ML20052F366
| ML20052F366 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Columbia |
| Issue date: | 04/01/1980 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML19250J515 | List: |
| References | |
| FOIA-81-378 NUDOCS 8205120388 | |
| Download: ML20052F366 (9) | |
Text
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Washington Nuclear Project No. 2 Evaluation Period:
(4/1/79-4/1/80)
I.
General On June 17, 1930, NRC issued a 10CFR50.54(f) inquiry on quality assurance, simultaneous with a notice of violation and $61,000 civil penalty, as a result of serious deficiencies in the sacrificial shield wall, pipe whip restraints, and other construction deficiencies.
The 10CFR50.54(f) inquiry required the licensee to provide information on the steps to be taken to provide reasonable assurance that the approved quality assurance program has been implemented and the steps to be taken to strengthen management control of the project.
On July 17, 1980, the licensee responded to these enforcement actions by halting work by the prime mechanical contractor.
The licensee also stopped work by all site contractors pending an evaluation of their detailed work methods to assure that there would be no quality problems upon their return to work.
The following nine months were spent on the planning, mobilization, and operation of three task forces to implement the corrective actions outlined in the response to the 10CFR50.54(f) inquiry and notice of violation.
Task Force I was established to expedite resolution of the outstanding problem backlog at WNP-2.
The task force performed an initial review of outstanding problem areas which resulted in recommendations to improve controls over backlogs and short term goals for reduction of backlogs.
These recommendations were assembled into an action plan for implementation which is essentially complete.
Task Force II consisted of a restart plan to ensure that contractor quality controls were effective and that any resumption of work would have minimal risk of quality problems and would not preclude reinspection of completed work.
These efforts were essentially cpmpleted by the end of March, 1981 with most contractors released to start work.
Task Force II also consists of a program to reverify ghe adequacy of completed safety-related work.
Detailed plans for
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accomolishing this activity are being formulated.
Task Force III was established to disseminate the lessons learned i
at,WNP-2 to other licensee projects and to r view and-evaluate the management systems of site organizations, including site contractors.
These efforts are continuing.
Following the appointment of Mr. R. L. Ferguson as Managing Director j
in June,1980, substantial Supply System and WNP-2 organizational changes were announced.
These changes include the establishment of a site-based Program Director for WNP-2 who is responsible for the i
l construction, startup, and initial power generation of the facility.
f Other actions incluced a change in the reporting relationship of the WNP-2 Project Quality Assurance Manager from the Corporate Quality Assurance Director to the WNP-2 Program Director and the establishment of a new Corporate Directorate of Nuclear Safety.
8205120388 811112 PDR FOIA BELL 81-378 PDR t
l would assume the function of Construction Manager, including Quality
_.I In March, 1981, it was announced that Bechtel Power Corporation i
Assurance, effective June 1, 1981.
Bechtel is also functioning as l
systems completion contractor and will perform the reverification y
I of completed safety-related work.
As systems completion contractor, r
Bechtel may be assigned responsibility for completion of a contractor's
[
work package.
This provides a clear alternative to a contractor L
whose performance may be unacceptable.
The integrated WPPSS/ Burns and Roe, Inc. organization has been.
abolished with Burns and Roe retaining the function of Architect-Engineer.
The licensee is now performing quality assurance ovepview.
l The licensee has also withdrawn from direct involvement in engineering l
activities specific to the project, assigning these functions to I
the Architect-Engineer.
The Architect-Engineer moved more engineering functions and personnel to the site and opened an office in the
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nearby town of Richland.
This supports evaluation and disposition
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of engineering questions relating to deficiencies found during the reviews of detailed work methods and backlogs of nonconformance l
documents.
i II.
Soecific f
i A.
Contention I
i i
The facility displayed evidence of weakness in the area of " quality 3
assurance (including management and training)."
l 1.
Basis i
i
{
Thirty-three items of noncompliance were identified.during the j
appraisal period, representing a significant increase from previous years.
In terms of inspection manhours per noncompliance, the i
enforcement history indicated a deterioration in licensee performance.
For the first half of 1980, the noncompliance rate was 21 insoection manhourspernoncompliance,comparedg51 hours /noncompliancein1979 i
and 142 hours0.00164 days <br />0.0394 hours <br />2.347884e-4 weeks <br />5.4031e-5 months <br /> / noncompliance in 1978.
All of the current items of noncompliance related to work performed by the licensee's contractors.
ThispegrmancetrenddevelopeddespiteanNRCEnforcementConference in 1978 and subsequent managemen lessthansatisfactoryperformance[3geetingsin1979,whichaddressed l
Of the 33 items of noncompliance identified during'the current appraisal period, five were repetitious of previous NRC findings, i
indicating a weakness in the licensee's ability to effect lasting resolutions to quality concerns.
Sixteen of the items of noncompliance involved work which was performed during the 1976 to 1978 time frame, raising questions about the effectiveness i
of the licensee's quality assurance program during that time.
While two of the items of noncompliance related specifically -
to inadequate qualification of personnel, '.he repetitive l
nature of some findings, and the more general deficiency of l
3 poor procedure implementation indicated a weakness in the licensee's employee train.ing and indoctrination program.
,,-a-
1 In summary, the significant increase in the number of items of noncompliance, including the repetition of five items of noncompliance, disclosed ineffective quality assurance program implementation with inadequate control of contractor's activities.
A below average rating was, therefore, assigned to the area of quality assurance.
2.
NRC Actions NRC actions during the appraisal period included a management meeting in April 1979 reiterating NRC concerns with the lack of effectiveness pf the licensee's quality assurance program (concerns which were previously expressed in an Enforcement Conference'in May 1978).
Other actions included a major investigation relating to the fabrication and erect pipewhiprestraints.{ggofthesacrificialshieldwalland Two "Immediate Action Letters" were issued in November 1979, effectively stopping further construction activities in those two areas pending NRC verification that effective control measu es were implemented for correction and repairs.
Based upon the results of the above investigation and the routine inspection program, a Civil
$61,000)wasleviedonthelicensee.{ggalty(intheamountof In addition, a 50.54(f) request was issued to obtain further information regarding the j
adequacyofpreviouslycompletedworkandwhethgg)currentand future work is (will be) adequately controlled.
The NRC also assigned a resident construction inspector to the WNP-2 site to monitor licenses corrective actions.
3.
Licensee Actions The licensee has undertaken major organizational and personnel changes in addition to the development cf a new quality assurance program.
The organizational and personnel changes included the assignment of a new Managing Director, and a project completion contractor (Bechtel).
The new quality assurance program is currently under NRC review.
This program includes additional management actions to assess the acceptability of previously l
completedwork;examigy}ionofworkprocedures;andexpanded training requirments.
B.
Contention The facility displayed weakness in the area of " safety-related structures."
1.
Basis During the appraisal period, eight items of noncompliance were j
issued which relate to safety-related struct the reactor vessel sacrificial shield wall) g{gs (primarily The most I
significant noncompliance related to the failure to properly weld the sacrificial shield wall together, a concition which (if.it had gone undetected) would have left the structure accidentconditions.gngtheshearforcespostulatedduring incapable of withsta Other items included work on structures without qualified procedures, failure to qualify inspection personnel, and failure to maintain adequate records.(4) 2.
NRC Actions NRC actions are summarized under item A.2. above.
In addition, the NRC performed a detailed technical review of the licensee's assessment of the structural adequacy of the sacrificial shield wall as well as the licensee's proposed repair program.(8) 3.
Licensee Actions In addition to the programmatic corrective actions discussed in A.3 above, the licensee has performed:
a 100% reinspection of all accessible surfaces of the sacrificial shield wall; extensive technical analysis of the defects and wall integrity; and a thorough examination of all records related to the erection and inspection of the structure.
C.
Contention The facility displayed weakness in the area of piping and pipe supports."
1.
Basis During the appraisal period, fourteen items gnoncompliance were issued relating to piping and pipe supports.
Major deficiencies were identified in pipe whip restraints used inside the containment to minimize the detrimental effect of a major break in a steam line or other pipe.
Analogous to the problems identified with the sacrifical shield wall, the NRC nonccmpliances pertained to:
work on the restraints without qualified procedures; failure to quagy inspection personnel and failure to maintain adequate records.
Other noncompliances issued during the appraisal period included:
waterpipewelds;gpostweldheattreatmentofmainsteamandfeed-improper control and the failure to pgerly perform inspections of pipe supports and attachments to pipe The subject of inadequate basisforninepreviousitemsofnoncompliance.ff0pygitieswasthe control over pipe support erection and inspecti 2.
NRC Actions In reference to the piping post weld heat treatment problems, the NRC retained an independent consultant who performed metallographic tests on pipe welds to determine the acceptability of the hardware.
It was concluded that, for those welds examined, the improg heat treat controls did not result in damage to the pipe.
The licensee's performance in the area
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ofpipingandpipesugortswasaddregdinmanagementmeetings(1) and the Civil Penalty > and 50.54(f) correspondence.
Licensee corrective actions are being monitored by the NRC Resident Inspector at the site.
3.
Licensee Actions The licensee has committed to perform further investigations and technical analyses to verify the adequacy of the post weld heat treatment procedure used.
Other reviews and analyses are underway to address the problems related to pipe whip restraints and pipe supports.
Deficiencies in pipe whip restraints have been identified by nondestructive testing and the licensee is evaluating the feasibility of onsite repair of these deficiencies.
The reverification program will include detailed reinspections of pipe supports and restraints.
D.
Contention Weaknesses were identified in the area of " electrical equipment."
1.
Basis Licensee weaknesses in the area.of electrical equipment contributed to three items of noncompliance during the appraisal period; these g :
failure to properly install emergency battery breakers,gproperidentificationofsafety-relatedcircuit racks; i
and the installation of non quality I
instrumentation into the reac. tor protection system 2.
NRC Action The NRC has monitored the licensee's actions taken in. response to the specific items of noncompliance.
These actions are still in progress so that a final assessment in this area has not been reached.
3.
Licensee Action The licensee has initiated actions to properly resolve the items of noncompliance including proper identification of safety-related circuit breakers; procurement of new battery racks; and verification that the requisite quality characteristics have been specified for reactor protective system instrumentation.
l The Architect-Engineer has increased the size of the onsite l
electrical engineering organization which is now reviewing and rewriting FSAR Chapters 7 and 8 and evaluating the degree of compliance with regulatory requirements.
E.
Contention Weaknesses were icentified in the area of " electrical cabling (trays and wires)."
1.
Basis While only one item of noncompliance relating to electrical cable installation was identified during the appraisal period (cable identification coding), a significant item of concern relating to electrical cable separation has remained unresolved.
In 1978 and s
1979, the NRC expressed concern to the licensee about the lack of definition {g4 gg) licensee's requirements for electrical cable t
separation.
From the NRC perspective, it was not assured that final cable installations would be in accordance with industry standards (IEEE-384) and the NRC Regulatory Guide (RG-1.75).
During the appraisal per.iod, it was determined that installed cabling was not in full accordance with these documents.
The technical accept-ability of the as installed configurations has not been finally determined.
2.
NRC Actions
-The NRC verified proper resolution of the incorrect cable identification coding.
The Office of Nuclear Reactor Repyggtion hasreviewedthelicensee'sproposedseparationcriggyja and has taken excepti3n to several of the criteria.
3.
Licensee Action The licensee has properly resolved the item of noncompliance involving cable identification coding.
A revised separation criteria has been developed and submitted to the NRC as a part of their FSAR. As indicated abov.e, the NRC Office of Nuclear Reactor Regulation has taken exception to some areas of the revised separation criteria.
The licensee is now evaluating these exceptions to determine their degree of compliance to the NRC position.
F.
Contention Weaknesses were identified in the area of " instrumentation."
1.
Basis During the appraisal period, six items of noncompliance relating to instrumentation were identified.
Four of these items were repetitive items of noncompliance involving the failure to maintain cleanliness of instrumentation tubing and piping.
The remaining items involved welding and inspection of instrumentation piping.
2.
NRC Actions management meetings,gygf the noncompliances wgg) discussed in (6)
The repetitive natur and the Civil Penalty and 50.54(f) correspondence.
Correction of the specific items of noncompliance is being monitored by the NRC staff.
t
3.
Licensee Actions The licensee's response to the items of noncompliance and the 50.S4(f) letter included actions to ensure that procedures adequately reflect the requirements of applicable codes and standards and that contractor personnel are adequately trained to these procedures.
The restart of work by the instrument contractor has been accompanied by heightened quality assurance surveillance.
Protection has been provided for instruments and startup personnel have been instructed in the maintenance of instrument system cleanliness.
G.
Contention "The area of quality assurance was characterized by ineffective program implementation and inadequate control of contractor activities."
(See Contention A)
H.
Contention "There were numerous items of noncompliance involving procedure and drawing adherence, control of special processes (welding and NDE), and maintenance-of quality assurance records."
(See Contentions B and C)
I.
Contention "The licensee had extensive difficulties in installation of safety-related pipe whip restraints, and in.the erection and welding of the sacrificial shield wall."
(See Contention C regarding pipe whip re'straint problems and Contention B regarding erection and welding of the sacrificial shield wall problems)
J.
Contention
" Licensee submittals to NRR displa'ed technical weaknesses and the licensee y
was not responsive to NRC technical requests on various occasions."
1.
Basis The staff rejected in June 1977, the FSAR which was tendered in March 1977 partially on the basis that Chapter 7 was unacceptable.
Specifically, this section was completely outdated and did not -
reflect the as-built plant or licensing progress on similar plants (LaSalle, Zimmer).
FSAR was retendered (3/78) and docketed in June 1976 with deficiencies still in Chapter 7 Prior to the NRC action (see below), it appeared that the applicant had given inadecuate in-house manpower to the I&C (Chapter 7) material supplied by the NSSS, which was not current.
2.
NRC Action First, NRR requested that the more deficient portions of the FSAR be rewritten to conform to Reg. Guide 1.70 and the SRP.
Next, we requested that WpFSS conform its application to the guidance /
examples provided by responses of other applicants to staff questions and positions and to conclusions in our SERs.
- Finally, we requested that where practicable, resolutions developed by other OL applicants for similar facilities be applied. We trans-mitted these requests to WPPSS in our letter of !iarch 28, 1979.
3.
Licensee Corrective Action In response to the staff's requests, the applicant submitted or completely revised Chapter 7 in July 1980. Additionally, the applicant hired more technically qualified people and assigned them to the task of implementing both the spirit and the letter of the staff's requests on this matter.
This included signifi-cant hardware changes in the plant to conform to the appropriate IEEE standards and the staff requirements on similar plants. As a result of the firm action by NRR in the I&C review at the beginning of this evaluation period, the licensee took actions in this period which corrected most of the serious deficiencies slightly after the end of this evaluation period.
e G
y References (1) USNRC RV WNP-2 SALP Rpt No. 50-397/80-11 (2) USNRC RV WPPSS Enforcement Conferences Rpts 50-397/78-04; 78-06 (3) USNRC RV WNP-2 Inspection Rpt 50-397/79-08 l
(4) USNRC RV WNP-2 Investigation Rpt 50-397/80-04 (5) USNRC (Stello) to WPPSS ltr of 6/17/80 - Civil Penalty r
(6) USNRC (Stello) to WPPSS ltr of 6/17/80 - 50.54(f) Request for Info.
(7) WPPSS ltr No. G02-80-153 to NRC (Stello) of 7/17/80 Response to 50.54(f) Request for Info.
(8) USNRC RV to WPPSS ltr of 1/20/81 - Work Release - Sacrificial Shield Wall (9) USNRC RV WNP-2 Inspection Rpt 50-397/79-10 (10) USNRC RV WNP-2 Inspection Rpt 50-397/77-07
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(11) USNRC RV WNP-2 Inspection Rpt 50-397/78-03 (12) USNRC RV WNP-2 Inspection Rpt 50-397/79-04 (13) USNRC RV WNP-2 Inspection Rpt. 50-397/79-16 (14) USNRC RV WNP-2 Inspection Rpt 50-397/78-10 (15) USNRC RV WNP-2 Inspection Rpts 50-397/79-04; 79-09; 79-16 l
(16) OIE:RV to IE:HQ ltr of 4/29/80 - WNP-2 Cable Separation (17) USNRC:
NRR to WPPSS ltr of 5/4/81 - WNP-2 Cable Separation I
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