmation stay extend in whole or in part to the suspended construction activities.
Nine different areas were identified as catters to be considered by the Director in reaching a determination
~
t.oncerning the licensee's proposed corrective actions.
III
,ince the issuance of the Order, numerous meetings and discussions,have been held between the licensee's management and the NRC staff regarding the licensee's planned corrective action.
A public meeting concerning the licensee's proposed corrective actions was held in Madison, Indiana on March 25, 1980.
The licensee formally replied to tha Order with a report entitled " Description of Licensee Actions Addressing Order Confirming Suspension of Construction" dated February 2E, 1980. This report addresses the appropriate matters identified in the Order of Au0ust 15, 1979.' The staf f has concluded that th'e report properly addresses the satters identified in the Order, and that it provides an adequate basis for
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partial resumption of the construction program.
To assure that the licensee's corrective actions are ti.plemented and effective, it is appropriate that construction activities gt the Marble Hill site resume in a graduated, step-wise f ashion with. review by the NRC at appropriate stages.
Accordingly, the m
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attached schedule (Appendix) provides for the completion to the satisfaction of the Director, Office of Inspectio,n and Enforceme~nt, of a numb'er of items before construction may resume in its' entirety at the Marble Hill site.
IV In view of the foregoing, and pursuant to the provisions of my Order of t'his is to confirm that the graduated rescission process August 15, 1979, prescribed in the Appendix hereto affords reasonable assurance that safety related construction activities will be conducted in accordance with requiren r.ts. -
FOR THE NUCLEAR, REGULATORY CO.ISSION 9
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Vict.orSteMt,Jr./
Director tj Office of Inspection and Enforcement Effective date: MAY 15 1950
Enclosure:
Appendix 9
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7 APPENDIX RESTART PROGRAM FOR MARBLE HILL UNITS 1&2 WilH NRC H0i.D Polhls At each point in this schedule identified as an NRC hold point, NRC @ill conduct a special inspection or series of inspections to review the ap-propriate procedures and practices for the particular operation.
- If the NRC determines that the licensee has ret satisfactorily all the nei:essary requirements, a letter of approval will be written by the Difector of the Office of Inspection and Enforcement (IE) to the licensee to state that the r.atter has been resolved satisf actorily and to confirm the types of cctivities which may be restarted.
A.
Revised QA Program Public Service o'f Indiana (PSI) will accomplish the folicwin 1.
actions before any new safety related construction can occur:g (a) Res* pond to the specific concerns expressed in the Office of Nuclear Reactor Regulation's April 1,1980 and April 28, 1980 questions relative to the upgrading of the quality assurance program and provide a Consolicated Quality Assurance Program description that includes the licensee's responses.
(b) Develop a Project Qua1ity Assurance Manual (PQAM).
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(c) Develop an ASME Quality Assurance Manual (AQAH).
W (d)
Increase project staff experience levels in accordance with the licensee's submittal dated February 28, 1980.
I 2.
HRC HOLD POINT:
HRC will review the adequacy of items b, c anc d above, and if the adequacy is confirmed, the Director of IE will issue a written statement to that effect to PSI.
B.
Receipt Inspection 5.
PSI will develop project managentent and other related procedures and will qualify its staff for receipt inspection.
2.
NRC HOLD POINT:
NRC will review P51's pirogram, procedures, arid staf fing for receipt inspection.
3.
If the results of the NRC's review are satisfactory, PSI may resume receipt inspection upon written notification from the Director of IE.
l l-l
2-PSI will start receipt inspet. tion and retain administrative 4.
custody of the equipment and materials.
l Each contractor will make adjustments as necessary to its QA program, precedures, and staf fing f or receipt inspection 5.
activities.
PSI manager >ent will review and approve the above adjustments for receipt inspection for each contractor as required by 6.
of the adjustments.
HRC will review the adequacy of the adjustments 7.
HRC HDLD PDINT:
noted in item B.5 and B.6.
within the subject discipline may start receipt inspe 8.
storage and emaintenance of PSI equipment and materials uponThe four ma written notification from the Director of IE. Civil / Structural; Mecha disciplines are:
Piping.
M6terial Verification Program - Currently in p'rogress and may be accceplished in parallel with Receipt Inspection.
C.
PSI will coglete appropriate project canagement and special I
process procedures and conduct a Materia 1 Verification Program 1.
t for all disciplines.
9 PSI management will review and approve the Ma l
2.
in writing of the results.
NRC will review the material verification NRC HOLD POINT:ef forts of PSI and confirm adequacy of the program 3.
discipline.
Construction Verification Program - Currently in progress and may b accomplished in parallel with Receipt Inspection.
D.
PSI wil'1 complete appropriate project manag 1.
tion Program.
PSI canagement will review and approve the Construction Ve cation Program results and inform the Director of NRC Region 2.
l III in writing of the results.
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NRC HOLD POINT:
The NRC will review the construction verification efforts of PSI and confirm the adequacy of the program in each discipline.
E.-
Resumption of Construction 1
1.
HRC HOLD PelHT:
as discussed in B, C, and D above for all disciplines.NRC will rev If the sdequacy is confirmed, the Director of IE will issue written notifica-tion to proceed as described in Item 2 below.
2.
Contractors' Program Adjustments Each contractor will adjust its QA proDram, procedures, and a.
staffing to be consistent with PQAM, AQAM, and other PSI pro-grap requirements for each dit.cipline, P11 management will review and approve the above adjustments b.
for each discipline and infore the Director of.NRC Region III in writing of the adju:tzents.
3.
HRC HOLD POINT:
The NRC will review the program adjustments for a particular discipline and the Director of IE will provide written notification that construction activities in a particular discipline F
may proceed in whole or in part if the adjustments are acceptable.
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