ML20062D484
| ML20062D484 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/04/1982 |
| From: | Wilcove M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Wilt D SUNFLOWER ALLIANCE, WILT, D.D. |
| References | |
| ISSUANCES-OL, NUDOCS 8208060097 | |
| Download: ML20062D484 (23) | |
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August 4, 1982 Daniel D. Wilt, Esq.
P.O. Box 08159 Cleveland, Ohio 44108 In the Matter of CLEVELAND ELECTRIC ILLUMINATING COMPANY, ET AL.,
(Perry Nuclear Power Plant, Units 1 and 2)
Docket Nos. 50 440 OL & 50-441 OL Dear Mr. Wilt; In accordance with the Staff's response to Sunflower Alliance's interrogatories, dated August 2,1982, specifically regarding 71
interrogatories 66 and 68, enclosed are the documents referred to. {
Sincerely, y p'
Michael N. Wilcove
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Counsel for NRC Staff g/)'\c,A
Enclosures:
As stated cc w/ enclosure:
Peter B. Bloch, Esq.
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Dr. Jerry R. Kline Mr. Frederick J. Shon DISTRIBUTION: ,
Jay Silberg, Esq. NRC Docket -
Donald T. Ezzone, Esq. LPDR E Susan Hiatt PDR Jeff Alexander FF (2)
Terry Lodge, Esq. Christenbury/Scinto Robert Alexander Murray John G. Cardinal, Esq. Rutberg Wilcove Atomic Safety and Licensing Board Chandler Schwencer Atomic Safety and Licensing Appeal Board Vogler Stefano Docketing and Service Section Lewis Chron.
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DATE : 8/ % /82 : 8/ 4 /82 : : : : :
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- April 2, 1980 MEMORANDUM FOR: Harold D. Thornburg, DRCI, IE-FROM: G. Fiorelli, Chief, RCSES Branch, RIII
SUBJECT:
TI 2512/4 - INTERVIEWS WITH CRAFTSMEN AT CONSTRUCTION SITES In accordance with the requirements of TI 2512/4, Perry was selected as the Region III site for trial implementation of the Temporary Instruction. The licensee, the Cleveland Electric Illuminating Company, was so notified on October 16, 1979. Interviews with thirty craf tsmen, foremen, and QC inspectors were then conducted during unannounced inspections on October 17-18, 1979, November 14-15, 1979, and February 27-29, 1980.
The interviews were conducted by two RIII inspectors (one being the Perry project inspector), and one RIII Section Chief. Interviewees were selected by two methods. Eight personnel were randomly selected during plant walkthroughs and 22 persons were randomly selected from personnel rosters and timekeepers' records. The attempt was made in all cases to obtain interviewees who were of journeyman or equivalent level and who had been at the site at least three months, although several of the individuals varied from those requirements.
Each interviewee was informed of the reasons for the interview and the fact thst a random selection technique was being used, and was told that any concerns which he expressed would remain strictly confidential. All contractor managements had previously been informed by the licensee that the interviewees were not to be questioned regarding the content of the interviews and that no discriminatory or personnel actions were to be taken against those interviewed. .
l.. Interviewees were asked whether they had any concerns regarding the ,,
l quality of construction at the site, whether they were aware of any le l
instances where construction did not meetjprescribed requirements and corrective actions were not taken, and whether they were aware of any day-to-day problems or irregularities affecting quality which the NRC should know.
All of the licensee and contractor personnel contacted during..this effort were fully cooperative. The craftsmen who were interviewed exhibited pride in their work and in general were positively impressed with the level of quality involved in the site construction activities.
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The breakdown by discipline of the personnel interviewed is as follows:
two ironworkers, four carpenters, one laborer, five pipefitters, (of which three are also welders), one storekeeper, one electrician, one cement finisher, four welders, six boilermakers, one te'chnician, one material receipt inspector, and three QC inspectors. Included in the above were three foremen and two union stewards.
Among the craftsmen interviewed, the amount of site time at Perry varied from three months to several years.
Only three or four of the interviewees had previous nuclear construction experience.
No formal allegations were made during the interviews; however, one concern was raised which was considered to warrant a followup inspection.
The concern involved the amount of grinding required on the weld end preparations for the reactor vessel recirculation nozzle modifications and the fact that the acceptance' criteria for the weld end preps had been changed.
Two Region III inspectors returned to the site on P. arch 4, 1980 and performed an inspection in this area. The results of that inspection are contained in RIII Inspection Report (50-440/80-03; 50-441/80-03). No noncompliances were identified during the followup inspection.
The remainder of the c6Ements elicited from the interviewees were grouped into several categories for discussion with the licensee and for future
! routine followup by RIII. The general categories are as follows:
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- a. Housekeeping / industrial-safety concerns. A list of specific h.. concerns in the areas of housekeeping and industrial safety was compiled by the interviewers and was discussed with the licensee.
! b. Training and indoctrination of workers. The inspectors noted that although most of the interviewees take part in regularly scheduled safety meetings, the interviews indicated a general lack of GA indoctrination meetings for the contractor craftsmen.
- c. Qualifications and availability of QC inspectors. The inspectors 1 received a number of comments pertaining to the lack of knowledge P.
i of some contractor QC inspectors, as well as the frequent '
unavailability of the DC inspectors when required to witness examinations or to signoff hold points.
During the February 29, 1980 exit interview, the licensee agreed to evaluate the need for improvements in the above areas. These three areas were designated in the RIII inspection report as an unresolved Jitem to be i reviewed in future inspections. With regard to the housekeeping / industrial-safety concerns, the RIII inspectors informed the licensee that the results of the future NRC inspections will determine whether any of the concerns are referred to OSHA for investigation.
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H. D. Thornburg -
April 2,1j80 s
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The total amount of time required to accomplish the interview program outlined by TI 2512/4, including the time spent in preparation, selection of interviewees, followup on concerns, and documentation was as follows:
Preparation 12 man-hours Travel 63 man-hours on site Interviews 97 man-hours On-site followup 8 man-hours Documentation 28_ man-hours 203 man-hours As noted above, the RIII inspectors received full cooperation from the licensee, the contractors' managements, and the interviewees. Many of the craf tsmen expressed highly favorable opinions reDarding the interviews.
The positive aspects of the interview effort appear to be (1) a greater visibility for the NRC inspectors with the site craftsmen, with a resulting increase in communication between the craftsmen and the inspectors, and (2) a greater feeling of participation by the craftsmen in matters relating to the safe construction of the plant, a feeling which should translate into improved workmanship. ~
On the other hand, the odds of randomly selecting a craftsman who has a substantive allegation to make are so low as to make the interview program concerns. an inefficient method for identifying significant safety related Experience at this site and at other sites has shown that a craftsman NRC.
who wishes to make an allegation will find a way to contact the The item of concern discussed above regarding the reactor vessel recirculation nozzles was initially telephoned to the project inspector at his motel by a site craf tsman, who was then " randomly" selected as one of the interviewees. No other significant safety related concerns were identified during the thirty interviews.
In summary, the results likely to be obtained from a formal interview i
J- program do not appear to warrant the amount of inspection time which 5
! would have to be diverted to that effort from other areas. However, the positive aspects of discussions between NRC inspectors and site craf tsmen, as noted above, do appear to warrant an effort to inccease such communication. A logical method for accomplishing that increase would be the inclusion of a requirement for informal discussions with two or more craftsmen in each NRC inspection procedure involving observation of work activities.
If you have any information, questions please call. regarding the above, or require any addit.ional l
r s &d G. Fiorelli, Chief '
Reactor Construction and l
Engineering Support Branch l .s
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f./ ittuumAtisc stoce,e rusue souaxt . ctivrano. osio 44 set . Tttrenowt (21s> c22 52so .[uAit Ao,carss : r.o. sog.sooo Dalwyn R. Davidson .
viet eatsiotsi systru asamt tamo aso cossinuction Dece=ber 7, 1979 Mr. James G. Keppler
, Director of Region III
, Office of Inspection and Enforcement U. S. Nuclear Regulatory Co==ission 799 Roosevelt Road Glen Ellyn, Illir.ois 60137 RE: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Final Report on S & M Constructors, Inc.'s Quality Assurance Program Breakdown Regarding Control of S & M Subcontractor:
The Halvorsen Boiler and Engineering Co=pany
Dear Mr. Keppler:
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Pursuant to the Interim Report of February 12, 1979, please find attached the Final Report on S & M Constructors, Inc. 's Quality Assurance Program breakdown regarding control of S & M Constructors, Inc.'s subcontractor:
The Halvorsen Boiler and Engineering Company.
The attached Final Report includes a description of the deficiency, an analysis of the safety i=plications, and the corrective action taken, as required by 10CFR50.55(e).
As a reruit of this Final Report, the condition described herein is no longer considered a Significant Deficiency.
Very truly yours.
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is ll 'An th D. R. Davidson Vice President System Engineering and Construction ksz -'
Attachment J
cc: Victor Stello, Director ,
Office of Inspection and Enforcement , b U. S. Nuclear Regulatory Co:;: mission Washington, D. C. 20555
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FINAL REPORT ON SIGNIFICAh7 DEFICIENCY S & M CONSTRUCTORS, INC.
QUALITY ASSURANCE PROGRAM BREAKD0'JN REGARDING C0h7ROL OF S & M SUBC0hTRACTOR, THE HALVORSEN BOILER AND ENGINEERING CO.
2 f, PERRY NUCLEAR POWER PLAh7 3,'.
DOCKET NOS. 50-440; 50-441 THE CLEVELAND ELECTRIC ILLUMINATING COMPANY t
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DECEMBER 7, 1979
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tapancRAMW2ClWFWLGIFICAfC DEFICIENCY o
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In accordance with the requirements of 10CFR50.55(e), this is the Final Report on the Significant Deficiency on S & M Constructors, Inc. Quality Assurance Program breakdown regarding control of S & M Subcontractor, The Halvorsen Boiler and Engineering Company.. and includes: (a) A description of the deficiency; (b) An analysis of the safety implications and (c) Sufficient information to permit analysis and evaluation of: (1) the deficiency and (2) Corrective Action.
DESCRIPTION OF DEFICIENCY A. INTRODUCTION The Interim Report regarding this Significant Deficiency was trans-mitted to the NRC on February 12, 1979. Although the transmittal to
.this Interim Report states in the last paragraph that the Final Report is scheduled to be in your office by June 1, 1979, there were two (2) letters written extending this date. One (1) letter dated May 29, 1979, requested an extension to August 31, 1979, and the other letter, dated August 29, 1979, requested an extension to December 15, 1979.- '
E. PROGRAM DEFICIENCIES Numerous hardware deficiencies identified on various Nonconformance Reports and audit reports led Projact Organization personnel to determine that major deficiencies were present in S & M Constructors, Inc. Quality Assurance Program.
The Interim Report details the specific program deficiencies known at the time of that writing. However, two (2) program. review audits, Audit Numbers 214 and 249, revealed deficiencies in S & M Constructors.
Inc. Quality Assurance Program in other areas of 10CFR50, Appendix B, and resulted in S & M Constructors, Inc. revising in total their Quality Assurance Manual. This revised Quality Assurance Manual, f:-
along with the Corrective Action section of this report is sufficient action to assure repetition in this area does not occur.
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DESCRIPTION OF DEFICIENCY (CONT'D.)
C. HAFN'ARE DEFICIENCIES A detail of the hardware deficiencies existent in the work perforned by Halvorsen Boiler and Engineering Cc=pany were identified 'on Non-conformance Report CQA 035 and was limited to the velds on the two (2) Intake Structures. A su==ary of the specific deficiencies on the two (2) Intake Structures is provided in the Interim Report.,
Since the issuance of the Interim Report, a detailed study was made in regards to other velds made by The Halvorsen Boiler and Engineering Co=pany.
Discharge These other velds are limited to certain areas of the Structure.
Structure is as follows: A su= mary of the fabrication of the Discharge 1.
The Discharge Structure consists of three (3) co=ponents:
- a. The Discharge Nozzle
- b. The Outer Shell
- c. Associatei Connections (Interior Bracing) *
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The Discharge Nozzle including the six (6) foot diameter discharge shaf t was fabricated by others than The Halvorsen Boiler and Engineering Company.
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The outer shell and associated connections were fabricated by l The Ha3vorsen Boiler and Engineering Co=pany. The latter consists of non-safety related material which is attached to the outer shell, and was for the purpose of assisting in installing the Discharge Structure in the lake.
Ihe outer shell is attached to the Discharge Structure via this interior bracing.
Since the issuance of the Interim Report. Engineering has re-analyzed this structure to determine the requirement for the outer shell as a load carrying member.
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In addition to the above, there is a cover plate with 'an assortment of valves bolted to the discharge nozzle. This cover plate is non-safety related, and is used to seal the Discharge Tunnel frow the intrusion of water.
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l3 - . , , ARALYSIS OF SAFEIY IMPLICATIONS -
As stated in the Interi Report, "The safety i=plications of the effects of the Quality Assurance Program breakdown vill be identical to the safety implications of the hardware deficiencies."
A. INIAKE STRUCTURES
\ The results of the analysis of the two (2) Intake Structures have revealed them to be unsuitable for licensing. As a result of this decision, the two (2) Intake Structures fabricated by Ihe Halvorsen Boiler and Engineering Co=pany have been dispositioned scrap, and two (2) additional Intake Structures are to be fabricated by Chicago Bridge and Iron Company.
B. DISCHARGE STRUCTURE Since the submittal of the Interi= Report, Engineering has re-analyzed the Discharge Structure to deter =ine the requirement for the outer shell as a lead carrying member. These evaluations have .
shown that the outer shell was required only as a form for the concrete and is not required as a load carrying me=ber. Ihis per=its the declassification of all steel parts of the structure except the no::le'. itself and the six (6) foot diameter discharge shaft.
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Engineering's opinion is that the quality of welds attaching brackets (supporting internal braces) to the no::le and that attach the no::le to the buter liner have no affect on the ability of the.
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structure to perform its intended function. No credit is taken for the strength of these velds.
Therefore, the questions concerning the S & M's QA Program do not affect the acceptability of the Discharge Structure.
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CORRECTIVE ACTION TAKEN
- In order that the significant conditions adverse to quality as detailed, herein do not re-occur, the following corrective actions have been taken:
l 1. The two (2) Intake Structures fabricated by The Halvorsen Boiler and Engineering Co=pany have had the numerous defects defined on nonconformance reports with the disposition being
" scrap".
l l 2. TVo program audits have been performed on S & M Constructors, l Inc., resulting in S & M Constructors, Inc. revising their l Quality Assurance Manual.
- 3. ChicagoBridgeandIronCS=panyhasbeenawardedacontracfto fabricate two (2) additional Intake Structures.
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- ~ ~~MRiS D CORRECTIVE ACTION TAKEN (CONT'D.) -'
- 4. Chicago Bridge and Iron Company will fabricate these two (2)
Intake Structures in accordance with the applicable requirements of SP-29-454 9-00, Rev. 3, (i.e. , Engineering Change Notice 2940-29-61) and utilizing the Chicago Bridge and Iron Co=pany Quality Assurance program. ~
- 5. The licensee, jointly with S & M Constructors Inc., vill review the Chicago Bridge and Iron Ce=pany Quality Assurance program, including applicable procedures. Approval of these documents from the licensee will be required prior to the start of fabrication.
- 6. The licensee shall have a representative from the Construction Quality Control Element closely monitoring the initial fabri-cation by Chicago Bridge and Iron Co=pany. This activity will continue until a satisfactory level of confidence has been established.
- 7. Periodic audits and/or surveillances will be performed on Chicago Bridge and Iron Company during various stages of fabrication.
These audits and/or surveillances will be performed by S & M Constructors, -Inc. Quality Assurance Element personnel, together
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with representatives from the licensee's Construction Quality Engineering Element. ~
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,? LLuuiNATiNc st:c* e. Pusuc so. tart e cLtyt No. owio 44tet e TtternoNt (216) c23asse e uAIL Accatss. e.o. eex'tooo
.Dalw9n R. Davidson wet passetNT sistgu ENGmtf a'NG AND CoNstavClioN yebruary 12, 1979
, Mr. Ja=es G. Keppler Director of Region III Office of Inspection and Enforcement U. S. Nuclee.r Regulatcry C-4 ssion .
799 Roosevelt Road Glen Enya, Illinois 60137 RE: Perry Nucler.r Power Plant Dociet Nos. 50-40; 50-41 Interim Report on S & M Constmeters, Inc. 's Quality Assurance Program Breakdown Rege.rding Control of S & M Subcontractor:
D e Ralvorsen Soiler and Ecgineering Co=pany
Dear Mr. Eeppler:
Pursuant to the telephone conversation on Jesua:712,1979, between essrs.
J. M. Le.stovka of CH and K. Ns.idu and J. KonWn of your office, plee.se find attached the Interim Report on S & M Constructors, Inc. 's Quality Assuresce Program Breakdown regarding control of S & M Constructors, Inc.'s subcontractor, De Helversen 3 oiler and Wgineering Cc=pery.
l De attached Interin Report includes a description of the deficiency, an
- ana'/ sis of the se.fety ir.plications and the corrective action taken, e.s l required by 10CE50 55(e).
In addition, the Enal Report is scheduled to be in your office by June 1, 1979 -
,_ Very truly ypurs, ,..
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- f. hW n i D. R. Davidson, Vice President - Syste= Engineering and Construction ks:
j Attachment l cc: JohnG. Davis, Director (Acting) l Office of Inspection and Enforcement l U. S. Nuclear Regulatory C. ission Washington, D.C. 20555 ~
A g'3D I 't F1979
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DiTERIM REPORT ON SIGNIFICANT DEFICIDiCY S & M CGTSTRUCTORS, INC.
QUALITY ASSURANCE PROGRAM 3REAXDCMN RE3ARDDiG CGiTROL OF S & M SUBCGiTRACTOR, TEE HALVORSDT BOILER & D;GDiEERDiG CO.
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l-l PERRY NUCLEAR POWER PIANT, UNITS 1 AND 2 DOCKET NOS. 50-M0; 50-W1 '
l* THE CLWiD ELECTRIC ILWMDULTDiG COGANY Feb:aary 8,1979 l
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INTERIM REPORT O!i SIGNIFICANT DEFICIEiCY DESCRIPTIO*i OF DEFICIDICY
". A. PR03 RAM Dr .tCIEiCIES Introduction Documented evidence is available which is indicative of a breakdown in the S' & M Constructors, Inc. 's (S & M) quality Assurance Program 'in the areas of: Criterion II, Quality Assurance Progran; Criterion IV, Procure-ment Docunent Control; Criterion V, Instructions, Procedures, and Drawings;
. Criterion VII, Control of Purchased Material, Equip =ent, and Services; Criterion IX, Control of Special Processes; and Criterion X, Inspection.
A brief chronology of events concerning S & M Constructors' QA Irogram and Site Organization's related activities is as follows:
Chronology
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August 22, 1977 - Audit' No.10 - This audit of S & M was performed to ,
evaluate their QA' Program in regards to Criterion VII, Centrol of Purchased Material, Equipment, and Services. Nine findings were issued as a result of this audit. .
October 10 and 11'; 1977 - Audit No. 20 - Audit No. 20 was perfomed on S & M Constructors, Inc. and their subcontractor, The Paterson-Leitch Co. covering Criterion VII. Four findings were issued as a result of this audit.
November 15, 1977 - Stop Work Notification (SW) 77-4 and Nonconfomance Peport (NR) CQA 014 - SWN and accc=panying NR vere issued due to l problems with velding and radiography at Paterson-Leit'ch.
December 13, 1977 - Audit No. 35 - This audit consisted of a review of
.. the S & M QA Program as it related to The Halvorsen Boiler & Engineer-ing Co. (HB&E). The following 10CFR50, Appendix 3 Criteria were covered by this audit: I, II, IV, V, iVII, IX, X, XVII, and XVIII.
Eight findings were issued as a result of this audit.
January 11, 1978 - Release for Stop Work Notification 77-4 was issued.
February 10, 1978 - Stop Work Notification CQA 78-4 and Corrective Action Request (CAR) Ok36 - Sw and associated CAR vere written concerning subcontractor control, but were not issued due to adequate documen-l tation of the cited condition in an audit report and an acceptable response to audit f4M4ng.
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, INTERIM REPORT ON SIGNIFICANT DEFICIDiCY
~ DESCRIPTIGi OF ICFICIDiCY - A - -
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February 14, 1978 - Audit No. 53 - This audit was perfomed to evaluate S & M Constructors' QA progra: in the area of Criterion VII as applied to peabody Testing Services. Four deficiencies were noted during this audit.,
February 15, 1978 - Stop work Notification CQA 78-5 and Corrective Action .
Request 0437 - This sWN and associated CAR vere issued due to deficiencies noted in Audit No. 53.
February 20 and 21,1978 - Audit No. 55 - This audit consisted of a review of S & M Constructors' QA Program against the requirenents of all eighteen criteria of loCFR50, Appendix 3. Fifteen findings were issued involving twelve of the eighteen criteria. This audit was perfomed utilizing the Standard Review Plan as a checklist.
March 10, 1978 - Release for Stop Work Notification CQA 78-5 was issued.
April 6,1978 - Audit No. 70 - This audit was perfomed to evaluate the effectiveness and implementation of the S & M QA Program in the area of Criterion VII as it applied to Halvorsen Soiler & Engineering.
Three findings were issued as a result of this audit.
April 17, 1978 - Audit No. 74 - This audit was perfomed as a follow-up to Audit No. 70. One finding and one Nonconfomance Report were issued as a result of this audit. The NR was issued to GAI Engineer-ing.
Septe=ber 27 and 28,1978 - Audit No.162 - This audit was perfomed as a follow-up to Audit No. 55.
Nove=ber 16, 1978 - CQC inspection trip was made to E3&E's shop. Defi-ciencies were noted. (Surveillance Inspection Report C-627).
Nove=ber 17, 1978 - Trend a,alysis of S & M Nonconfo=ance Reports was completed. A negative trend at HE&E was identified.
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- November 28, 1978 - An unannounced visit to EE&E's facility was made #
by representatives of Contract AMn4 stration, Nuclear Engineering Department (NED), Resident Design Engineering, and Construction Quality Engineering (CQE). Result of this visit was consensus agreement by all representatives of the Site Organization that significant problems existed at Halvorsen's shop.
November 29, 1978 - As a result of the previous day's visit to Halvorsen, Nonconfomance Report OQA 035 was issued. This NR identified numerous velding deficiencies on the Intake Structure. Stop Work Notification CQA 78-12 was issued concurrently with NR CQA 035.
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IIGRIM REPORT GT SIGNIFICANT DEFICID?CY ,
3 DESCRIpTIGi 07 DECIDiCY - A - , ..
page 3 Dece=ber 13, 1978 - Piipp Review scard reviewed S & M's response to NR cQA 035. Response was rejected since S & M refuted the existence of majority of deficiencies identified by Site Organization perso=tel.
December 14, 1978 - S & M sub=itted revised respense to NR cQA 035, Rev. 1. S & M stated in this response: "Ite=s 1, 2, 3, 4, 5, 6, 7, and 9 (of NR cQA 035) are not identified as deficiencies by the -
S & M QA Ele =ent . . ." .
December 19, 1978 - A =eeting was held between the Site Organization and S & M, including their subcontractors. The pu n ese of this meeting was twofold: (a) to discuss in detail each deficiency noted in NR caA 035, and (b) to discuss the six conditions i= posed by the Site Organization for release of Stop Work Notification OQA 78-12.
The six conditions are as follows:
- 1. Satisfactory resolutien of NR CQA 035.
! 2. Satisfactory. resolution of NR 29-18.
- 3. Date certain for Eci 1359-29-45 (Eci modifies velding and -
NDEregairementsforSp-29).
- 4. Agree to additional radiographic testing of Intake Structure welds.
5 All velding and HDE procedures used on Intake Structure shall be sub=itted to Site Organization for approval.
- 6. Agree =ent per provisions of Sp-708 for a site Organization Resident QC Inspector at Halvorsen.
I Subsequent to this =eeting, NR cQA 035, Rev.1, was rejected by the Site Organization.
December 20, 1978 - Continuation of =eeting of Dece=ber 19,I 1978 was held at Ealvorsen's shop. Purpose of this co'tinuation n was to demonstrate the presence of deficiencies noted by the Site Organi-i c. zation and refuted by S & M. Mr. S. Hopkins, consultant to S & M,?-
concurred that deficiencies noted by the Site Organization did, in fact, exist and were generic in nature, and not 14-4ted to a few specific welds.
Dece=ber 21, 1978 - S & M sub=itted Revision 2 to NR CQA 035 S&M also sub=itted welding and NDE procedures which vere in use by their subcontractors. This sub=ittal for Site Organization review was one of the previously identified conditions for release of Stop Work Notification 78-12.
I January 4,1979 - CQE co=pleted review of all NDE and Inspection procedures sub=itted by S & M. All procedures were totally inadegaate for work and were dispositioned "Not Acceptable."
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INTE5D4 REPORT CH SIGITIFICANT DEFICIEN'CY . .4
- DESCRIPTIgi C'F DITICIENCY - A ,' s Page 4
' January 5,1979 - a7p Review Board rejected Ia caA 035, Rev. 2; Im 29-18, Rev. 2; NR 29-39; NR 29 40; NR 29-41; and NR 29-42. The last four IG's were issued to docu ent additional deficiencies at Halvorsen.
Deviation Analysis Report (DAR) initiated this date. This 'date is Date Certain for ECN 1359-29-45 (see Ite: 3 under Decedoer 19, 1978). -
Janua:7 12, 1979 - Telephone can between J. M. Lastovka (CEI) and K. Naidu and J. Ko*W (NRC Region III) to discuss potential Significant Deficiency in S & M's QA progra=.
. January IG 29-16,40, Rev.1, without regaired weld procedures.1979 Review pending - S & M su receipt and review of weld procedures.
January 17, 1979 - Selection of audit team and audit date for Program Review audit of S & M Constructors. Received revised NDE procedures.
January 18, 1979 - Site organization received qualificatien docu=entation for Quality Testing IDE personnel (subcontractor performits NDE at Halvorsen shop) fro = S & M.
- January 19, 1979 - Site Organization received Quality Testing's ultrasonic, radiography, and =26netic particle procedures fron S & M.
January 26, 1979 - Site Organizatien co=pleted review of resub=itted Quality Testing NDE procedures which were previously dispositioned as not acceptable. Current dispositions range frc= " Conditional Accept" to " Accept."
Detailed Smary of Progra= Deficiencies Initial concerns over quality of work at Halvorsen . Boiler & Engineering Co. were stin:ulated by hardware deficiencies identified on various Nonconfor-ance Reports and audit reports referenced in Chronology, above 3.
Further investigation by Site Organination personnel led to the conclusied that major deficiencies were present in the. S & M Constructors' Quality Assurance Progra=. In fact, the nt=ber of hardware deficiencies, and the =a6nitude thereof, were directly related to the progra= deficiencies in that the hardware problems were either not identified or were not recognized as deficiencies by the contractor.
Specific progra= deficiencies identified are as follows:
1 10CTR50, Appendix 3, Criterion II, Quality Assurance Program, states in' part, ". . . the Quality Assurance program shall provide control over activities affecting the quality of the identified (as safety-related) structures, syste=s, and co=ponents . . ." and ". . . =ana6e-
=ent of other (than applicant) organizations participati=g in the egh
IICRIM REPORT ON SIGNIFICANT DEFICIE CY c ' "
"3 DESCF.IrHOri 07 DZHCIEliCY - A "
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, Quality Assurance Progra= sha71 regularly review the status and adegaa.cy of that part of the Quality Assurance Program stich they are executing."
- Contrary to the above, S & M Constructors' Quality Assurance Program vas deficient in that: (a) S & M's Quality Assurance personnel failed to identify numerous significant nonec=pliances with specifi- ~
cation and code regairenents in the areas of welding and weld inspection prior to identification by Site Organization personnel, and; (b) S & M QA personnel failed to recognize the.above-referenced nonce =pliances as deficiencies after identification by the Site Organization. The latter deficiency is substantiated by the S & M responses to Nonconformance Report CQA 035, Rev. O and Rev.1, and statements made in the Dece=ber 19, 1978 meeting (reference Minutes ofMeeting).
- 2. 10CFP50, Appendix B, Criterion II, Quality Assurance program, states in part, " . . . the program shall provide for indoctrination and training of personnel perfo=ing activities affecting quality as necessan to assure that suitable proficiency is achieved and maintained . . ." and ". . . Manage =ent . . . shall regularly review the status and adegaacy . . . of the Quality Assurance Prcgram . '. ."
Contrary to the above, S & M Constructors' QA Program is deficient '
in the area of persennel qualification and certification in that:
(a) S & M's QA Program does not address qualification and certification of welding inspectors; and (b) Site Organization has verified that l certain data utilized in the certification of S & M's velding inspector was erroneous.
- 3. 10CFR50, Appendix B, Criterion IV, Procurement Decument Control, states in part, " measures shall be established to assure that applicable regulatory regairements, design bases, and other require-ments stich are necessary to assure adequate quality are suitably
, included or referenced in the documents for procurement of material.., . ."
i~ Contrary to the above, S & M Constructors did not include or reference all applicable regairenents of Specification SP-29-4549-00 on a purchase order for ASTM A-441 steel to be used in the Intake Structure.
- h. 10CFR50, Appendix B, Criterion V, Instructions, Procedures, and Dras-ings, states in part, " activities affecting gaality shall be prescribed by documented instructions, procedures, or drawings . . .
l (stich) shall include appropriate quantitative or qualitative accep-tance criteria for deteMn4ng that important activities have been satisfactorily accomplished."
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Contrary to the above, S & M Constructers' Visual Welding Inspection procedure (Q,CP-107, Rev. 0) was deficient as it lacked sufficient detail and guidance for perfo:=ing regaired inspections, did not contain acceptance criteria for all inspections, and did not provide adegaate documentation of inspection results.
- 5. 10CFP50, Appendix B, Criterion VII, Control of Parchased Material, Eqaip=ent, and Sr:rvices, states in part, " measures she.11 be estab-lished to assure that purchased material, equipent, and services, whether purchased directly or through contractors and subcontractors, confom to the procurement documents . . . Documentan evidence that material and equipent confom to the procurement requirements shall be available . . . and shall be sufficient to identify the specific requirements . . . met by the purchased material and equipment."
Contrary to the above, S & M Constructors' QA Progra= vas deficient in the area of subcontractor control. This deficiency is substantiated by the Site Organization review of in-place procedures belonging to S & M's subcontractors. Each of these procedures reviewed was found to be inadequate and was dispositioned "Not Acceptable." Tnis review and disposition was considered to be evidence of inadequate reviev by S & M.
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- 6. 10C 750, Appendix B, Criterion IX, states, " measures shall be established to assure that special processes, including velding, heat treating, and nondestructive testing are centro 11ed and acco=plished by gaalified personnel using gaalified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Contrary to the above, S & M Constructors' control of special processes is deficient, as demonstrated by the following:
(a) Joint configurations represented by velding procedures submitted by S & M are not shown on Halvorsen Boiler & Pngheering's (HB&E) shop drawings. 7; (b) Joint configurations shown on the' EB&E shop drawings are not represented by velding procedures.
- 7. 10CFP50, Appendix B, Criterion X, Inspection, states in part, "a program for inspection of activities affecting quality shall be established and executed by or for the organization perfoming the activity to verify confomance with the documented instructions, procedures, and drawings for acco=plishing the activity . . . ,
Examinations, measurements, or test of material or products processed whall be perfomed for each work operation vbere necessary to assure quality." .
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3 INTERIM REPORT CT SIGNIFICANT DEFICIDiCY DESCF.IPIIGi OF DEFIClaict - A Page 7 .
Contrary to the above, S & M Constructors' visual velding inspection was inadequate as demonstrated by the m:mber of obvious deficiencies
, identified by Site Organization personnel subsequent to S & M's inspection.
B. HARDWARE DEFICIDiCIES -
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Introduction Hardware deficiencies existent in verk perfomed by Halvorsen Boiler &
W.41neering were primarily identified in Nonconfomance Report CQA 035.
S-a7 of specific deficiencies identified are as follows:
1 I= proper veld joint fit-up. Rootopeningsvaryfrom0"to3/4" (top to bottom - 48" approximate). Documentation reviewed indicated this problem had been documented and identified by the contractor on two veld joints (for' excessive gap once). Subsequent visual .
examination by Site Organi=ation personnel revealed this condition existed on other Gelds dich were tacked and aligned (both excessive and inadequate gap).-
. 2. No pre-veld cleaning had been perfomed. Sla6 and oxidation from flame cutting were present.
This condition also existed on a joint dich was in-process of being-velded on Novenber 28, 1978. Sla6 and exidation evident was not li=ited to that left frce fla=e cutting. Exa=ination of in-process velding revealed indications of improper preeleaning and inadequate
, cleanin6 between veld passes. This condition appears to be a generic problem with all velds.
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- 3. Finished weld profiles do not meet the requirements of AWS Dl.1 Exa=ination of co=pleted weld profiles revealed that. profiles range
, from below surface of the base material to reinforcement, which 7,.
exceeds the requirement of AWS D1.1 Previous inspections by Site Organization revealed weld prefiles of filler passes, Wich would indicate improper velding te+ 4 ques such as high veld metal build-up or rope-type bead. This condition is inherent with all velds. ,
- 4. Visual exmination of various f471et and full penetration velds <
revealed: (a) excessive porosity; (b) undercut; (c) sla6 pockets; (d) inca =plete fusion; and (e) poor tie-ins to tacks. Subsequent.
inspection revealed cracks observed visuany on surface of welds. <
Conditions noted above were observed on completed and in-process
. welds. *
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- 9 5 Tack welds used for fit-up are not being tapered at their starting and stopping edges prior to incorporating the= into the root pass.
This problem was originmy identified on Nonconfo=Ence Report CQA 023 as a result of CQE Audit No. 74, dated April 25, 1978. As documented in the body of the report, this condition vould not exist if the tack welds had been removed as explained to the auditors .
by the subcontractor. To date, satisfactory resolution to Noncon-fo=ance Report CQA 023 he.s not been obtained. However, a meeting on January 30, 1979, between CQE and GAI Engineering resulted in agree =ent for satisfactory resolution.
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- 6. Where joints have been fit-up and tack velded, and the carbon steel banking strip is velded in place, there is no penetration of the tack weld into the backing strip. On the vertical velds connecting the outer liner of Intake Structure No. 2, the banking strips were placed after the tack welds were made in the veld groove. Further investigation involved cases Were the backing strip was tacked in place fro = the veld groove side. This practice is contrary to~nomal velding technicues. (NOTE: Back side of veld joint was accessible ,
for proper tanking of the banHng strip.) This condition could be identified only for those velds for which root pass had not been made. -
- 7. weld bead vidth (weave) is as much as two inches or more. At the re r est of consultants for S & M Constructors, Inc., this matter was referred to AWS for interpretation. This condition is prevalent in all velding. s
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- 8. The approved veld joint design for the top plate velds is not being used. (Reference Halvorsen Shop Drawing G850-1, Rev.19.) subsegaent .
investigation has also revealed that joint configurations shown on drawings do not correspond with veld procedures submitted.
9 visual exa=ination reveals an appearance of copper deposits in the , ~~
veld metal connecting the outer liner plates to the stiffener. , One s veld had been ca=pleted and one prepared for velding using copper ,
n ban >%g bars without Pngineering approval. 5
- 10. The specification (SP-29-4549-00, Rev. H) required material to_b'e ,
in accordance with ASTM AM1-74. The purchase order did not specify the applicable edition of AS2M. The material supplied to a later
- edition of AS2M (AS2M AM1-75) did not contain te :andatory require- -
ment of transverse bends. This should have bet. uMed by purchase order as a supplemental reqairement. A3% d M *f1 4 material for structures associated with Sp-29-4549-Oe p n e..S9ted. '
- 11. Prior to the above hardware deficiencies, other deficiencies, siich as lamellar tear betveen adjacent velds, had been identified by the contractor.
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II"ll2 RIM PIPORT CT SIGNI/ICANT DEFICIDiCY ,
,.. AHAl% SIS OF SAI'ETY ~ EJCA'Ef.ms
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- ANAIXSIS OF SAFE 2Y Db1ICATICUS t
A. PauiRt.M DEFICIDiCIES
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' , y The scfety:i=plications of a Quality Assurance _ breakdown are difficult 3 '
to evaluate as an entity. In the specific case addressed in this report, the Quality Assurance Program deficiencies are directly related to
- hardware deficiencies identified and discussed in other sections of this report. Because of this correlation, and other evaluations discussed ~
under the " Corrective' Action Taken" section, the safety i=plications i
of the effects of the Quality Assurance Program breakdown vill be identical to the safety i=plications of the hardware deficiencies. The hardware deficiency analysis is given in the following section of this report.
B. EARITJAPI DEFICIETCIES Safety 1:rp31 cations of hardware deficiencies are currently being evaluated by Engineering. Results of this evaluation are not available at this time; however, cc=plete; results of the sma.1ysis of safety implications;of the hardware deficiencies vill be included in the Final Report to be -
sub=itted by June 1,1979 l
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CORRECI'IVE ACTIGi TAKDi A. FRO 3 RAM DEFICIETCIES Corrective actions taken or to be taken on identified program deficiencies are presented in the same order and format as in the " Detailed Su=utry of Program Deficiencies."
Details of corrective action are as follows:
,- 1. S & M Constructors' failure to recognize the identified hardware $
deficiencies as such has been corrected as demonstrated by S & M's revised response to Nonconfo:=ance Report 0;tA 035, Rev. 2, as well as by additional Nonconforance Reports written by S & M to further document veld deficiencies. This change in the attitude of S & M is further de=enstrated by statements made by Mr. S. Hopkins of Industrial Inspection Industries, Inc., a consultant to S & M at a meeting held at Halvorsen Boiler & Engineering's facilities on Dece=bermo,1978, wherein Mr. Hopkins agreed that the deficiencies identified by Site Organization did, in fact, exist and were generic in nature and not li=ited to a specific weld.
Corrective action taken by Site, Organization in this area consists of arrangements for a full time Site Organisation Level Il Welding Inspector to be present in Halvorsen's shop when Stop Work Notification CQA 78-12 is re3 eased.
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- 2. No corrective action has been taken by S & M Constructors to date.
, Site Organization corrective action taken in this area consists of written direction to S & M that a re-evaluation of the qualifications /
certifications of their (S & M's) welding. inspector is to be sub=itted to the Site Organization for review and evaluation prior to any further utilization of that inspector on safety-related work for the perry Nuclear Power Plant.
- 3. This deficiency has also been identified on Nonconfo=ance Reports CQA 035 and 29-42. Corrective actions have been specified on both nonconfomance reports. In addition, subsequent purchase orders have been reviewed and vritten co=:nents provided to,S & M to preclude farther recurrences of this problem.
- h. S & M Constructors' Visual Weld Inspection procedure (QCP-107) has been revised to adequately address the concerns cited. Additionally, Site Organization Review Board co=:nents on Nonconfomance Report CQA 035, Rev. 2, require S & M to perfom and document additional inspections to co=pensate for the cited inadequate documentation.
- 5. In order to preclude recurrence of problems in this area, Site ,
Organization has relieved S & M of the responsibility for review of special process procedures and Site Organization has assumed this responsibility.
- 6. Two-fold corrective action is necessary for this ite=. This first t
action required is a ce=plete re-review of the shop drawings by Gilbert Engineering, and resolution and incorporation of the Engineering co=ments by S & M/Halvorsen. The Engineering review has been completed and the com:nents trans=itted to S & M.
The second action reqaired is a re-review of the veld procedures b3 the Site Organization. This re-review will be performed subsequent to S & M revision and resubrdttal of the shop drawings and acceptance of the revised drawings by Engineer 2.ng.
].' 7. S & M Constructors' visual Welding Inspection procedure, QcP-107, '-
bas been revised to provide greater detail and direction for perfomance of visual inspection.
In addition, a full-time Site Organization Level II Weld Inspector will be placed in Halvorsen's shop at the time of release of Stop Work Notification CQA 78-12.
E. HARDRARE DEFICIENCIES -'
Corrective actions taken or to be taken on identified hardware deficiencies are presented in the same order and femat as in the " Description of 3
- Hardware Deficiencies." No physical corrective. action has been taken to date due to Stop Work Notification CQA 78-12 being in effect.
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INERIM REPORT M SIGNIFICANT DETICIENCY
- " % CORRECTIVE ACTION -TAKEN - B . , ' " "
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Site Organization Review Board co=nents on Noncenfor=ance Report caA 035, Rev. 2, placed the additional regairement that all velds, regardless of status (i.e., fit-up, in-process, or complete), either be docu=ented as acceptable or reported on nonconfor=ance reports. A farther retaire-ment was the verification of the acceptance status of all velds by the Site Organization.
Details of corrective action are as follows:
1 All nonconfor=ing veld fit -ups will be documented on nonconfor=ance reports and dispositions and corrective actions vill be based on specific details of each deficient veld joint.
- 2. S & M Visual Weld Inspection procedure (QCp-107) has been revised to provide adegaate procedural address to prevent recurrence of this problem. Welds will be cleaned prior to any further processing.
- 3. S & M procedure qCp-107 bas been revised to address veld profiles' acceptability. All nonconfor=ing veld profiles vill be identified and dispositioned on nonconfo:=ance reports. .
4 All velds containing defects of the type noted in this deficiency vill be identified and dispositioned on nonconfo:=ance reports.
- 5. S & M procedure qcp-107 bas been revised to require the removal of tach velds with magnetic particle testing after re= oval to ensure-that sound metal has been reached.
- 6. Same as for item 5, above.
- 7. A code interpretation has been obtained from the American Welding Society Structural Welding Co-4 ttee confirming the enndition cited as an item of nonce =pliance with Structural Welding Col.e (AWS D1.1).
Exact corrective action is. contingent upon resalts of Engineering's
,, evaluation of the condition. c.
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8.
Corrective action for this item is the same as that indicated for item 6 in Program Deficiency Corrective Action section of this report.
9 The use of copper backing bar is now specifically prohibited. Welds cade utilizing copper backing bar vill be ground from the root side to a sufficient depth to ensure co=plete removal of copper conta=ination.
- 10. The corrective action for this ite= is the same as that indicated for item 3 in the Program Deficiency Corrective Action section.
11 Specific corrective actions for other hardware deficiencies noted ,.
vere given on the specific nonconfo:=ance reports in question.
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