ML20052C066
| ML20052C066 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 08/28/1981 |
| From: | Bishop T, Dodds R, Haist D, Haynes R, Narbut P, Larry Wheeler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V), Office of Nuclear Reactor Regulation |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20052C063 | List: |
| References | |
| NUDOCS 8205040324 | |
| Download: ML20052C066 (33) | |
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UNITED STATES 0
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AUG 2 81981 MEMORANDUM FOR:UG H. Faulkenberry, Chief, Reactor Construction i
P,rojects Branch _
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AblP Regional' Evaluation Review Board - WNP 3/5 FROM:[
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.NRC REGIONAL EVALUATION OF WASHINGTON s
, NUCLEAR P"" N05. 3.A d 5 (WNP-3/5)
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The Regional Evaluation Review Board for WNP-3/5 met on August 18, 1981 to perform an evaluation of'projec't activities for the period of September 1980 through June 1981.
The review was conducted in accordance with NRC Draftitanual Chapter 0516.
Enclosed is a copy of the assessment report.. Sectiop11 is an overall evaluation of site management.Section V is tha'_act!9n plan recommended by the Board for the Regional Direct'1Fs c'o$.urr ence.
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The Board believes t.'1e licenley has talen'strcng action to improve project and construction management. ' However, contihuing attention needs to be given to assuring that adequace h.-eparation and preplanning has been accomplished by each contractc4r prior to the start of safety reltted work and on improving thq ouality of procedures and adherence to procedures.
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R. T. Todds Chairman, Chief D.P.l[aist,ReactorInspector s
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~P. P. Narbut, Reactor Inspector C. t R. C. H4ynes, Deputly Director IU}
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'T. W. Bishop, Sri Resident L. L. Wheeler, Projbct Manager, NRR Inspector En~ closure :
SALP Evaluation Report
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REGIONAL PERFORMANCE EVALUATION REPORT UTILITY PERFORMANCE EVALUATION - REGION V Utility: Washington Public Power Supply System Facilities: WNP-2 (Construction)
WNP-1/4 (Construction)
WNP-3/5 (Construction)
Appraisal Period: WNP-2 May 1, 1980 - June 30, 1981 WNP-1/4 -
July 18, 1980 - June 30, 1981 WNP-3/5 -
September 1,1980 - June 30,1981 Review Board Members:
WNP-2 WNP-1/4 WNP-3/5 R.T. Dodds, Chairman, IE:V X
X X
R.C. Haynes, IE:V X
X X
D.P. Haist, IE:V X
X A.D. Toth, IE: Resident Inspector X
J.0. Elin, IE:V X
X J.D. Carlson, IE:V X
P.P. Narbut, IE:V X
X D.F. Kirsch, IE:V X
T.W. Bishop, IE: Resident Inspector X
R.
Auluck, NRR X
R.W. Hernan, NRR X
L.L. Wheeler, NRR X
Areas of Good Performance Following the appointment of Mr. R. L. Ferguson as Managing Director in June 1980, substantial Supply System and reactor project organizational changes were made. The changes included the establishment of site-based Program Directors responsible for construction, startup, and initial power generation of the facilities. Other changes included deintegration of the WPPSS site organization from day to day engineering and construction management decisions and placing them in the.true role of oversight project management.
Experienced management has been brought in to key positions to implement these changes. The utility has also had a team of industry management experts evaluate all projects.
'1 This has lead to substantial contract changes to strengthen construction management.
It is too early to assess the net effect of all of these changes, but the results to date appear promising.
Utilization by the Utility of independent investigators from the home office to examine allegations and significant problems appear to add an additional degree of independence and lends credibility to findings.
l l
c A " hotline"- program has recently been established for concerned site personnel to use when their own "in-house" management is not responsive to their problems.
The " hotline" provides a mechanism for cuality problems to be brought before top Supply System management to be resolved.
There has been strong emphasis from top management of the need for attention to a quality product.
This has been particularly noticable during the last five months of the review period.
This has been reinforced by several memorandams and by the involvement of corporate level personnel.
Areas Uhere Improved Performance is Harranted While the deintegration of project management from construction management and quality assurance is believed to be a strength, the changes were implemented prior to the necessary changes being made to the program plan. Also, the f
associated implementing procedures have lagged these chances unduly.
In the Supply Systems response to the 10 CFR 50.54(f) request for information, the utility committed to a lessons learned program.
Implementation of this program has been delcyed and only recently has it begun to function effectively.
A special team audit (nine auditors for two weeks) was conducted by the utility at the hhp-1/4 site in January 1981. This was conceived L
to be preparatory to a proposed NRC team inspection. The audit appeared to be very thorough and uncovered many significant deficiencies requiring corrective action by the Project and its contractors.
Based on the results of this one major audit, it appears that all sites could benefit from periodic audits of this type directed by utility management.
The Supply System was very responsive to supplying team members for task force assignments at UNP-2; however, there was a constant change of personnel and management for this effort. This made it difficult to provide continuity to the review effort and has resulted in delays and the loss of identification of some weak areas that s' hould be examined during the reverification effort.
While NRR gave the Utility a rating of "below average" only.at one facility, all of the NRR Project Managers expressed concern with the timeliness of licensee responses to requests for technical information, believing that it too'K longer than necessary to clear material through licensee management.
i Comparison Between Reactor Sites All three sites deintegrated their organizations a little differently depending upon the particular needs of the facility snd upon the strength of the architect-engineer and construction contractors.
Bechtel has assumed construction management and system turnover (completion in some instances) at WNP-2 and only construction management at WNP-1/4; while at WNP-3/5, Ebasco now has complete responsibility for construction management as well as engineering. On the surface, the changes appear to have been for the better.
The utility needs to evaluate the quality of 50.55(e) reports (construction deficiency reports). The reports from WNP-3/5 are quite comprehensive and seldom require contact with the licensees to obtain pertinent data needed to assess the deficiency and its generic implications. The reports from the other two sites tend.to be quite sketchy and generally require immediate followup by the NRC for additional information.
With the placement of a Project Director at each site, onsite Quality Assurance no longer reports directly to the General Office. We have not had sufficient time to assess the full impact of this change, but as yet, we have not seen any loss of objectivity or freedom to identify quality problems of site quality assurance personnel.
Overall Evaluation There are indications that the management reorganization initiated in the past year and the subsequent contractual changes, such as involving the Bechtel Power Corporation in construction management, will result in overall betterment in licensee performance.
This has had a partial detrimental effect on morale, resulting in lost production; however, it is not evident that this has adversely effected the quality of construction. Total effectiveness of the utilities management QA-program continues to be suspect. The NRC's inspection experience, as well as the utility's findings, continue to show that the failure to adhere to procedures and failure to include code and industry standard requirements in the procedures are the predominant causes of items of noncompliance.
The utility has initiated a lessons learned program that should assist the early identification of common problems.
t WNP-3/5 II.
LICENSEE PERFORMANCE EVALUATION Facility: Washington Nuclear Project Nos. 3 and 5 Licensee: Washington Public Power Supply System Unit Identification:
Docket No.
License No./Date of Issuance Unit No.
50-508 CPPR-154/ April ll, 1978 3
50-509 CPPR-155/ April 11, 1978 5
Reactor Information:
MWt 3800 3800 Appraisal Period:
September 1,1980 - June 1981 Appraisal Completion Date: July 23, 1981 Review Board Members:
R. T. Dodds, Chainnan, Reactor Projects Section 2, IE:RV D. P. Haist, Project Inspector, IE:RV T. W. Bishop, Senior Resident Inspector, IE:RV R. C. Haynes, Deputy Director, IE:RV P. P. Narbut, Reactor Inspector, IE:RV L. Wheeler, Project Manager, NRR Overall Licensee Management Evaluation Following the appointment of Mr. R. L. Ferguson as Managing Director in June 1980, substantial Supply System and WNP-3/5 organizational changes were announced in October,1980.
These changes included the establishment of a site-based Program Director for WNP-3/5 who is responsible for the construction, startup, and initial power generation of the facility.
This position was filled in February 1981 with i
Mr. R. S. Leddick who has had substantial nuclear power plant construction and startup management experience.
Other actions included a change in the reporting relationship of the WNP-3/5 Project Quality Assurance Manager from the Corporate Quality Assurance Director to the WNP-3/5 Program Director and the establishment of a new Corporate Directorate of Nuclear Safety.
The previously " merged" organization of WPPSS and Ebasco was deintegrated with Ebasco assigned full construction-management responsibilities and the Supply System assuming an oversight project management role for WNP-3/5.
The new organization appears more responsive to NRC concerns and attentive to quality related matters.
However, the documented quality assurance program policies, procedures,
and instructions which are used for the management and control of safety related activities have not been maintained current with changes in management policies and organizational structures or consistent with each other.
The time alloted to fully establish an adequate documented program appears to be excessive.
The utility has initiated a Q-Tips training program for craf ts foremen that is intended to be passed on to the craf tsmen.
The program is beir:g utilized at this facility.
The construction manager has a program in effect to obtain AWS certification for welding inspectors. However, the failure to follow procedures by employees of several contractors continues to be a chronic problem at this site and is indicative of a deficiency in the training programs and/or construction management.
Historically, the quality of procedures varies significantly among the site contractors with some not reflecting essential SAR and contract specifications requirements.
This area continues to be a problem as evidenced by (1) the reactor building civil-structural contractor's procedures not incorporating contract specified nonconformance reporting requirements and (2) reactor auxiliary building civil-structural contractor's procedures not meeting the structural joint inspection requirements of the ANSI standard.
The quality of the utility's/A-E's vendor inspection program for this project has been mixed. Difficulties experienced included:
(1) deficiencies identified with the vendor welding of stainless steel and carbon steel pipe spools; (2) fabrication deficiencies identified with the Combustion Engineering supplied safety related comoonents (gas decay tanks, decay heat exchanges and letdown heat exchangers); and (3) unauthorized fillet welds in embed plates fabricated by a structural steel vendor.
The licensee has taken steps to correct these types of problems by (1) assigning full time vendor representatives where problems were identified, (2) bringing the vendor representatives in for training and (3) increasing the quality of receiving inspe.: tion in problem areas.
There was an increase in items of noncompliance per inspection hour this past year.
The quality of the licensee's responses to items of t
noncompliance was of concern during the early portion of the appraisal period.
In three instances the licensee was requested to submit additional information.
In one instance it was found that the licensee's statements of corrective actions having been completed were incorrect.
The NRC's investigation of this concluded that there was no intent by the licensee to deceive the Commission, rather that poor data assembly practices and lack of verification of the contractor's e
actions led to an inaccurate report.
The licensee has taken actions to insure the accuracy of data and improve the quality of responses provided to the NRC.
Recent inspections have not identified any further problems in this area. __-
l NRR's experience with the licensee has been satisfactory.
Experience with the handling of geological data indicates that the processing of internal documents took longer than expected and could cause problems in the future.
The Board believes the licensee has taken strong action to improve project and construction management.
However, continuing attention needs to be given to assuring that adequate preparation and preplanning has been accomplished by each contractor prior to the start of safety-related work and on improving the quality of procedures and adherence to procedures.
Evaluation Criteria The various functional areas and the licensee's overall performance were assigned a Category 1, 2, or 3 rating based upon the following evaluation i
criteria:
Category 1.
Reduced NRC attention may be appropriate.
Licensee r
l management attention and involvement are aggressive.and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to opera-tional safety or construction is being achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with i
respect to operational safety or construction is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
i Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
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i III. PERFORMANCE ANALYSIS OF FUNCTIONAL AREAS A.
Cuality Assurance 1.
Analysis The utility senior site and corporate management has recently given added emphasis to the importance of quality in all aspects of the job.
The assignment of Ebasco as the sole construction manager with the Supply System as the overseer appears to have strengthened quality assurance.
This was evident during the team inspection by the appearance of increased quality assurance surveillance in the field.
The utilization of an independent quality assurance auditor under the corporate organization to investigate allegations has been effective in ferreting out problem areas. At least one member of the Board and members of the team inspection believe that the quality of audits conducted by the quality assurance organization of the Supply System, Ebasco, and site contractors has improved. The audits evaluated were found to be well planned, comprehensive in nature and well performed.
The Supply System was found to have an excellent training program for quality assurance auditors. However, the actions to resolve findings warrant improvement based on the observation that some findings were repetitive and there has been a continuing pattern of procedure violations.
Increased management attention to audit findings by Ebasco and the Supply System, the auditing organizations, i
appears to be warranted.
Quality assurance implementing procedures and work procedures prepared by contractors frequently fail to incorporate specification and industry standard requirements.
L Quality Assurance _ department reviews of contractor submittals are generally controlled by instructions and have been more thorough than those of engineering groups.
One item of noncompliance (80-15-01) was issued for failure to incorporate specification requirements regarding control of nonconforming conditions into a contractor's quality assurance procedures.
Licensee action has included issuance of instructions detailing minimum review criteria for resident engineering review of contractor submittals.
One item of noncompliance (80-12-01) was issued for failure of the HVAC contractor to control a nonconforming condition. Careful review by the licensee quality assurance organization of this contractor's deficiency reporting and nonconformance control procedures should have identified this weakness.
The corporate manuals, procedures and safety analysis. report are not fully consistent with each other, particularly with respect to the new organization and management / contractor interface:.
The team inspection disclosed that the interfaces between Ebasco site and construction management, quality assurance, and Ebasco Site Support Engineering are not well defined or implemented.
The time alloted to fully establish an adequate documented program appears excessive..
l 7
e Contractor's procedures still need attention as evidenced by weak procedures being a contributing factor in six items of noncompliance, four of which were applicable to both units.
(80-10-02, 80-15-01, 81-02-03, 81-03-10, 81-07-01 and t
81-10-01).
Licensee action in this area includes:(1) development of generic procedures (reported as less than i
effective by licensee representative); (2) development of a
" Procedures Improvement Program" (not off the ground as of i
May 1981); and (3) development of improved procedure review instructions for engineering reviews.
2.
Conclusions While positive action is warranted in the areas identified above, the board considers the overall functional area of quality assurance to be rated as Category 2.
l 3.
Board Comments l
t The Region should continue to focus attention on the cuality of procedures and personnel adherence to procedures.
The routine inspection program should be continued, including the annual cuality assurance inspection to assess the effectiveness i
of the revised quality assurance program with the deintegrated organization.
Special attention is warranted in this area because of the use of many construction contractors, each with their i
own quality assurance program.
B.
Substructures and Foundations, Concrete and Containment Vessel 1.
Analysis The contractor for the steel containment vessel continues to reflect sound management control and quality craf tsmanship.
The NRC inspectors have found the contractor's managers to be intimately familiar with field activities, work progress and 1
problem areas.
Two contractors are involved in the areas of concreting and structures, contract No. 265 inside containment and contract i
No. 263 outside containment. Contract 263 management is now very responsive once a problem is identiifed.
This 3
situation is greatly improved from over a year ago.
Both contractors have experienced problems in the area of concrete consolidation. Corrective action appears to have been short term in this area as evidenced by a recent case of inadequate consolidation in a Reactor Auxiliary Building wall.
Concerns have also been identified with rebar spacing.
Concrete manu-facture and testing activities were found to be satisfactorily performed in accordance with the accepted program.
I i i
2.
Conclusion Concrete placement performance is rated as Category 2, while erection of the containment vessels is rated as Category 1.
Board Coments Continuation of the routine inspection program appears to be appropriate.
C.
Safety-Related Structures 1.
Analysis Contract 263 steel structures work has been less than satisfactory.
Related procedures have been weak (one noncompliance for Unit 3 and one for Unit 5); adherence to the procedures by both craft and quality control has been weak (six noncompliances for Unit 3; 80-13-01, 81-01-01, 81-02-01, 81-02-04, 81-08-18, and 81-08-17; and five noncompliances for Unit 5; 80-13-01, 81-01-01, 81-02-04, 81-02-05, and 81-08-18).
The licensee has initiated a 100% reinspection and records review for structural steel work. This action was to be completed in July 1981.
2.
Conclusion, Structural steel work by the 263 contractor is rated as Category 3.
3.
Board Coments NRC close-oud of contract 263 open items should continue.
Specific attention should be given to reviewing contractor's/
licensee's action taken, including training, to assure employee compliance with procedures. The Region should sample a significant portion of the contractor's work to assure that the corrective actions being taken are effective.
D.
Pioing and Hangers - Reactor Coolant and Others 1.
Analysis Work has not yet started on the reactor coolant system piping.
Experience with the contractor for other safety-related piping has shown pipe and hanger weld quality in the field to be very good.
Results of the team inspection indicated that this contractor appeared to have a (1) strong quality assurance /
quality control program, (2) good interface between quality l
assurance and construction management, (3).well coordinated and managed records system, (4) strong and effective construction management, and (5) high level of employee morale. One item of noncompliance was issued for improper weldinn procedure qualification applicable to both Units 3 and 5 (81-10-01).
The Architect-Engineer's designs for hangers also resulted in an item of noncompliance related to insufficient weld size (81-10-02).
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r 2.
. Conclusion Performance of construction for pipe and hangers is rated as Category 2.
3.
Board Comments Continue with the routine inspection program.
l E.
Safety Related Components including HVAC 1.
Analysis No items of noncompliance
- have been identified in the areas of reactor vessel components or other nuclear steam supply system components. Significant deficiencies were identified in the HVAC contractor's quality assurance program as discussed under paragraph III.A.
The HVAC contractor was investigated following allegations that records had been withheld from an NRC inspector.
The allegations were substantiated. Other areas of poor performance by this contractor included items of noncompliance for:
(1) disposition of a nonconforming condition "use-as-is" without approval by the Architect-Engineer (80-12-01); (2) improper test jig for welder qualification (80-17-05); and (3) failure to calibrate test equipment within specified frequencies (80-14-01).
The licensee identified a problem with the documentation of training records, resulting in the issuance of a stop work order.
The HVAC contractor has since experienced significant managerial and procedural changes designed to alleviate the identified deficiencies.
The storage of components by the mechanical equipment contractor has been "above average" with the exception of inplace storage of the charging) pumps which resulted in an item of noncompliance: (80-10-02.
2.
Conclusion Performance in the portion of the functional area inspected is rated as Category 3.
3.
Board Comments Continue with the routine inspection program, with emphasis on the licensee's audits of the HVAC contractor and management of audit findings.
l F.
Electrical Equipment, Tray and Wire 1.
Analysis There has been very little inspection activity in this area.
The contractor's quality assurance program and some procedures have been reviewed and found acceptable. Maintenance and storage of switchgear has been found acceptable. One item of noncompliance regarding the qualification of a tray support welding procedure was issued (81-07-01).
2.
Conclusion Perfonnance in this functional area is rated as Category 2.
3.
Board Comments The routine inspection program should be continued.
G.
Instrumentation No activity in this functional area.
H.
Fire protection No activity in this functional area.
I.
Preservice Inspection No activity in this functional area.
J.
Corrective Action and Reporting Analysis 1.
Analysis Reporting of potential 50.55(e) construction deficiencies has been adequate.
Interim and final reports of these deficien'ces
. have been timely and accurate. Quality Assurance keeps accurate files of these deficiencies for NRC review.
Responsiveness to IE Bulletins and Circulars has been satisfactory, with one exception being an inaccurate response regarding the use of masonry walls.
This item was subsequently identified and corrected by the licensee.
Accuracy and technical adequacy of licensee responses to items of noncompliance was of concern during the early portion of the appraisal period.
In three instances the licensee was requested to submit additional information due to an inadequate initial response.
In one instance it was determined during NRC followup that a licensee statement of actions completed was incorrect.
An investigation of this incident disclosed that there was no licensee intent to deceive the NRC, but rather poor data assembly v.
Dractics and a lack of verification led to the inaccurate report.
The licensee has taken additional actions to insure the accuracy of data provided to the NRC. Recent NRC inspections have not identified any further problems in this area.
The effectiveness of corrective actions has been suspect in noncompliance in the structural steel area. (g items ofsee paragraph C two areas such as:
(1) instances of recurrin and (2) in March the licensee was informed that a citation would be issued for the use of an unqualified welding procedure by the electrical contractor but during the April team inspection, it was found that the contractor was still using the unqualified procedure.
During the team inspection it was found that organizations with line responsibility for a function were not assuming responsibility for avoidance and correction of the problem.
It appeared that quality assurance was formulating and auditing corrective actions when construction management should have assumed responsibility for formulating corrective actions (81-08-04).
2.
Conclusion Licensee attention is warranted to assure identified problems are throughly analyzed and promptly and permanently resolved.
Performance, while apparently weak at times with respect to corrective action, is rated as Category 2 for this functional area.
3.
Board Comments The board recommends continued attention to assure that corrective actions are being effectively implemented and that construction management is assuming responsibility for effecting corrective actions.
K.
Procurement 1.
Analysis Deficiencies were identified throughout the year with procured components, some of which resulted in items of noncompliance, others identified by the licensee have resulted in 50.55(e) reports.
The team inspectors found, "The system utilized by the licensee and Ebasco for on-site receipt inspection of safety-related items and components does not include conformance to engineering specifications." The i
following problems were identified:
l l
_9_
a a.
Vendor supplied components provided by Combustion Engineering (CE) reflect poor vendor surveillance and weak vendor quality programs.
This resulted in one item of noncompliance for Unit 3 (80-09-05) and two 50.55(e) reports.
The licensee has taken action to strengthen vendor surveillance by assigning a vendor surveillance supervisor to the site (from Ebasco Headquarters),
additional training for all vendor quality assurance representatives, and applying pressure on CE to improve control of their subcontractors.
b.
A repeat item of noncompliance was identified relative to excessive off-set in a stainless steel pipe spool supplied by Associated Pipe and Engineering (80-15).
c.
The utilization of rivets in ITT Grinnell supplied pipe clamps was questioned regarding ASME code acceptability, which resulted in vendor application for a code interpretation. Subsequently, the licensee identified design and material problems with the clamps, resulting in an extensive qualification, testing and material analysis program which is still in progress (Interim 50.55(e) Report dated July 9,1981).
d.
An item of noncompliance was issued for vendors welding through cope holes on structural steel beams.
Two supp. liers were referenced on this item (81-08-19).
e.
An audit by the licensee identified a problem with stud welding on embed plates supplied by CB&I.
The problem was traced to a bad stud welding gun at the factory.
Extensive testing and analysis were required before it was detennined, at an acceptable confidence level, that embeds in safety related structures did not contain enough defective stud welds to affect serviceability (Final 50.55(e) Report dated May 29,1981).
2.
Conclusion The Region's experience is that there has recently been improvement in this area.
The licensee is taking corrective action when a problem is identified.
However, based on the number and types of problems identified with procured items, the consensus of the Board's opinion is that overall performance is rated as Category 3.
3.
Board Comments l
The board recommends that continued attention be applied to the inspection and surveillance program for procured components, with particular emphasis on quality of welding.
L.
Design Changes The area of design control was one of the areas specifically examined during the team inspection. Generally, it was found that design change control was effective. The one item of noncompliance identified related to the failure of the Ebasco Site Support Engineering (ESSE) group's failure to establish measures to assure that approved changes to documents are distributed and used. Seven drawings were identified in an ESSE control file which did not include approved changes (81-08-10). Also, Ebasco had not fully implemented their program guidelines for updating master drawings after five change documents had been issued against the drawing. As a result, many drawings had a large number of Field Change Requests and Design Change Notices that need to be used in conjunction with the drawings.
- However, document control and records management systems employed by the site centractors appeared to be well ordered and implemented, in spite of the large numbers of design document changes imposed on these systems by Ebasco (81-08).
The team inspectors found that there was a substantial commitment on the part of the licensee's onsite engineering organization to quality and technical evaluation. This was evidenced by licensee action in having (1) established a task plan for. system reviews, (2) defined review procedures, (3) established a deficiency reporting and resolution system, and (4) provided for documentation of review completion.
The reviews conducted to date appear to be comprehensive and substantive (81-08).
2.
Conclusion The overall handling of design changes is rated as Category 2.
3.
Board Comments Continue with routine inspection program with emphasis on i
ESSE's role in design control.
M.
Training 1.
Analysis The utility previously initiated a training program for contractor foreman which is designed to filter down to the craftsman.
The program has not been as effective as expected as evidenced by at least six items of noncompliance regarding adherence to construction procedures.
e
Ebasco has initiated a qualification program to certify _
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a11 weld inspectors to the AWS code.
The licensee identified a weakness with the HVAC contrator's i
training program and has taken steps to correct the identified deficiencies.
i The team inspection indicated that the Ebasco UPPSS auditors had received the appropriate training for their respective positions.
2.
Conclusions Performance is rated as Category 2.
3.
Board Comments Continue with the routine inspection program.
4 i
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IV.
SUPPORTING DATA AND SUMMARIES A.
Noncompliance Data Noncompliance Category Applicable to:
or Severity Level Unit 3 only Unit 5 only Both Units Violation 0
0 0
Infraction 1
0 1
Deficiency 0
0 1
Level I 0
0 0
II 0
0 0
III 0
0 0
IV 1
0 3
V 6
0 8
VI 0
0 2
TOTAL 8
0 15 See Attachment IV-3 and IV-4 for additional noncompliance data.
See enclosures 1 and 2 for a list of noncompliances.
B.
Reports Data (Construction Deficiency Reports)
The licensee has notified NRC of ten potentially reportable construction deficiencies as they are defined in NRC guidance on 10 CFR 50.55(e) construction deficiency reporting dated April 1, 1980.
Of these ten potentially reportable items, 6 have been determined to be not reportable and 4 are still under evaluation. is a listing sf these reports.
The licensee's activities in this area have been satisfactory.
C.
Licensee Activities Following the appointment of Mr. R. L. Ferguson as Managing Director in June 1980, substantial Supply System and WNP-3/5 organizational changes were announced in October,1980.
These changes included the establishment of a site-based Program Director for WNP-3/5 who is responsible for the construction, startup, and initial power generation of the facility.
Other actions included a change in the reporting relationship of the WNP-3/5 project Quality Assurance Manager from the Corporate Quality. Assurance Director to the WNP-3/5 Program Director and the establishment of a new Corporate Directorate of Nuclear Safety.
The previously
" merged" organization of WPPSS and Ebasco was de-integrated with Ebasco assigned full construction management responsibilities and the Supply System assuming an oversight project management role for WNP-3/5.
D.
Inspection Activities Resident and regional inspection programs were in effect throughout the assessment period. The total 1502 manhours of inspection effort include 537 manhours routine resident inspection, 354 manhours routine regional-based inspection, 421 manhours special team inspection, and 190 manhours special investigation of allegations.
The special teara inspection addressed the new organizational relationships and revised Quality Assurance Program. Areas Management; (3) Design Control; (4)y Assurance Program; (2) Proj of inspection included:
(1) Qualit Procurement Control; and (5)
Construction Control.
Routine inspections addressed the major construction activities in progress during the period which generally included containment erection, reactor auxiliary building and containment building concrete placement, reactor auxiliary building structural steel erection, and receipt, storage, and installation of safety-related components.
Increased emphasis was placed on the licensee's methods to assure that contractors are adequately prepared before executing safety-related activities and that contractor's procedures reflect specification, code, and standard requirements.
E.
Investigations-and Alleaations Review The major investigative activity during this period involved allegations that the HVAC contractor Quality Control Supervisor had withheld quality assurance records from an NRC inspector to prevent the inspector from seeing a quality problem, and that the same supervisor had directed the back-dating of quality records.
The first of these allegations was substantiated and the second was considered unsubstantiated due to inconclusive evidence. During the course of the NRC investigation, additional allegations were received regarding the contractor's performance.
These additional allegations were essentially items that were identified by a previous licensee investigation of this contractor resulting from allegations that a contractor employee had been improperly terminated.
The licensee issued a stop work order to the HVAC Contractor on September 29, 1980, based upon the findings of their investigation and preliminary results of the NRC investigation.
The licensee also initiated an audit of the contractor's quality assurance program. Corrective actions have been taken and the contractor has been released to continue safety-related work..
F.
Escalated Enforcement Actions None.
G.
Management Conferences Held During Appraisal Period A management meeting was held at the request of WPPSS Senior Management on February 25, 1981, to describe to NRC the actions taken by the licensee with regard to concerns expressed by the NRC at the October,1980 SALP meeting.
NRC representatives also discussed current concerns relating to licensee performance.
The licensee discussed the following topics at this meeting:
Current State legislative considerations to allow negotiated contract awards which would result in improvement of the bidder selection process and selection of any replacement contractors.
Decision to employ Ebasco Corporation in construction management and quality assurance roles at the WNP 3/5 site.
Establishment of an engineering SWAT team to examine engineering problems at all four projects.
Planned withdrawal of WPPSS from an integrated quality assurance program concept to one involving WPPSS in a quality assurance oversight role.
Quality assurance program improvements Specification and requirement changes and' design reviews.
Approach and progress toward achievement of improved quality.
Responsiveness to NRC findings.
Adequate preparation and preplanning.
Actions to strengthen vendor surveillance program.
Personnel transfers and replacements.
Translation of PSAR committments into specifications.
Translation of specification requirements into construction and inspection procedures.
Completeness and accuracy of quality records.
Corrective action systems.
Contractor training.
NRC representatives reviewed the enforcement history for the WPPSS 1, 3, 4, and 5 projects and expressed concern that the number of items of noncompliance identified has increased significantly in the six-month period following the SALP review.
NRC representatives -stated that a significant and lasting improvement in licensee performance has yet to be observed, and that such improvement is necessary to preclude future escalated enforcement action by NRC.
4 1
i '
.a.--
Page 1 of 2 ATTACHMENT IV-3 WNP-3 flVMBER AND NATURE OF fl0flCOMPLIANCE ITEMS - C0flSTRUCTION REACTORS Inspection Noncompliances Functional Area f&1nhours Severity Level Classification I
II III IV V 'VI Vio.
Inf.
Def.
Dev.
1.
Quality assurance 83 (1) 2.
Substructure &
foundations, con-crete & liner (containment &
others) 225 3.
Safety-rela ted structures (inc.
2 welding) 125 (5) (1) 4.
Piping & hangers--
others--(incl.
I welding) 115 1
(1) 5.
Safety-related com-ponents (vessel, internals, & HVAC) 152 (2)
(1)
(1) 6.
Electrical equipment, tray & wire 29 1
7.
Instrumentation 0
8.
Fire Protection 0
9.
Preservice inspection 0
- 10. Corrective actions &
reporting 108
- 11. Procurement 21 (1) 1 (1) 1*
12.
Design changes 23 (1) 13.
Training 10 TOTAL 891 1
5 1
(3) (8) (2)
(1)
(1)
- Down graded to Severity Level V based on re-evaluation, s
fl0TE:
( ) means the iten of noncompliance is applicable to both units.
Page 2 of 2 ATTACHMENT IV-3 WNP-5 NUMBER AND NATURE OF NONCOMPLIANCE ITEMS - CONSTRUCTION REACTORS Inspection Noncompliances Functional Area Manhours Severity level Classification I
II III IV V VI Vio.
Inf.
Def.
Dev 1.
Quality assurance 81 (1) 2.
Substructure &
foundations, con-crete & liner (containment &
others) 174 3.
Safe ty-rela ted structures (incl.
welding) 50 (5) (1) 4.
Piping & hangers--
o thers--(i ncl.
welding) 52 (1) 5.
Safety-related com-ponents (vessel, internals, & HVAC) 111 (2)
(1)
(1) 6.
Electrical equipment, l
tray & wire 32 7.
Instrumentation 0
8.
Fire Protection 0
9.
Preservice inspection 0
- 10. Corrective actions &
reporting 72 e
11.
Procurement 11 (1)
(1) 12.
Design changes 23 (1)
- 13. Training 5
TOTAL 611 (3)(8) (2)
(1)
(1)
NOTE:
( ) means the item of noncompliance is applicable to both units. _ _ _ _ _ _ _
r ATTACHMENT IV-4 ENFORCEMENT HISTORY FOR WNP 3/5 Number of Items Inspection Hours per SALP Period Inspection Hours of Noncompliance Item of Noncompliance 8/79 - 8/80 520.5 11 47.3 9/80 - 6/81 1502 37 40.6 -
_y_--_____-_____
UNIT ENFORCEMEtlT ACTIONS DURING PERIOD OF INTEREST PERIOD WNP-3 September 1,1980 - Juna 30,1981 Begins with Report 80-09 Ends: Report 81-1 (TEM OIL fiUMBER TYPE OR REPORT DATE RESPONSE LTR. NO./
REPLY REPORT DESCRIPTION SEVERITY DATE ADEQUATE CLOSED 1
80-09-05 I
10-26-80 G03-80-2966/
No Failure to fabricate gas decay tanks 11-21-80 in accordance with requirements G03-81-529/
N/A 2-20-81 Delay requested G03-81-747/
Yes 3-13-81 2
80-09/04 D
10-26-80 G03-80-2966/
Yes Failure to specify the proper quality i
11-21-80 classification in contract specification G03-81-386/
N/A 2-9-81 Delay reported 3
80-10/02 I
10-21-80 G03-80-2965/
No 81-09 Failure to provide for adequate storage /
11-21-80 protection of safety-related equipment G03-81-264 N/A 1-29-81 Delay requested G03-81-746 Yes 3-13-81 4
'80-12/01 4
11-26-80 G03-80-3239 Yes Failure to control a nonconforming condition 12-19-80 G03-81-885 N/A 4-1-81 Delay reported G03-81-1010 N/A 5-1-81 Delay reported 9
tnclosura -l
' " " ' ~ ~ ~ ' UNIT ENFORCEMENT ACTIONS DURING PERIOD OF INTEREST PERIOD WNP-3 September 1, 1980 - June 30, 1981 Begins:
Report 80-09 Ends: Ronnrt 81-10 (TEM OIL NUMBER TYPE OR REPORT DATE RESPONSE LTR. NO./
REPLY REPORT DESCRIPTION SEVERITY DATE ADEQUATE CLOSED 5
80-13/01 5
12-12-80 G03-81-054 Yes Failure to properly accomplish bolting 1-9-81 G03-81-254 N/A 1-29-81 Correction of inaccuracy 6-80-13/02 4
12-12-80 G03-81-054
.Yes Failure to properly translate design 1-9-81 requirements into working drawings 7
80-14/01 6
12-15-80 G03-81-033 N/A 81-07 Failure to calibrate equipment within 1-6-81 specified requirements Request for delay G03-81-059 No 1-9-81 G03-81-560 Yes 3-6-81 8
80-04/03 5
1-9-81 G03-81-511 No Excestive offset in pipe welds Report Repeat 2-19-81 80-15 G03-81-922 4-14-81 Request for delay G03-81-1044 Yes 5-11-81 9
'80-15/01 5
1-9-81 G03-81-511 Yes 81-06 Failure to incorporate specification 2-19-81 requirements into quality assurance procedures O
tnclosura -1 Paga 3 of 4
. UNIT ENFORCEMENT ACTIONS DURING PERIOD OF INTEREST PERIOD WNP-3 September 1, 1980 - June 30, 1981 Begins:
Report 80-09 Ends:
Report 81-11 e
l TEM OIL NUMBER TYPE OR REPORT DATE RESPONSE LTR. NO./
REPLY REPORT DESCRIPTION SEVERITY DATE ADEQUATE CLOSED 1
10 80-17/05 4
1-9-81 G03-81-510 Yes 81-07 Failure to properly perform welder 2-19-81 qualification tests 11 81-01/01 5
2-12-81 G03-81-620 Yes 81-06 Failure to properly perform stud welding 3-2-81 G03-81-756 N/A 3-17-81 Additional info.
12 81-02/01 5
3-24-81 G03-CI-933 Yes Failure to maintain adequate records 4-16 of inspection activities (Criterion V)
G03-81-2121 Extension 6-15-81 to 6-15-8]
13 81-02/03 5
3-24-81 G03-81-933 Yes Failure to incorporate proper structural 4-16-81 steel bolting inspection criteria into procedures 14 81-02/04 5
3-24-81 G03-81-933 Yes Failure to properly perform structural 4-16-81 steel bolting inspections 15 81-02/05 6
3-24-81 G03-81-933 Yes Failure to maintain adequate records of 4-16-81 inspection activities (Criterion XVII) 16 81-07/01 5
4-29-81 G03-81-2046 Failure to qualify fillet weld procedure 5-26-81 for use on electrical tray supports G03-81-2057 Yes 5-29-81 Clarification 6*
3 tnclosu rt -i
.g'3 Paga 4 of 4 UNIT ENFORCEMENT ACTIONS DURING PERIOD OF INTEREST PERIOD WNP-3 September 1, 1980 - June 30, 1981 Begins:
Report 80-09 Ends: Report 81-10 s
REPLY REPORT DESCRIPTION SEVERITY DATE ADEQUATE CLOSED 17 81-08/10 5
7-20-81 Failure to establish measures to control design changes
'18 81-08/18 5
7-20-81 Failure to bend reinforcing steel as required by' specification 19 81-08/07 5
7-20-81 Failure to bend studs as required for Repeat daily process qualification 20 81-08/19 4
7-20081 Failure to fabricate structural steel beams as required by drawings 21 81-10/01 4
7-2-81 G03-81-2339 Failure to qualify weld procedure in 8-7-81 accordance with ASME B&PV Code Failure to specify proper weld s1ze for 22 81-10/02 5
7-2-81 G03-81-2339 8-7-81 ASME NF hangers e
a 4
0
ncicsure -2 raga i or J,,
UNIT ENFORCEMENT ACTIONS DURING PERIOD OF INTEREST PERIOD-WNP-5 Septemoer 1, 1980 - June 30, 1981 Begins with Report 80-09 Ends: Report 81-)
s s
(TEM OIL NUMBER TYPE OR REPORT DATE RESPONSE LTR. NO./
REPLY REPORT DESCRIPTION SEVERITY DATE ADEQUATE CLOSED 1
80-09/04 D
10-26-80 G03-80-2966/
Yes Fa11ure to specify the proper quality 11-21-80 classification in contract specification G03-81-386/
2-9-81 Delay reported 2,
80-10/02 I
10-21-80 G03-80-2965/
No 81-09 Failure to provide for adequate storage /
11-21-80 protection of safety-related equ;pment G03-81-264/
N/A 1-29-81 Delay requested G03-81-746/
'Yes 3-13-81 3
80-13/01 5
12-12-80 G03-81-054 Yes Failure to properly accomplish bolting 1-9-81 G03-81-254 1-19-81 Correction of.
inaccuracy 4
80-13/02 4
12-12-80 G03-81-054 Yes Failure to properly translate design 1-9-81 requirements into working drawings 5
80-14/01 6
12-15-80 G03-81-033 N/A 81-07 Failure to calibrate equipment within 1-6-81 specified frequencies Request for delay y
G03-81-059 No 1-19-81 G03-81-560 3-6-81 Yes
~
ll r
~ ~ _.G Enclosuro -2 ro9ts i us a
)
j p -
- f f.
'4,;
UtlIT -
'E.':FORCEMErlT ACTI0ftS DURIfiG PERIOD OF IfiTEREST
~6 PER 0
~
WNP-5 September 1,1980 - Jd e 30, -1981,~
r Begin:
Raport 80-09 !End: Report 61-10 i-TEM OIL fiUMBER TYPE OR REPORT DATE RESP 0flSE LTR. fl0./
REPLY REPORT DESCRIPTI0fl SEVERITY DATE ADEQUATE CLOSED l'
'I b
80-15/01 5
1-9-81 G03-81-511 Yes 81-06 Failure to incorporate specification 2-19-81 requirements ipt'ipuality sssirance procedures
- f(
^
7 80-17/05 4
1-9-81' G03-81-510 Yes 81-07 Failure to properly perform welder qualification tests 8
81-01/01 5
2-12-81 G03-81-620 '
Ves 81-06 Failure to properly perform stud welding S 2 *31-G03-81-756 N/A
/'
3-17 -
Additional. info.
i
~~
- gr-s..
9 81-02/03 5
3-24-81 G03 'GI 933
-ele'fes Failure to incorp,ordtd proper Atructural
/.
4-16-81 _ ~
steel bolting inspection c*1teria int,oj
<{
=
procedures
_ y, 9
t 10 81-02/04 5
3-24-81 G03-81-933 Yes Failure to properly perform structtical
,e
/'
4-16-81 steel botting inspections s
i,.*
11 81-02/05 6
3-24-81 G03-81-933 Yes Failure to maintain adequate records of,"
4-16-81 inspectiomactivities (Criterion X/,11)'.' ~,
12 81-08/10 5
7-20-81 Failure'to', establish measures -to.contesi design ihanges e
~i
an susur e 4 Page ~ 3 of 3
- -2G-' '
Uf1IT ENFORCEMErlT ACTI0tlS DURIt:G PERIOD OF IriTEREST PERIOD WNP-5 September 1, 1980 - June 30, 1981 Begin:
Report. 80-09 End:
Report 81-10 s
TEM OIL llVMBER TYPE OR REPORT DATE RESP 0flSE LTR. fl0./
REPLY REPORT DESCRIPTI0tl SEVERITY DATE ADEQUATE CLOSED
' 13 81-08/18 5
7-20-81 Failure to bend studs as required for daily process qualification 14 81-08/19 4
7-20-81 Failure to fabricate structural steel beams as required by drawings 7-2-81 G03-339
' 15 81-10/02 5
Failure to specify proper weld size for ASME hangers t
8 h
l
. ' Enclosure -3 C0flSTRUCTI0tl DEFICIENCY REPORTS 50.55 (e) llNP-3/5 Issu r/
NOTIFIED
RESPONSE
RESPONSE RESP. LTR REPORT ITEM
' DESCRIP TION
~DATE REQ. DATE REC EIV E NO./DATF CLOSED 92680 Volcanic ash cleanup 10-1-80 003-80-2370 81-07 and CBl Derrick Crane Not Reportable 9-26-80 Collapse 32681 Deficiency in CBI s tud 2-26-81 3-28-81 3-30-81 G03-81-861 weld tes ting program In terium 3-25-81 4-30-81 G03-81-979 In terim 4-28-81 6-3-81 G03-81-256 Not Reportable 5/29/81 81-08 12881 Morrison-Knudsen 1-28-81 2-27-81 2-23-81 G03-81-503 and s truc tural bol ting In terim 2/19/81 3178A problems 3-17-81 5-11-81 G03-81-1027 In terim 5-7-81 Final RPT Due 8-15-81 3178B Failures and Cracking 3-17-81 4-16-81 42881 81-09 on 3/4 inch lock-Not Reportable washers used on tray 5-26-81 G03-81-20ll supports 5-21-81 3-2781 Improper ins tallation 3-27-81 4-26-81 6-12-81 81-12 of coupling sleeve Not Reportable retaining pin on Unit 3 T/B Crane 4-28-8A Field fabricated reinf. 4-28-81 5-27-81 5-26-81 G03-81-2002 81-12 s teel nnt inspected for tb t Reportable 5-20-81 cracks following cold bending (NCR3032) 4288B Unacceptable indications 4-28-81 5-27-81 5-26-81 G03-81-2012 on Radiographs for 3 SI In terim 5-21-81 tanks and tao RX coolant 7-6-81 G03-81-2200 pump supports Extension 7-2-81 In terim or Final Due 9-15-81 43081 Voids under embedded 4-30-81 5-30-81 5-8-81 G03-81-1014 81-12 plates WNP-5 base mat No tifica tion 5-1-81 6-3-81 G03-81-2055' No t Reportable 5-29-81 51231 Cracks in safety related 5-12-81 6-11-81 6-15-81 G03-81-2111
~
embed plates In terim 6-12-81 Final due 8-15-81 6-26-81 03-81-2159 In terim 6-24-81 61181 ITT-Grinnell s tiff clemp 6-11-81 7-11-81 deficiencies !
NRR PERFORMANCE EVALUATION Facility:
WNP 3/5
--Project Manager:
L. Wheeler Appraisal Period: 9-1-80 thru 6-30-81 1.
Performance Elements a.
Quality of responses and subnittals (such as SAR amendments, technical specification changes, generic letter response, and responses to requests for additional information).
Satisfactory.
No major shortcoming noted.
b.
Efforts reauired to obtain an acceptable response or submittal including timeliness, effort, responsiveness to staff requests, and anticipation or reaction to NRC needs.
Fair. Rating will become unsatisfactory if no improvement is made.
WNP 3/5 management attention should focus on improving these areas.
Major problems are likely to develop during the operating license review if present standards of performance are not improved.
c.
Working knowledge of regulations, guides, standards and generic issues.
Satisfactory.
d.
Technical competence.
Sa tisfactory.
e.
Conduct of meeting with NRR.
Not evaluated.
f.
Long-standing open items.
Not evaluated.
g.
Organization and management capabilities.
See list below.
h.
Results of operator licensing examinations conducted during the appraisal period.
Not evaluated.
.23-i
e 1.
Performance on specific issues (as selected by the Project Manager).
Processing of correspondence (routing for signatures and concurrences) is too slow, causing delays.
Staff preparation of correspondence is satisfactory.
2.
Observed trends in performance.
Not evaluated.
3.
Notable Strengths and Weaknesses.
None observed that are considered " notable."
4.
Overall Summary.
The licensee's performance in the very limited interaction with the NRC is rated as Category 2.
However, when the level of interaction increases, the licensee's quality of performance may change significantly.
Areas identified during this appraisal period as having significant potential for causing problems in the future are the routing and review procedures for documents that have been completed by the staff and are ewaiting approval.....,