ML20052C383
| ML20052C383 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 08/28/1981 |
| From: | Dodds R, Haynes R, Narbut P NRC - SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REVIEW |
| To: | Faulkenberry B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20052C374 | List: |
| References | |
| NUDOCS 8205040738 | |
| Download: ML20052C383 (28) | |
Text
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o UNITED STATES g
g NUCLEAR REGULATORY COMMISSION l
HEGION V L
8, g
1450 MARIA LANE. SUITE 210 g
WALNUT CREEK.CALIFORNI A 94596 Aug 281981 MEMORANDUM FOR:
B. H. Faulkenberry, Chief, Reactor Construction Projects Branch FROM:
SALP Regional Evaluation Review Board - WNP 1/4
SUBJECT:
NRC REGIONAL EVALUATION OF WASHINGTON NUCLEAR PROJECT NOS. 1 AND 4 (WNP-1/4)
The Regional Evaluation Review Board for WNP-1/4 met on July 21, 1981, to perform an evaluation of project activities for the period of July 18, 1980 through June 1981. The review was conducted in accordance with NRC Draft Manual Chapter 0516. Enclosed is a copy of the assessment report.
Section II is an overall evaluation of site management.
Section V is the action plan recommended by the Board for the Regional Director's concurrence.
It is the opinion of the Board, based on the results of the review, that the licensee's performance at this site during the appraisal period was weaker during the first half of the appraisal period. However, new management took substantive actions to improve project and construction management controls of site construction activities and this performance steadily improved.
Because of previous problems experieanced with contractors at this site and the deficiencies identified during the first half of this appraisal period, the region plans to continue its surveillance to assess the continued effectiveness of the licensee's new organization. The' region was unable to follow through in these areas the second half of the review period due.
to a reallocation of resources for the performance of Headquarter's ordered team inspections.
V 1
R. T. Dodds, Chairman, Chief, ONKii-sch, Reactor Inspector Projcts ectiop,RCPB
}/ Y k W 0b R. C. Haynes, eputy' Director
@. O. Elin Reactor Inspector Y 0.
[R Ef P'. P. Narbut, Reactor Inspector R. W. Hdrnan,' Project' Manager, NRR
Enclosure:
SALP Evaluation Report for Appraisal Period 7/80-6/81 8205040738 820429 PDR ADOCK 03000460 A
PDR L
i REGIONAL PERFORMANCE EVALUATION REPORT I.
UTILITY PERFORMANCE EVALUATION - REGION V Utility: Washington Public Power Supply System Facilities: WNP-2 (Construction)
WNP-1/4 (Construction)
WNP-3/5(Construction)
May 1, 1980 - June 30, 1981 Appraisal Period: WNP-2 July 18,1980 - June 30,1981 WNP-1/4 September 1, 1980 - June 30, 1981 WNP-3/5 Review Board Members:
WNP-2 WNP-1/4 WNP-3/5_
f 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
l P.P. Narbut, IE:V X
X
= 0.F. Kirsch, IE:V X
I
-T.W. Bishop, IE: Resident Inspector X
R.
Auluck, NRR X
4
.R.W. Hernan, NRR X
i 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 ~tienm of industry management experts evaluate all' projects.
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 k
an additional degree of' independence and lends credibility to. findings.
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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 quality 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 i
during the last five months of the review period. This has been reinforced by several memorandums and by the involvement of corporate level personnel.
Areas Where Improved Perfomance is Warranted 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 associated implementing procedures have lagged these changes unduly.
]
In the Supply Systems response to the 10 CFR 50.54(f) request for infomation, L
the utility committed to a lessons learned program.
Implementation of this program has been delayed 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 WNP-1/4 site in January 1981. This was conceived 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 orie 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 WNP-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 should be examined during the reverification effort.
While NRR only gave the Utility a rating of "below average" et one facility, all of the NRR Project Managers expressed concern with the timeliness of licensee responses to requests for technical informatic.1, believing that it took longer than necessary to clear material through licensee management.
Comparison Between Reactor Sites i
All three sites deintegrated their organizations a little differently depending upon the particular needs of the facility and upon the strength w
- m
. 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 Pie 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 sh_ould assist the early_ identification of cormion_ problems.
WNP l/4 1981 II. LICENSEE PERFORMANCE EVALUATION Facili ty: Washington Nuclear Project Unit 1 and Unit 4 Licensee: Washington Public Power Supply System Unit Identification:
Docket No.
CP No./Date of Issuance Uni t No.
50-460 CPPR-134 Dec. 23, 1975 1
50-513 CPPR-174 Feb. 21, 1978 4
Reactor Information:
Unit 1 Uni t 4 NSSS B&W B&W MWt 3600 3600 Appraisal Period:
July 19, 1980 through June 30, 1981 Appraisal Completion Date:
July 21, 1980 Review Board Members:
1 R. T. Dodds, Chairman, Chief, Reactor Construction Project Section 2 D. F. Kirsch, Reactor Inspector P. P. Narbut, Reactor Inspector J. O. Elin, Reactor Inspector R. C. Haynes, Deputy Director R. W. Hernan, NRR Project Manager for WNP 1/4 Overall Licensee Manaaement Evaluation During the latter half of this appraisal period the licensee made major changes in the organizational structure and employed several new top management personnel with the goal to improve the performance and control of site construction activities.
These changes included establishing a project organization within the Supply System to focus responsibility and authority for the successful completion of the WNP 1/4 project, appointing experienced construction management personnel to key positions in-the project organization, employing the Bechtel Corporation as site construction manager, and redefining certain _ responsibilities of site contractors, the architect-engineering firm and the Supply System engineering, quality assurance and construction management organizations.
Positive effects noted during the last six months include improved attention by site personnel to quality program requirements and improved responsiveness to NRC regulations and inspection findings.
During the first half of this appraisal period several items of noncompliance with NRC regulations on quality assurance reouirements for safety related equipment were identified by NRC inspectors.
These findings showed weaknesses in management by some site contractors for performing work according to approved procedures and the licensee's commitments to the NRC. A labor strike was in effect during the first four months of this appraisal period which limited the amount of construction work accomplished.
Subsequently, the Bechtel Corporation was hired to manage and provide surveillance of the quality of work performed by site contractors.
The Bechtel program was fully implemented June 1,1981.
The Region's initial experience indicates that this change will have a positive effect on the project and should substantially improve the quality and management controls at the site.
The new Supply System Project Director is responsive to NRC findings and has exhibited strong leadership in taking actions to resolve quality problems.
The utility previously initiated a training program for contractor craft foremen which should filter down to and be helpful to the craftsmen.
The program has not been as effective as hoped since adherence to construction procedures by personnel for some contractors continue to be a chronic problem. As noted earlier, the recent changes in site management and responsibilities indicate that craft performance in this area is improving.
There was a significant increase in items of noncompliance during the first half of this appraisal period.
These items were confined mostly to the mechanical and HVAC contractors.
Corrective action taken in response to NRC findings was, in some cases, weak.
The licensee's efforts to correct and identify root causes of problems were not always satisfactory. Of ten the licensee was slow to respond to identified weaknesses and some items worsened until they become items of noncompliance for which citations were issued.
Examples of the latter include (1) lack of instructions by the mechanical contractor for installation of piping system weldolets and sockolets, (2) missed hold points for quality checks by mechanical contractor, (3) failures to note applicable WPPSS quality classification on governing contractor drawings.
Closecut of items such as these was delayed because of the lack of central control and assignment of responsibility for this resolution.
Also, an investigation of the HVAC contractor revealed six items of noncompliance which demonstrated that the previous site management and QA organizations were not fully effective in identifing quality problems and providing adequate surveillance of " weak" contractors.
Furthermore, the mechanical (piping and hanger) contractor continues to have administrative problems in controlling work as identified by the results.of NRC inspections and the Supply System's audit of l
January 1981.
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NRR's experience with the licensee has been satisfactory. NRR considers the utility's strength to be its aggressiveness in proposing and developing programs to resolve technical issues in advance of FSAR submittal.
The objective here is to reduce staff review time required to render a favorable licensing decision.
The Region's overall evaluation is that the licensee's performance at this site during this appaisal period was weaker during the first half of this appraisal period. However, new management took substantive actions to improve project and construction management controls of site construction activities and this performance steadily improved.
Because of previous problems experienced with contractors at this site and the deficiencies identified during the first half of this appraisal period, the region plans to continue its examination of the effectiveness of the licensee's new organization. The Region was unable to follow through in these areas the second half of the review period due to a reallocation of resources for the performance of Headquarter's ordered team inspections.
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 criteria:
Category 1.
Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear 4
safety; licensee resources are ample and effectively used such that 1
a high level-of performance with respect to operational safety or 5
construction is'being achieved.-
Category ~2.
NRC* attention should be maintained at normal levels.
Licensee management. attention and involvement are evident and are i
concerned.with nuclear safety; licensee resources are adequate and are rsasonably effective.such that satisfactory performance with respect to operational safety or construction is being achieved.
Ca'tegory 3.
Both NRC and licensee attention should be increased.
.. 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.
III. PERFORMANCE ANALYSIS A.
Quality Assurance 1.
Analysis No items of noncompliance were identified by the Reactor Construction Branch in this area.
Generally, the quality assurance organization and their functions, staffing levels and personnel qualifications met regulatory requirements. Also, the quality programs were structured according to regulatory requirements.
Difficulties encountered in this area were mostly related to the ability of some contractors to resolve identified quality problems in a timely manner, including improving compliance of construction craftsmen with procedure requirements.
Factors contributing to these problems included:
a)
Each of the several site contractors is responsible for promulgating their quality assurance program, including the procedures required for controlling the work, inspection, documentation of results, and record keeping (this results in a large variation between procedures for like work performed by different contractors).
b)
Each contractor is responsible for implementing the quality inspection and quality assurance audit program for their scope of construction work, irrespective of the size of their organization and their experience in implementing quality assurance programs.
c)
A difficult labor management climate exists with quality assurance inspectors included in a strong building trades union (pipefitters local).
d)
Lack of effectiveness of the construction management organization.
Corrective action take by the licensee (Supply System) during this perfor,mance appraisal period included restructuring of their organization and ~employement of a new project management team experienced in large scale nuclear construction projects; employment of a separate organization (Bechtel Corporation, San Francisco Office).
as the construction manager; a unified quality surveillance program implemented by the construction management organizations; and the addition of incentives to' encourage better contractor performance..
The effect of these corrective actions to date is encouraging and, improved leadership and attention to quality problems by all' contractors appears to be occuring. More time is needed, however, to fully assess the effect of these corrective actions.
2.
Conclusion Performance is rated as Category 2.
3.
Board' Comments
^
The board. recommends that a team type inspection be conducted to assess the overall implementation and effectiveness of the corrective actions recently taken by the licensee.
Special attention is warranted in this area because of the many construction contractors, each with their own QA/QC program.
B.
Substructures andFoundations, Concrete and Containment Liner 1.
Analysis No items of noncompliance were identified in these areas.
The contractors performing this work are experienced and have been successfully implementing their quality programs.
2.
Conclusion Performance is rated as Category 2.
3.
Board Comments Continue with the routine inspection program in this area.
C.
Safety Related Structures 1.
Analysis Limited-inspection effort was devoted to this area during this appraisal period.
No items of noncompliance or open items were identified that relateJ to this functional area.
2.
Conclusion The performance in this area is rated as Category 2.
3.
Board Coments Continue with the routine inspection program in this. area.
t D.
Piping and Hangers 1.
Analysis There were four Severity Level V items of noncompliance related to this functional area.
These problems included failure of the Architect Engineer source inspection program -
to identify nonconforming configurations and undersized fillet welds on hangers and supports.
Since this was " owner" supplied material, the mechanical contractor did not have source inspection responsibility and was specifically prohibited from performing a source type inspection.
The contractor now has this authority.
The contractor was.
initially classified as a marginal performer, but the trend appears to be improving in this functional area.
2.
Conclusion The overall performance in this area is rated as Category 2.
3.
Board Comments Include the Supply System's role during inspection in this area. Add emphasis to the routine program to assure that the contractor's performance continues to improve.
E.
Safety Related Components 1.
Analysis There were eight items of noncompliance in this functional area and two open items. One open item dealt with controls for limiting the amount of zinc in the containment building and the second related to controlling the use of temporary welds.
The eight items of noncompliance indicated that the contractor inspectors pay insufficient attention to detail or lack training as evidenced by improper installation of the-component cooling water heat exchanaers (mechanical contractor) and improper welding identified on HVAC duct worP and supports and i
for weldolet/sockotlet branch line connections.
The investigation of the HVAC contractor appears to indicate that
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the licensee has been ineffective in identifying and providing the necessary support to " weak" contractors.
- l.
L 2.
Conclusion Performance in this area is rated as Category 3 -
during this appraisal period.
Performance-is expected to improve due to the management and contractual changes initiated by the licensee, including the utilization of Bechtel Corporation as the construction manager with QA/QC surveillance responsibility.
I 3.
Board Comments Additional inspection effort should be devoted to this important area to assess the effectiveness of the licensee's corrective actions.
i F.
Electrical Equipment, Trays and Wire 1.
Analysis t
There were no items of noncompliance identified in this area; but one open item was identified which related to the failure to include appropriate inspection criteria in the cable installation procedures.
The cable installation procedures did not provide instructions to ensure that the !
l cable pull limits committed to in the PSAR were not exceeded.
Otherwise, the installation of cable trays and supports (only work in progress during SALP review period) was found to be 4
satisfactory.
2.
Conclusion i
Performance in this area is rated as Category 2.
r 3.
Board Comment The board recommends that routine inspection program be continued.
G.
Instrumentation Only-limited inspection activity in this area.
H.
Fire Protection i
i No inspection activity in this area.
I.
Preservice Inspection
[
No inspection activity in this area.
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J.
Corrective Actions and Reoortina 1.
$nalysis The licensee's identification and reporting of construction deficiencies in accordance with 10 CFR 50.55(e) have been sa tisfactory.
The system to assure corrective actions, documented in response to Notices of Violation, 50.55(e) reports, etc., were
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accomplished as stated.in the responses has been weak as evidenced by following two examples.
l a.
WPPSS letter No. G01-80-79, dated February 19, 1980, provided response to a Notice of Violation issued in IE i
Inspection Report No. 50-460/79-13 (item no. 79-13-02 regarding excessive weld weave width).
The actual corrective actions taken. differed significantly from those specified by the letter in that the two nonconformance reports referenced did not pertain to the identified specific noncompliance and the stated reinspection of all stainless steel welds welded by the SMAW process had not been accomplished, as indicated.
This item was discussed in IE Inspection Report No. 50-460/80-16.
b.
WPPSS letter No. G02-79-154, dated March 9,1979, provided the final 50.55(e) report on the WKM Valve Overpressurization deficiency.
The-Appendix A indicated a number-of valves which were to be modified to correct the deficiency.
Two valves listed (RCV-10 and RCV-ll) had not~been modified as stated.
(IE Inspection Report-50-460/81-01) 2.
Conclusion The utilities performance in this area, while somewhat weak,_
is rated as Category 2.
.s 3.
Board Comments The Board recommends continued attention to assure that corrective actions are being effectively implemented.
K.
Procurement 1.
Analysis No specific inspections were made in this functional area during the evaluation period.
However, one item of noncompliance was identified regardi"g procurement controls for paint as discussed in inspection report 80-13.
i i
2.
Conclusion Performance in this area is rated as Category 2.
L.
Design Changes flo specific inspection activity in this area.
ii.
Training flo specific inspection activity in this area.
_9
e IV. - SUPPORTING DATA AND SUMMARIES A.
Noncompliance Data Noncompliance Category Applicable to:
or Severity Level Unit 1 only Unit 4 only Both Units Violation 0
0 0
Infraction 2
0 0
Deficiency 0
0 0
Level I 0
0 0
II 0
0 0
III 0
0 0
IV 3
0 0
V 4
1 2
VI 0
0 1
TOTAL 9
1 3
See Attachment IV-3 for additional noncompliances data. See Enclosure (1) for a list of noncompliances.
B.
Construction Deficiency Reports During the evaluation period the licensee has notified the NRC of seven 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 seven potentially reportable items, three have been determined to be reportable, one has been determined to be not reportable, and three are still under evaluation. During the reporting period six potentially reportable items from the 1976 to 1979 timeframe were examined and closed.
The potential 50.55(e) reports for this evaluation period are listed in enclosure (3).
The written reports submitted by the licensee have generally been timely and complete, as required by 10 CFR 50.55(e).
C.
Licensee Activities During this evaluation period the licensee has made major organizational and managerial responsibility modifications which have significant potential for enhancement of regulatory compliance, construction quality and project completion schedules.
As these changes were only recently established, evaluation of effectiveness will be performed during the conduct of future inspections.
i i
4 1.
Contract Realignment Major construction contracts have been modified to provide for increased licensee management control of work activities. As such, management has significantly increased the sanctions available for use when a particular contractor is found to be dilatory in the discharge of contractual requirements.
2.
Organizational Changes The licensee abolished the integrated organizational structure and has contracted with Bechtel Power Corporation to provide project construction management.
United Engineers and Constructors remains the Architect /
Engineer responsible for project design engineering along with the attendent engineering quality assurance function.
Bechtel has assumed construction management with project quality assurance and quality control surveillance responsibility as defined by the Bechtel QA Topical Report.
The licensee has redefined their quality assurance role as an overview function as opposed to a first line responsibility.
Upper level project management was recently elevated in the corporate heirarchy and reports directly to the Supply System Managing Director.
The Program Director now has increased project management responsibilities and authorities.
Project Ouality Assurance now reports directly to the Program Director rather than " Corporate" Quality Assurance.
D.
NRC Inspection Activities A total of 682 inspector hours were charged to WNP 1/4 during the evaluation period. Of this total, 348 hours0.00403 days <br />0.0967 hours <br />5.753968e-4 weeks <br />1.32414e-4 months <br /> were routine inspection, 204 hours0.00236 days <br />0.0567 hours <br />3.373016e-4 weeks <br />7.7622e-5 months <br /> were in response to allegations, 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> were allotted to a management meeting, and 104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> were for a special inspection of electrical equipment environmental qualifi-cation. Routine inspections were not carried out as planned during February - May 1981 due to the Region's involvement in carrying out Headquarter's ordered team inspections.
Enclosure (2) provides cumulative inspector hours and noncompliances for the past 2 periods of SALP review.
E.
Investigations and Allegations Review The only major investigative activity was an investigation of allegations in the HVAC contractor area..
Thirteen allegations were made, five of which were substantiated.
Six items of noncompliance were issued as a result of the investigation of the allegations and corollary areas.
The noncompliances.were in the general areas of welding control, inspection control, nonconformance control and repair control.
Subsequent to January '31,1981, only one additional inspection was conducted at WNP 1/4, primarily in the electrical area.
Another inspection and an investigation were started but not completed the week of June 22, 1981.
The results of the June 22 inspection will be included in next years report.
Consequently very little new information is available for the 1981 appraisal period beyond that discussed in the February 1981 meeting with the licensee.
F.
Escalated Enforcement Actions 1.
Civil Penalties - none 2.
Orders - none 3.
Confirmation of action letters - none G.
Management Conferences Held During Appraisal Period Two management conferences were held during the appraisal period. The first was a meeting in the Supply System Offices in Seattle, Washington on October 9,1980 to discuss the regional evaluation for 1980.
The second management meeting was held on February 25, 1981 at the NRC regional offices.
The meeting was held at the request of the licensee and was to describe the actions taken by the licensee with regard to the concerns expressed by the NRC at the October,1980 appraisal meeting.
The presentation by the licensee _
indicated a strong commitment to take proper corrective actions on the problems identified at the October meeting.
The Region V staff expressed concern that the number of items of noncompliance had increased in the six-month period following the 1980 appraisal.
The staff pointed out that the basic causes for those violations remain the same, i.e., apparent failure to provide adequate procedures and failure to follow approved procedures.
H.
Other 1.
The presentation by the regional staff to the licensee at the October 1980 SALP meeting indicated improvements were warranted in three areas.
a.
Assuring that PSAR commitments are fullv and properly translated into specifications and thai. requirements of specifications,-and referenced codes and standards, are adequately translated into work and inspection procedures.
b.
Assuring that corrective actions for adverse findings are effective and timely.
c.
Assuring that contractor training activities are effective and craft and inspection personnel are sufficiently knowledgeable and disciplined in the execution of work and inspection procedures.
2.
Since the October 1980 SALP, the regional followup on the SALP conclusions have shown the following:
SALP ITEM N0.1--Assuring that PSAR commitments are fully translated into specifications and specification requirements, including specification referenced codes and standards, are adequately translated into work and inspection procedures.
Findings a.
Architect / Engineer Appropriate and adequate installation and inspection criteria were not supplied for piping branch line connections to craft and inspection personnel.
(50-460/80-15) b.
J. A. Jones (Piping and Hanger Contractor)
(1) Procedures for controlling hold points did not adequately define hold point types or method of indicating hold points on process control sheets.
(50-460/80-15)
(2) Procedures controlling weld and base metal repairs did not adequately specify appropriate inspection techniques,or acceptance criteria to assure piping wall thickness meets ASME code requirements.
(50-460/80-11)
(3) Procedure for control of measuring and test equipment did not implement the traceability of calibrations to National Bureau of Standards.
(50-460/80-16)
(4) Procedural inconsistencies on implementation mechanism definition problems were observed in procedures specifying preheat requirements and temporary hanger installation controls.
c.
UNSI(HVACContractor)
(1) Measures were not provided defining the control and administration of QCPR system.
(50-460/81-02)
(2) Adequate measures were not provided for implementing AWS Dl.1 welding electrode controls.
(50-460/81-02)
(3) Frocedures controlling weld repairs did not adequately specify methods to implement specification requirements.
(50-460/81-02) d.
Root causes The above examples appear indicative of (1) weakness in procedural reviews by WPPSS/UE&C and (2) weakness in the WPPSS/UE&C surveillance system.
SALP ITEM N0. 2-Assuring that corrective actions for adverse findings are effective and timely.
Findings a.
Failure to apprise craft and inspection personnel of appropriate installation criteria (threadolet, i
weldolet, sockelets)
An unresolved item of inspection report 50-460/79-14 was followed up in reports 80-06 and 80-08 and was identified as an example of this concern during the SALP review. This was eventually determined to be an item of noncompliance as stated in report 50-460/80-15.
b.
Failure to affect adequate corrective actions with regard to missed hold points This concern had been identified by WPPSS and J. A. Jones; was followed up by flRC in reports 79-10, 80-05, 80-06, 80-08, and 80-11; was identified in SALP as a concern; and eventually identified as an item of noncompliance as stated in report 80-15.
c.
Failure to post contractor drawings with WPPSS quality class This was an item of noncompliance in report 79-02; documented as an example of failure to effect adeqaute corrective action in report 80-06; was identified in SALP as a concern; was addressed in 80-08 with the
1 observation that additional supplier drawings would be examined in the future; and was eventually identified again as a repeat item of noncompliance as stated in report 80-16.
SALP ITEM NO. 3 -Assuring that contractor training activities are effective and craf t and inspection personnel are sufficiently disciplined and knowledgeable in the execution of work and inspection procedures.
Findings Field Engineers were not sufficiently knowledgeable a.
of code requirements regarding piping branch line connections as stated in report-80-15.
b.
As evidenced by the number of violations issued this past year for failure to follow procedures, it appears that craft and inspection personnel are either insufficiently knowledgeable of procedural requirements or are not sufficiently motivated and disciplined to assure procedure compliance.
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ATTACHMENT IV-3 II.
fiUMBER Arid NATURE OF N0flCOMPLIANCE ITEMS - CONSTRUCTION REACTORS - WNP-1 Inspection floncompliances Functional Area Manhours Severity Level Classification I
II III IV V VI Vio.
Inf. Def.' Dev 1.
Quality assurance 42 2.
Substructure &
foundations, con-crete & liner (containment &
others) 10 3.
Safety-related structures (incl.
welding) 13 4.
Piping & hangers--
o thers--(i ncl.
welding) 58 2
2 5.
Safety-related com-ponents (vessel, 2
internals, & HVAC) 118 2 +(2) 'l )
6.
Electrical equipment, tray & wire 67 7.
Instrumenta tion 5
8.
Fire Protection 0
9.
Preservice inspection 0
- 10. Corrective actions &
reporting 93 11.
Procurement 10 1
12.
Design changes 0
- 13. Training 0
418 0
0 0
3 4 (1) 2 (2)
NOTE:
( ) means the item of noncompliance is applicable to both units.
e x
2.
4 u-.
,,4 ATTACPNENT IV-3 II. NUMBER AND NATURE OF NONCOMPLIANCE ITEMS - CONSTRUCTION REACTORS - WNP-4 Inspection Noncompliances Functional Area
- Manhours Severi ty -Level Classification I
II III IV V
VI Vio.
Inf. Def.
Dev.
1 1.
Quality assurance 31 2.
Substructure &
foundations, con-crete & liner (containment &
others) 7 3.
Safety-related structures (incl.
welding) 10 I
4.
. Piping & hangers--
o thers--(i ncl.
i i
welding) 18 5.
Safety-related com-ponents(vessel, 1+
a internals, & HVAC 106 (2) (1) 6.
Electrical equipment, tray & wire 56 7.
Instrumentation 5
a 8.
Fire Protection 0
j 9.
Preservice Inspection 0
- 10. Corrective actions &
reporting 31
- 11. Procurement 0
i
- 12. Design changes-0
- 13. Training 0
264 0
0 0
0 1
(1) 0
_0 0
0 (2)
~
NOTE:
( ) means the item of noncompliance is applicable to both units.
[
NONCOMPLIANCES Type Functional or Applicibality Area OIL #
Sev Lev 1
4 IV-3 Description Contractor Criterion
.08-11-01 INF 1
4 Pipe fillet welds undersize on B.F. Shaw v
pipe stop. attachment 80-11-02 INF 1
4 Arc strikes removed from pipe JAJ V
w/o using a Work Request 80-13-01 IV 1
11 Failure to provide adequate JAJ IV procurement controls for paint to be used in containment (Decontamination factor 6.3 vs. 10) 80-15-01/02 V
1 5
Failure to install NSW Heat JAJ V
Exchangers.as required by
. drawing (Washers not installed under anchor bolt nuts) and failure to comply with procedure requirements for QV hold' points (NSW Heat Exch No. 2B) 80-15-03 V.
1 4
Failure to provide weld dimen-UE&C V
sions or inspection criteria for weldolet on Containment Spray 80-16-02 V*
1 5-Failure to post contractor dwgs Vendors V
with WPPSS Quality Class Repeat Violation 80-16-04 V*
1 4
Pipe support installation does Huico V
not conform to drawing (beam to wall attgchment plate joint rotated 180 )
81-02-01 V
1 4
5 Failure to provide procedure for UNSI V
use of UNSI QC PR System
- 0riginally cited as Level-IV but spsequent information indicates that the categorization should have been to a lower Severity Leve ENCLOSURE (1) Pg. 1 of 2
... NONCOMPLIANCES Type Functional or Applicibality Area OIL #
Sev Lev 1
4 IV-3 Description Contractor Criterion :
81-02-02 V
4 5
Failure to comply with NCR UNSI V
reporting procedure.
NCR not written - welding done with wrong polarity
. 81-02-04 V*
1 4
5 Failure to control welding UNSI IX electrodes per AWS D.l.l.
Low Hydrogen electrodes reissued w/o redrying 81-02-05 IV 1
5 Failure to install / inspect HVAC UNSI V
Supports as req'd by procedure 81-02-06 IV 1
5 Failure to install / inspect HVAC UNSI V
Plenum as req'd by procedure 81-02-08 VI 1
.4 5
Failure to implement procedure UNSI V
requirements for repair weld documentation 4
l
- 0riginally cited as Level IV but subsequent information indicates that the categorization should have been to a lower severity level.
i ENCLOSURE (1) Pg. 2 of 2 9
1 4
=. - -.. - -
. Enforcement History Hf1P 1/4 fiumber of Items of Inspection Hours Per SALP PERIOD Inspection Hours floncompliance Item of floncompliance 5/79 - 7/80 1257 11 114 8/80 - 6/81 682 16 43 EllCLOSURE (2) Pg.1 of 1 e
... 1981 SALP - 50.55(e) Summary Notification Licensee Item Description
'Date Correspondence Evaluation 1.
Induced Flux Error in excess of 11-03-80 G01-80-379 Reportable PSAR specification 12-12-80 Interim 2.
Incomplete-Analsysis of piping 11-13-80 G01-80-380 Potential attached to RCS under LOCA 12-12-80 conditions Interim 3.
Bostrom Bergen Metal Products 08-80 G01-81-03 Potential Embedment Weld Problems 1-7-81 Interim G01 167 Interim 4.
GSB Air Intake Design Def.
12-08-08 G01-81-02 Reportable 1-6-81 Interim G01-81-164 6-1-81 4
Interim
~
5.
Lack of Fusion in DHR HX tubes 1-07-81 G01-81-25 Potential 1-30-81 Interim 6.
Spent Fuel Cask Handling-does 1-07-81 G01-81-279 Reportable not meet design criteria 2-2-81, Interim G01-81-163 6-1-81, Interim 7.
Skid Maintained Equipment -
. 5-18-81 Not Reportable Anchor Bolts not properly torqued ENCLOSURE (3) e 3
,-.-s,.
,.a
' VI, flRR PERFORMANCE EVALUATION Facility: WNP UNITS 1 AND 4 Project Manager:
R. W. HERNAN Appraisal Period: July 1, 1980 to June 30, 1981 A.
Performance Elements 1.
Quality of Responses and Submittals WPPSS is in the process of preparing a Final Safety Analysis Report on WNP-l/4 for submittal to the NRC in December 1981.
Most of the activity requiring responses has therefore been related to post-TMI generic problems dealing with problems specific to Babcock and Wilcox design.
One major task requested of WPPSS in early 1980 was perfonnance of a loss of main feedwater risk analysis which was scheduled to be, and in fact was, submitted to the staff by July 22, 1980.
In addition to meeting the committed date, WPPSS recognized the need to change the normal and fail position of some valves in the auxiliary feedwater system to further improve system reliability as the result of this anslysis.
During this report period WPPSS also submitted:1) an upgraded emergency preparedness plan which includes provisions for WNP-1/4 during their construction phase;and 2) the environmental /
seismic qualification for WNP-1/4 Class IE instrumentation and electrical equipment.
No instances of poor quality and/or timing of WPPSS responses have been identified during this period.
2.
Efforts in Obtaining Acceptable Responses cr Submittals Generally the WPPSS response to NRC staff requests during this' period have been both timely and substantial.
The amount of time and effort dedicated to the limited number of responses during the period appear to have been commensurate with the importance of the request. NRR considers that WPPSS makes a concerted effort as a matter of course to take the initiative in pursuing all aspects of issues.
There are presently a number of areas (including an independent design review program, resolution of the small break LOCA model problem and proposal of a method to provide instrumentation for detecting inadequate core cooling) in which WPPSS is establishing meaningful programs.
In preparation for submitting an FSAR, WPPSS has been sensitive to anticipating technical or administrative problems which could delay the staff's acceptance review and subsequent docketing of the FSAR.
l 3.
Working Knowledge of Regulations, Guides, Standards and Generic l
Issues NRR considers the knowledge of the utility in thes'e areas is Category 2 with no significant weaknesses or strengths noted.
(
.s 4.
Technical Competence The technical competence within the WPPSS organization is
' Category 2 for a utility with nc nuclear plants yet operational.
The utility appears to make effective use of consultants in areas requiring specialized technical expertise.
5.
Conduct of Meetings with NRR Generally, WPPSS has been very cooperative in meeting with NRR when an issue could most efficiently be resolved by a meeting and has dedicated the necessary effort to adequately prepare for these meetings.
l 6.
Long-Standing Open Items - None 7.
Organization and Management Capabilities Changes in top utility management, internal organizational changes and changes in the roles of the major contractors involved indicate an aggressive attempt on the part of the utility to correct some of the management-related problems which may have existed in the past.
These changes were initiated for the most part in late 1980.
8.
Results of Operator Licensing Exams - none this period 9.
Performance on Specific Issues WPPSS has requested to meet with NRR to discuss two programs which are of mutual interest. On July 29, 1981 a meeting is scheduled to allow the utility and Babcock and Wilcox to present their approach to meeting the requirements of item II.F.2 of NUREG-0737 " Instrumentation for Detection of Inadequate Core Cooling".- On August 20, 1981, the utility will present a plan for implementing the Independent Design Review (IDR) concept in the licensing of WNP 1, 3, 4 and 5.
NRR considers that the aggressiveness demonstrated by WPPSS in these cases will enhance timely completion of the licensing process for UNP-l/4.
B.
Observed Trends in Performance, if any On the basis of the relatively good responses to staff requests, initiative towards resolving issues in advance and management /
organizational changes during the past year, NRR considers the performance trend of WPPSS in licensing matters to be improved.
C.
Notable Strength and Weaknesses 1.
Strenoths NRR considers the utility's strength to be it's aggressiveness in proposing and developing programs to resolve technical issues in advance of-FSAR submittal with the objective of reducing staff review time required to render a favorable licensing decision.
r;;
- 1, 2.
Weaknesses WPPSS needs',to develop more confidence in their ability to make technical and administrative decisions relative f
_to licensing matters. There have been a few occasions wherein staff written approval of certain licensing matters has been requested even though application for an operating license has not yet been tendered. Diversion of NRR staff
~ reviewer manpower to these items could have a detrimental affect on reviews required for near term operating licenses.
NRR believes that the utility has the resources to make these decisions in-house without guidance from the staff.
D.
Overall Sumary On the basis of the limited activity which has transpired in the licensing area during this evaluation period, NRR considers WPPSS performance is Category 2 overall.
The utility has taken measures to improve completion of plant construction and licensing during the past year. Frequent contact with NRR on matters which will affect licensing exists and is considered to be a key factor in timely completion of the licensing process.
Submittal of the license application on time in December 1981 will provide a more meaningful basis for evaluation during the July 1981 -
June 1982 period.