ML20064D292
| ML20064D292 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 11/23/1982 |
| From: | Ferguson R WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Sternberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20064D232 | List: |
| References | |
| GO1-82-0781, GO1-82-781, NUDOCS 8301040614 | |
| Download: ML20064D292 (35) | |
Text
ENCLOSURE 3 Washington Public Power Supply 5,ystem P.O. Box 968 3000GeorgeWashingtonWay Richland,WashingtoA)%
{509)372-5000
- 5 ll: y November 23, 1982 ilP/g.
G01 0781 Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 120 Walnut Creek, California 94596 Attention:
D. M. Sternberg, SALP Board Chairman and Chief Reactor Projects Branch No. 1
Subject:
NUCLEAR PROJECT NOS. 1 & 4 DOCKET NO. 50-460 & 50-513 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
Reference:
Letter, D. M. Sternberg to R. W. Root, same subject, dated October 27, 1982 l
The WNP-1/4 Project staff has reviewed the draft report prepared by the i
NRC Region V SALP Review Board.
We find the presented facts substan-tially correct, however, the method of presentation and the omission of other facts results in a report that lacks balance and perspective. The narrative conclusions reached in the report do not reflect the overall status of the project and are not supported by the facts.
Also, the report does not address twenty-five percent of the reporting period during which the Project was in a major transition from full construction l
to deferral of construction.
We believe the report should have acknowledged the significant actions initiated, and improvements obtained, during the past reporting period by the Supply System, Bechtel and United Engineers & Constructors (UE&C).
We agree with your assessment that there is every reason to believe that these actions would have improved our program and been successful, as actions taken to date have already strengthened the overall Project Management and Quality Programs, thus resolving some of the issues identified in your report.
A major achievement for the Project was receipt by the Supply System of the ASME "N" Certificate for overall Section III, Division 1, Code responsibility.
By achieving this, the Supply System became the sixth utility in the country to reach this milestone.
The efforts associated with this task resulted in a stronger QA program, better understanding of program requirements and a better working relationship among the involved organizations on the Project.
Evidence of the improved performance during the last SALP reporting period includes the increase of NRC inspection hours per noncompliance by almost a factor of three.
8301040614 821229 PDR ADOCK 05000460 G
Mr. D. H. Sternberg Page Two November 23, 1982 Another concern we have with the SALP Report is the repetitive use of the word " weakness".
This term could lead someone (who is unaware of the actions which have been taken on the Project) to the erroneous conclusion that little, if anything, has been done over the past year to improve our system of project management controls.
Areas for improvement and strengthening can always be found without leading to a conclusion that serious problems exist.
We wish to assure you that our commitment to, and objective of, a quality product is our management philosophy and we will build upon the present quality system for the WNP-1 engineering and construction program, as we have demonstrated at the WNP-2 and WNP-3 Supply System Projects.
Further improvements will be investigated and initiated during the construction delay, including procedure simplifi-cation and consolidation, and increased assurance of design control.
I
'j Most of the draft SALP Report was directed towards the Heating Ventilation and Air Conditioning (HVAC) contractor, where considerable Supply System management attention was placed.
Our management actions included not only those necessary to resolve the specific issues which were identified, but also those necessary to strengthen the contractor's management and quality organizations. Attachments I and II describe the various actions which have been taken. However, the decision to suspend construction at WNP-1 occurred prior to the finalization of the actions to be taken to strengthen this contractor's organization.
Responses to those areas in your report which the Supply System believes need to be addressed, and specific comments and responses associated with Sections IV and VI of the draft SALP Report, are contained in Attachments I and II, respectively.
t I am requesting that our initiatives, and their results, be considered in your assessment of our performance.
I also request that factual information in the proper perspective be added to the subjective perceptions, and that misleading and negative statements not supported by facts and trend data be removed from the report as further defined in Attachment II.
y'e =~
s R. L. Fedtdon Managing Director (387)
RLF:kr Attachments cc:
A. Toth, NRC (819)
J. D. Batemen, UE&C (895) i J. P. Laspa, BPC (861)
V. Mani, UE&C (897)
?'GW3 r pc "9 p"eu 20 ATTACHMENT I
- W ll.
SUPPLY SYSTEM ASSESSMENT OF NRC PERCEIVED WNP..1 WEAKNESSES MWJ:,. ;
The Supply System has reviewed the draft SALP report and has identified four functional areas which we believe the NRC considered to be areas of weakness requi ring additional attention.
These functional areas are:
procedure implementation and compliance with policies; timeliness and accuracy of responses to the NRC; effectiveness of corrective action; and management awareness and involvement in resolving quality issues and providing contractor support.
Our response to these areas includes a brief statement which we believe addresses the NRC's concern.
In our response to each of these areas, we have included a statement of the improvements vhich were either in place, or were planned to be in place, prior to the announcement of the extended construction delay at WNP-1.
There are certain portions of the draft SALP report which the Supply System does not believe accurately reflect the f acts and circumstances.
Therefore, clarification information is provided in our Attachment II for certain examples noted in Sections IV and VI of your report.
General Comments The enforcement items identified during the SALP reporting period have been thoroughly discussed at exit meetings and in responses which have been submitted to the NRC, therefore, additional specific details are excluded from this response.
While some of the items may be controversial in nature, as evidenced by the NRC requiring additional information and not accepting initial responses, we have concluded that the report's references to the items of noncompliance are technically correct.
Although these specific items of noncompliance existed, it should not be concluded (as the report implies) that they represent wide-spread systematic hardware and program discrepancies. For example, the failure of one contractor to be aware of the existence of a nonconformance report prior to further processing of a work activity appears to be an isolated occurrence. However this same item of noncompliance is referred to four times in the report in three different categories to substantiate l
" weaknesses" in those areas.
It should also be noted that the application of j
one noncompliance to other categories is not isolated to just this situation.
The Supply System believes that the use of words such as " major problems" and "particularly disturbing" overstate the conditions that existed and are inconsistent with the tone of other NRC reports, including the special team inspection (Report 81-10) and the severity level of infractions on WNP-1.
During this period, there were a total of 15 noncompliances, all of which were l
only Severity Level 5, whereas during the previous period there were 14 (of which 3 were Severity Level 4 and the remainder Severity Levels Sand 6). The
" weaknesses", perceived or documented, in many cases are subjective and are not be supported by specifics which are needed in order to take appropriate corrective action.
An example is,
" control of quality procedures and policies", which is used many places in the report (e.g.,
top and bottom paragraphs on page 8).
The implication is that procedures are uncontrolled whereas the specifics would indicate that the concern is actually the frequency of deviations from approved procedures.
l l
]
The responses below are organized by the functional areas identified above.
It should be noted that, although responses are being provided by functional area, activities in one area may have a direct effect and influence on other areas.
Therefore, the close inter-tie of these areas must be considered when reviewing our response.
Responses to Functional Areas of Weakness e
Procedure Implementation and Compliance with Policies The NRC's concern in this area seems to be that strict adherence to and implementation of procedures, and compliance of these procedures to codes, standards, specifications and policy or upper-tier documents requires improvement.
Response
During our evaluation of this area we have concluded that the majority of procedural violations have been caused by excessive procedural require-ments (e.g.,
- code, standard and specification), excessive number of procedures and procedures which do not clearly state the requirements and acceptance criteria.
An effort had been initiated in the early part of this SALP reporting period to streamline procedures, eliminate overcommitments and to reduce i
the number of contractor procedures.
The initial effort was with the piping and mechanical contractor (J. A. Jones), with subsequent efforts initiated with the structural steel installer (Shurtleff and Andrews) and the HVAC contractor (UNSI).
This procedural streamlining effort was consistent with the findings of the study conducted by Bechtel prior to January, 1981, and one of the lessons learned from WNP-2.
Although the effort with J.A. Jones procedures had for the most part been completed, the efforts with Shurtleff and Andrews and UNSI had just begun to result in revised and consolidated procedures when all construction activities in this area were suspended.
One of the efficiency improvements during the extended construction delay period will be the standardization of procedures among constructors, consolidation of work to minimize the number of contractors, and identify-ing methods to assure strict adherence to procedural requirements. These actions are considered to be those necessary to assure effective improvement in the area of procedure implementation and compliance.
Due to the uncertainty of the restart for WNP-1, it is indeterminate at this time when these efforts will be completed.
e Timeliness and Quality of Responses to the NRC The NRC's concern in this area seemed to be that some formal replies to NRC findings were untimely and, in some cases, inaccurate in the characterization of facts or status of corrective actions.
Actions described to the NRC at one point in time would be modified without revision of the commitments.
There were cases where a contractor had not 2
implemented the actions stated by the Supply System.
Similarly, for inspector questions that were formally presented to the Supply System as inspection findings, the subsequent Supply System actions were incomplete or otherwise not sufficient for the inspector to affirm acceptability of the matters in question.
Response
The Supply System does not believe that the draft SALP report accurately reflects the effort which has been expended and the results achieved in this area. Regarding the timeliness of responses, the Supply System QA Engineer responsible for preparing the majority of the responses during this reporting period had discussed this subject with the Region V Project Inspector.
Due to past criticism of this area, the QA Engineer wanted to establish the most effective and meaningful method for informing Region V when a response would be late, even if it meant writing a letter.
The QA Engineer was concerned with providing an accurate and meaningful response, not just a response which would be questioned later.
The Project Inspector indicated that verbal (telephone) notification was most acceptable and most efficient for all involved.
This practice was followed by the Project for responses which were going to be issued late.
The regional office has apparently changed this policy, therefore, we will follow the procedure outlined during our November 3,
1982, meeting.
Future notification of late responses will be made to you by letter.
Additionally, the WNP-l Acting Program Director advised the Chief, Reactor Projects Branch No.1, that some responses would be put on hold to allow the Supply System and the NRC to discuss the method and need of responding while in a construction delay.
The WNP-1 Acting Program Director and the Chief, Reactor Projects Branch No.1, met on November 3,1982, to discuss this matter, and they agreed to the method of categorizing responses and that statusing of certain responses may not be necessary until construc-tion restart.
The Supply System will submit a formal proposal to the NRC on this matter.
Regarding the accuracy of responses, it was recognized by the Project during the early portion of this reporting period that an up-to-date status of responses to NRC findings did not exist.
The cause of this problem was due to personnel turnover during the Supply System /UE&C de-integration which occurred at the time of Project re-organization.
A self-initiated (Project) effort was implemented to status and validate prior responses to NRC findings.
This effort resulted in closure of a number of previously outstanding items.
I To further expand on the past efforts that were identified above, a detailed listing of open NRC items (findings, open and unresolved items, etc.) has been compiled by Supply System Project QA and sent to Bechtel, l
UE&C and Supply System organizations with a requirement that a current status for each identified item be provided.
This status would include backup documentation, as appropriate, and revised expected completion i
dates when appropriate.
I i
3 1
Due to the recent announcement to initicts a five-year construction delay (previously a two-year restart was planned), this listing will have to be re-evaluated and updated.
However, it is currently planned that this detailed listing and status of completion will be part of the information used to assist in the restart of construction.
As was discussed during our November 3,
1982, meeting, extenuating circumstances contributed to the unsatisfactory response to reports 82-04, 82-07 and 82-08.
A contributing factor was the emphasis which. was placed on the orderly rampdown of construction activities for the extended construction delay. These reports were prepared during a period when significant changes in personnel assignments were being made to preserve resources.
Management attention was focused on accomplishing the extremely difficult task of construction rampdown in a disciplined manner.
As we have noted during our November 3, 1982, meeting, it appears that Table 4 of your report is in error in that you indicate report 82-05-01 required a response by May 27, 1982.
Our review of this report and Appendix A of page 2,
indicates that you stated, " subsequent prompt corrective action to resolve the noted matter and effect training of personnel appeared to have been adequate.
Therefore, no Supply System written response was required".
A correction should also be made on page 16,Section VI.2.a. of your report.
1 Additional clarifications are provided in Attachment II as it relates to i
specific examples noted in Section VI of the draft SALP report.
e Effectiveness of Corrective Action We believe that the NRC was concerned that corrective actions established were often not effective in resolving issues.
e
Response
Improvements made during this period were effective, as demonstrated by the severety level of the infractions and the nearly three-fold increase in the number of NRC inspection manhours required to identify an item of noncompliance.
The previous assessment period covered approximately a twelve-month period, five months of which saw limited construction due to a strike.
That report identified 14 items of noncompliance, three of which were Severity Level IV, whereas during this assessment period when the plant was under full construction for ten months for one unit and seven raonths for the other unit, fif teen items of noncompliance were identified, none of which were of a severity level greater than V.
This, combined with the increased NRC manhours per item of noncompliance, reflects a positive trend in the effectiveness of corrective actions.
The NRC team inspection report (81-10) of November 20, 1981, credited the project with " greater effectiveness in resolving identified problems."
Additional management attention continued in order to further improve the quality of the construction work, including the accuracy of the inspec-tions.
4
i t
Accordingly, and to illustrate the effectiveness of corrective action regarding a specific contract, the following is a summary of actions taken (including the results achieved and improvements expected) on the HVAC contract.
j 1.
Actions taken:
j a.
Project Manager was replaced with a more quality-conscious individual.
b.
Additional personnel changes were made, including addition of a Field QA Manager, 15 Field Engineers, three QA l
Engineers, and one lead auditor.
Also, the Corporate QA Manager was onsite full time for six weeks, and the contractor was in the process of adding an experienced training manager.
i c.
The contractor, with CM assistance, was in the process of I
reviewing and rewriting procedures. One major procedure had been revised and implemented prior to the extended con-struction delay.
Three other procedures were in the revision process.
Weiding Procedure Specifications were also reviewed by a team of welding engineers (from contractor, owner, CM and A/E organizations) and subsequent revisions have been made.
2.
Results Achieved and Improvements Anticipated i
I a.
No new allegations have been reported either via the j
" hotline" or from the NRC since the above actions were j
initiated.
b.
Procedure revisions, completed and underway, would have resulted in improved procedures (e.g.,
procedures less subject to interpretation, containing more explicit accept /-
reject criteria, and elimination of unncessary inspections).
c.
Also, the above strengthening of the contractor's management team and QA staff, combined with improved training, would have resulted in even closer adherence to procedures.
d.
The overall result would have been a continuation of the trend of fewer procedure violations, as well as an improvement in quality verification inspections and documen-tation.
The extended construction delay beginning on April 29, 1982, changed the project from a plant under full construction to one of document review.
A sampling of documentation prepared recently reflects that major improvements have been made in the area of documentation completeness.
Bechtel and the Supply System have performed management surveys of contractor documentation review efforts underway, and these reviews did not identify any significant concerns.
The survey indicated that the records would support plant licensing.
l 5
)
s Management Awareness and Involvement in Resolving Quality Issues and Providing Contractor Support The SALP review board states in their draft report, "There appeared to be a weakness in the Supply System surveillance of contractor activities, such that significant management / quality system events were not brought to the Supply System management's attention in a timely manner".
Response
As was noted in the response to NRC Report 81-07 and summarized in the cover letter to this report, management awareness to quality issues has received continued attention during this reporting period. The identified weakness is subjective and a management technique issue, with no bearing on the quality program at WNP-1.
The Supply System has chosen to assume an Owner's oversight role with subsequent primary surveillance activities l
delegated to the Construction Manager.
Supply System personnel perform limited and random surveillances.
The issue of timeliness reflects a personal preference and not a substantive quality-related finding.
Considerable management attention was placed on specific contracts, not only to resolve specific issues, but to strengthen contractor management organizations.
A summary of some of the management actions taken during this reporting period are listed below:
1 e
During 1981 - Major construction contracts were modified to provide for increased licensee management control of work activities, including l
incentives to complete QA/QC documentation and inspections.
e September 1981 - The HVAC Project Manager was removed as Project Manager for not adhering to the Program Director's directive to follow procedures.
e October 1981 - The Hotline Program was instituted on site in order to allow all personnel at WNP-1/4 to report, via a direct phone line to the Program Director's office, any concerns that have not been adequately responded to by their parent organizations.
The Hotline Program also provides the Supply System the opportunity to prevent personnel unrest and i
allow the Project to correct its own problems.
The Hotline was used on many occasions.
Contractor QA Managers held meetings with inspectors to reinforce management desires that problems be identified to supervisors or managers, and if the inspectors were still not satisfied with the results, to contact Bechtel/ Supply System QA/QC personnel (identified by hardhat i
decals).
e The CM held management meetings with contractors weekly.
In addition, contractor QA managers met weekly with the CM's Project Construction QC Engineer to discuss quality concerns.
e The CM's Construction Quality Control Manual was modified in January, 1982, to improve contractor surveillance effectiveness and resolution of discrepancies.
i e
Management changes were made in contractor quality organizations (F/W&B and J.A.J.)
6 i
i A
4 J.A. Jones, F/W&B and UNSI increased their corporate management involve-e ment significantly during the latter half of this year's SALP reporting period.
o In January, the CM issued a detailed letter identifying the Lessons Learned Program from WNP-2 to each Quality Class I contractor and requested the contractor to evaluate how lessons learned information affected their operations.
e Team building sessions were conducted jointly by the Supply System, Bechtel and UE&C to improve the free flow of information.
e A major achievement for the Project was the Supply System receipt of an ASME "N" Certificate. The efforts associated with this task resulted in a stronger QA program, better understanding of program requirements and a better working relationship among the involved organizations on the Project.
e An effective Construction Delay Rampdown Program has been implemented.
Efficiency studies are underway to improve jobsite operations (e.g.,
consolidation of work into fewer major contracts and additional procedure review).
e Supply System, UE&C and Bechtel Management performed surveys of the Documentation Review effort.
l An ongoing effort in the area of management involvement and awareness to quality problems is the continual interchange of information among the Supply System projects and the industry (e.g., INPO, Atomic Clearing House), including trading information with other utilities.
This information is disseminated among the Projects.
l Due to the importance of management awareness of quality issues, the Project is continually working to improve this area. However, as was discussed during our November 3, 1982, meeting, Supply System management will not necessarily become involved in every issue which occurs at the contractor level.
The degree of involvement will be based on the information available at the time, a judgment as to the significance of the issue, the actions being taken by the CM and the contractor to resolve the condition, and any additional information received via staff or the " Hotline".
i For example, in the case of the electrical contractor QA manager's concern, it is known that he was aware of the " Hotline" by which he could have expressed his concern.
He had numerous discussions with Supply System QA and Bechtel QA/QC management personnel on various topics which would have allowed him the opportunity to express his concerns to familiar individuals who were interested in resolving issues and concerns.
The degree of management awareness and involvement was based on the information available at the time and not information available at a later date.
i 7
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s ATTACHMENT II
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SPECIFIC COMMENTS TO DRAFT SALP REPORT - SECTIONS IV AND VI
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specific comments and responses 'aisociated The following provides our with Sections IV and VI of the draft SALP report.
SECTION IV - Performance Analysis Item 1 - Soils and Foundations
- a. Technical Accuracy No Comment
- b. Need for Clarification No Comment
- c. Action Taken/ Planned No Comment Item 2 - Containment and Other Safety-Related Structures Paragraph 1 -
- a. Technical Accuracy No Comment
- b. Need for Clarification No Comment
- c. Action Taken/ Planned No Comment l
Paragraph 2 -
- a. Technical Accuracy See Below
- b. 3 ed for Clarification i
The three nonconformance reports which were closed without sufficient basis (welds not identified on as-built drawings) occurred during the 1980-1981 SALP reporting period. Also, the " unacceptable methods of bolt tightening" was identified during the previous SitLP period. The SALP report would lead one to believe that the Supply System l
l i l
t
commitments made to the NRC. One commitment date to revise a procedure was submitted eleven days late (bolt tightening). The corrective action for enforcement item " proceeding with work prior to proper authorization" incorrectly stated that a work package system had been implemented. As the amended response (G01-82-0716, dated October 12, 1982) stated, the work package system had not been implemented in lieu of previously-approved procedures but was in addition to approved procedures. With the amended response, the SALP sentence In the case...... written procedures" should be deleted and previous SALP sentence should reflect item instead of items,
- c. Action Taken/ Planned All of the corrective actions identified in the responses to enforce-ment items have not been completed due to the suspension of construction activities. The following actions were taken during the current assessment period to improve the quality of the structural steel erection work:
o Contractor changed QA Managers.
e All contractor procedures were reviewed by the CM. The contractor was in the process of revising procedures at the i.ime of rampdown.
Thirty-six (36) procedures reviewed, eight (8) revised, and twenty-eight (28) not revised due to rampdown. An additional fifteen (15) procedural revisions were made during this SALP period prior to all procedures being reviewed by the CM.
e A training class was conducted by the CM on inspection of skewed fillet welds and skewed fillet weld guages were provided to the contractor.
l e The CM added an additional QC Engineer to monitor the contractor's in-process construction activities.
l Prior to additional structural steel work, it is planned that this i
work will be included in the scope of an existing contract. This contracter will be required to write procedures to address structural j
steel work. Additional reinspections will also be required to resolve enforcement items.
Paragraph 3 -
a.
Technical Accuracy l
Factual
- b. Need for Clarification No Comment
}
l ;
__,__m
- c. Action Taken/ Planned The specific actions taken on this item are contained in the formal e
response to the NRC from UE&C dated October 29, 1982.
o Lehigh Testing completed tests to determine the behavior of the
}
framing angle connections to loads.
e The AE finalized structural analysis and design considering the thermal and seismic effect and the interface with the supported j
systems.
Physical modifications to be made to a limited number of framing e
connections, removal of certain bracing members and providing
" sliding" joints for certain main framing members.
All required framing modifications have been identified.
o l
Modifications will be performed after construction resumes.
e e Verification of seismic design for safety-related systems, uti-lizing rev.ised Amplified Response-Spectra (ARS) generated for the modified structural framing, will be performed in accordance with AE's ongoing program.
Paragraph 4 -
- a. Technical Accuracy No Comment
- b. Need for Clarification This paragraph leads one to believe that significant structural steel problems exist, however, the three enforcement items are classified as severity Level V.
While the Project's goals are to minimize discrepancies, the three enforcement items which identify two under-size welds, three NCR's closed prematurely, and two instances where work proceeded prior to authorization do not indicate wide-spread problems. This is especially true given the high level of construction activity underway when the deficiencies were identified.
- c. Action Taken/ Planned Management has been actively involved in the structural steel contract t
as identified previously in paragraph 2. A review of previous NRC l
enforcement actions failed to reveal previous similar deficiencies that would support the statement, " weakness in enforcement history repetition".
I l - - - - -
3
-3 33
A major effort is nearing completion by the contractor in the review of all documentation.
The correlation of inspection reports to as-built drawings reflects that a few inspection records are missing for some welded and bolted joints. These items are being added to a punch list and the inspections will be performed and documented in the future.
The contractor is not only referencing design change documents, but is also adding detailed 8) x 11" sketches to the design drawings to accurately reflect as-built conditions.
The design vertification effort will then be completed by the Engineer.
Item 3 - Piping Systems & Supports Paragraph 1 -
- a. Technical Accuracy No Comment
- b. Need for Clarification d
No Comment
- c. Actions Taken/ Planned Regarding procedure review At the time of the addition of a new Construction Management Organ-ization, the responsibility for the quality review of contractor procedures was transferred from the Construction Management QA Sur-veillance group to the Architect / Engineer Quality Engineering group.
Due to the nature of Quality Engineering activities, personnel in this group are more familiar with the requirements of the contract, including codes and standards.
In addition, a QA Engineer with welding background and experience was added to the QA Engineering group to improve the quality of contractor procedure review.
Action Taken/ Planned Regarding effectiveness and timeliness of l
corrective actions A system has been developed for tracking NRC items to assure that corrective actions are taken in a timely manner. Due to the extended construction delay all NRC open items will be statused and data assembled for presentation to the NRC to close the open items, where possible.
Paragraph 2 -
- a. Technical Accuracy No Comment
_4_
b, Need for Clarification The bypassing of hold points has not been eliminated. The bypassing of-hold points is normally attributed to craft failure to notify I
inspection personnel during construction processing, however, the improper release to start post-weld heat treatment was not a craft violation but represents an error by nonmanual personnel who failed to place a copy of the NCR in the work package or to tag the item. In order to evaluate the effectiveness of corrective action, trending must be based on the date the violation occurred and not the date the l
violation was identified. The date the violation occurred has proved to be difficult to ascertain. In addition, this creates a difficulty for both the NRC and the Project QA organization in determining the f
effectiveness of corrective action. However, it is acknowledged that i
more must be done to assure that the issue of bypassed hold points is resolved. This includes increased management initiatives to enforce compliance by the crafts and their direct supervision.
- c. Actions Taken/ Planned It is correct that actions have been taken to correct the problem of bypassing hold points. Actions taken to eliminate bypassed hold points include:
Training of personnel including crafts.
e Holding quality circle meetings.
e e The responsibility for keeping track of the individuals was re-assigned to supervision personnel who are also directly responsible for terminating individuals who have more than 2 hold point violations. Termination should provide the motivation for personnel not to violate hold points.
The method of establishing hold points has been proceduralized.
e The quantity of hold points has been reduced to the essential few, e
including elimination of ill-defined hold points (e.g., interpass temperatures).
Revisions have been made to the technical specification to reduce e
unnecessary contract-required hold points (e.g. customer hold point on root pass for ISI welds).
It is anticipated that upon ramp-up, the above actions will be rein-stated and re-emphasized.
Subparagraph 3a - Piping Lug Sizing
- a. Technical Accuracy No Comment -wy7~~m:r w
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1 1
b.'Need for Clarification Past history of the deficiency noted above shows that the Supply System responded to the NRC inspection report within one month.
Questions raised by the NRC in January 1981 regarding. the Supply System's response were answered the same month. The NRC did not re-address this problem until June 1981, when additional questions-were raised by the inspector. This does nct substantiate an example of I
corrective action which required repeated NRC prompting.
- c. Actions Taken/ Planned The specific actions taken on this item are contained in the formal response to the NRC (G01-80-347, dated November 6, 1980 and G01-81-20, I
dated January 27, 1981). A summary of the actions taken are as follows:
The NRC identified 2 undersize welds on spool DHR-412030-2. Project e
QA identified an additional 4
undersize welds on spool DHR-412030-2.
i A nonconformance report was issued for 6 undersize stop block welds e
j on pipe spool DHR-412030-2.
l Surveillance was performed on a random sample of 54 pipe spools for e
identification of similar conditions.
Thirty drawings were checked on site to identify pipe spools with e
shop-welded lugs. Five drawings identified had a total of 15 spools with shop welded lugs. None of the spools had been received on site.
i l
e Project QA issued a second NCR on 1-23-81 for 8 undersize stop l
block welds on pipe spool HSF-411790-3.
A Corrective Action Request was issued to the vendor on 1-26-81 for e
inadequate weld inspections.
e UE&C vendor surveillance was instructed to include 100% dimensional inspection of all attachment welds as part of " final inspection".
e The NCR's were dispositioned by UE&C Engineering. Disposition action to be completed when construction is restarted.
- d. Further Actions Required Resolution of additional questions raised in NRC Inspection Report e
50-460/82-10 and update Project file.,
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_ - _,. _. _ _ -. _ _, _.. ~., - - ~ - - - -
i Subparagraph 3b - Control of Weldolet Installation Criteria
- a. Technical Accuracy The prior assessment period example referred to an allegation by a field pipefitter that a shop weld on a weldolet appeared to be undersize. The current assessment period example regarding weldolets involved the failure to include installation criteria in the applicable field procedure,
- b. Need for Clarification As noted above, one identified deficiency on weldolets involved an alleged undersize shop weld and the other identified deficiency involved the failure to include the weldolet installation criteria into a field installation procedure. In both cases, the installation criteria had been defined in the specifications and ASME Code. Due to the difference in the nature of the two deficiencies, corrective action taken with the supplier who made the shop weld would be unre-lated to corrective action taken with regard to the field installation procedure deficiency.
Since both the identified deficiencies and the required corrective actions were unrelated, it cannot be concluded that the corrective action taken was weak nor that repeated NRC prompting was required to resolve the issues.
The issue was not resolved during the current assessment period due to the deferral of construction and the resulting lack of manpower to perform the required reinspections.
- c. Action Taken/ Planned The specific actions taken on the item addressed during the current assessment period are contained in the formal response to the NRC G01-81-04, dated January 12, 1981.
These actions included the following:
e A nonconformance report was issued to document the lack of installation / acceptance criteria in the field procedure.
e The applicable field procedure was revised to include the weldolet installation / acceptance criteria.
Reinspection of installed weldolets to the installation / acceptance e
criteria included in the revised procedure will be completed after restart of construction. ~ n
_.w.
_ _._ 2_ =-.
Subparagraph 3c - Temporary Attachments, Heat Exchanger Washers, and Contamination of Stainless Steel Piping
- a. Technical Accuracy No Comment
- b. Need for Clarification No Comment
- c. Action Taken/ Planned Temporary attachment welds and heat exchanger washers are being tracked as open NRC items requiring further Project actions. The contamination of stainless steel piping was responded to in Letter No.
G01-82-0578.
Subparagraph 4a - Weld Penetration on a Pipe Whip Restraint
- a. Technical Accuracy Factual
- b. Need for Clarification Further investigation by the Supply System and UE&C into this ident-ified problem, shows the cause of the undersized partial penetration welds to be improperly prepared weld bevels rather than a lack of penetration. These items were fabricated off-site by a prepurchased supplier and not a site contractor.
- c. Action Taken/ Planned The specific actions taken on this item are contained in the formal response to the NRC (G01-82-0578), dated September 30, 1982.
i Subparagraph 4b - Absence of Skew Weld Acceptance Criteria
- a. Technical Accuracy Factual
- b. Need for Clarification No Comment
- c. Action Taken/ Planned Actions were identified in our following responses: G01-81-414, dated 12/12/81; G01-82-0066, dated 3/10/82; and G01-82-0437, dated 7/16/82. __
Subparagraph 4c - Post Weld Heat Treatment Prior to Resolution of a Nonconformance Report I
- a. Technical Accuracy i
No Comment
- b. Need for Clarification l
l No Comment
- c. Action Taken/ Planned
}
l The corrective action taken on " post weld heat treatment" (PWHT) prior j
to resolution of a nonconformance report included the assignment of one individual responsible to release welds for PWHT, assuring that applicable documents are included in work packages and reinstructing i
the QC supervision. This corrective action was verified by the NRC and l
the item was closed by the NRC during the inspection.
Paragraph 5 -
- a. Technical Accuracy Factual I
- b. Need for Clarification No Comment
- c. Action Taken/ Planned I
L No Comment i
Paragraph 6 -
i
- a. Technical Accuracy No Comment
- b. Need for Clarification o This problem, as it relates to skewed weld criteria, should be assigned to the category of " inadequate review of contractor procedures" and is being addressed as part of programmatic action to strengthen this area of interface between the Engineer, Construction Manager and Contractors.
_9_
1
e All applicable portions of 10CFR50, Appendix B, requirements were imposed on the design of the Pipe Whip Restraints. At the time the Pipe Whip Restraints were released for fabrication, it was 4
determined that their functional requirements did not warrant a need to classify them as WPPSS Quality Class I. Upon later review by the Supply System, it was determined that the Pipe Whip Restraints be classified as Quality Class I.
Prior to the Supply System reassessment of the quality classifi-cation of the Pipe Whip Restraints, UE8C had initiated an independent evaluation of the fabrication, quality control and inspection procedures, and had determined that the processes and procedures employed in the manufacture of the Pipe Whip Restraints (by Corner & Lada) are of a level equivalent to be WPPSS Quality Class I
requirements generally applied to Quality Class I
components. Recently, a decision to retroactively upgrade the quality class of the hardware has been taken at the direction of the Supply System. No changes in hardware or substantive changes in documentation are anticipated. Installation of the hardware has
]
been specified to be in accordance with WPPSS Quality Class I requirements.
e During the conduct of seismic analyses of the piping systems, instances of conscious deviation from the lumped mass modeling techniques specified in UE&C's Mechanical Analysis Group procedure had been an accepted practice. This was done on the basis that the resulting models, as judged by the analyst, would produce adequate results. The basis for such deviations from the procedure were not
{
documented as part of the piping analysis packages.
To address the concerns over the acceptability of the deviations from the specified Mechanical Analysis Group procedure, UE&C (at the request of the Supply System) conducted technical reevaluation of samples of piping analysis packages. The reanalyses have shown 4
that the original
- analyses, including said deviations, have l
produced conservative results. The Engineer has now taken all i
necessary steps to ensure that the procedure will clearly mandate the need to document the basis for deviating from the specified piping analysis procedure in the future.
- c. Action Taken/ Planned No Comment Paragraph 7 -
- a. Technical Accuracy l
No Comment
- b. Need for Clarification i
i No Comment
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c.. Action Taken/P1anned A list of lessons learned at WNP-2 was sent to WNP-1/4 Quality Class I contractors during January 1982. The site contractors were requested to review the lessons learned guidelines and respond identifying program aspects in force, or those that will be implemented to prevent similar occurances. All of the currently suspended contractors have responded.
8 The responses reflected that some of the lessons learned items were not problems at WNP-1/4 while others represented concerns that required action. Many of those requiring action related to documenta-tion review which is now in progress. Others requiring actions relate i
to procedure streamlining which is planned for action prior to restart of construction activity. Additionally, management attention at WNP-1 was focused on documentation as a result of occurences at WNP-2. It was not necessary for the NRC to continually remind the Supply System of its commitment to the NRC in this area.
)
Paragraph 8 -
- a. Technical Accuracy Addressed in Attachment I.
- b. Need for Clarification Addressed in Attachment I.
- c. Action Taken/ Planned i
Addressed in Attachment I.
Item 4 - Safety-Related Components l
Paragraph 1 -
- a. Technical Accuracy No Comment
- b. Need for Clarification No Comment
- c. Action Planned /Taken The heat exchanger washers are being tracked as an NRC open item requiring additional inspections. a.w vm. p g- ;. 2 -
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P,aragraph 2 - See response to Section VI, Item 1(e)
Paragraph 3 -
- a. Technical Accuracy No Comment
- b. Need for Clarification No Comment
- c. Action Taken/ Planned No Comment Paragraph 4 -
- a. Technical Accuracy Addressed in Attachment I.
- b. Need for Clarification Addressed in Attachment I
- c. Action Taken/ Planned Addressed in Attachment I Item 5 - Support Systems (Heating & Ventilating)
Paragraph 1 -
- a. Technical Accuracy No Comment
- b. Need for Clarification The NRC's perception that weaknesses identified during the prior assessment period continue into the current period is accurate as it relates to the effectiveness of corrective action, however, the need to aid the HVAC contractor had been well understood and actions, had been taken to strengthen the contractor's management. Therefore, the
- category,
" weakness", is not justified because the Supply System identified the need for corrective action and continues to evaluate it.,..
- . --. ~,,-:
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- c. Action Taken/ Planned i
The following actions took place during this assessment period to improve the HVAC contractor's performance:
e The CM's Quality Control surveillance of contractor operations commenced on May 18, 1981 and by October / November 1981 an additional Quality Control Engineer was assigned to the HVAC contract on day shift, and swing shift surveillance activities were also increased. In addition, a change was made in QC Leads assigned to the HVAC contract. This change permitted the lead to devote additional time to the contract.
e Late in February 1982, the CM's Assistant Project Construction QC Engineer was assigned to spend full time on the HVAC contract with principal emphasis on revising procedures. The initial procedure to be rewritten was QCP/CP 27.0, which was implemented on April 5, 1982. Three additional procedures were in a state of review / rewrite at the time of the extended construction delay. A part of the procedure rewrite included interfacing with the A/E in areas where the contract specifications lacked definitive accept / reject cri-teria, which was necessary for incorporation into revised proce-dures. The CM's welding engineering personnel, Lead QC Engineer, A/E's weld engineer, and the owner's weld engineer were involved in the review of the contractor's welding procedures. The contractor has subsequently revised the WPS's as necessary.
e The HVAC contractor also had several initiatives underway durin5 this time frame directed at improving the quality of the work and 4
the inspections. Some of these were at the CM's direction, while others were contractor-initiated with CM concurrence. Included in 1
j these initiatives was the employing of a Field QA Manager to supervise the union inspection personnel in the field areas. The individual filling this position is an ex-CM QCE who had been assigned to the HVAC contract. This resulted in the contractor utilizing an individual who was knowledgeable in the contract and the on-going problems / allegations. The contractor added 15 field engineers, four QAE's (to add inspection criteria to inspection docut.entation as required by the revised QCP/CP 27.0), and a lead auditor. Inspection personnel reassignments were made in order to eliminate unrest. The HVAC contractor's Corporate QA Manager was on site full time for a period of six weeks, just prior to the shutdown of WNP-1.
l Paragraph 2 -
- a. Technical Accuracy See Below l
i l
- _ n_-
- _ y
b, Need for Clarification The report is technically correct in that there were 6 en?orcement items during this period, however, the description of the items appear incorrect. We are unable to identify the enforcement item involving
" material receiving contrary to procedures". This appears to be a follow-up item (81-07-08). It is difficult to associate items with the description provided in the draft SALP report.
- c. Action Taken/ Planned Identified in response to the following specific enforcement items.
NRC Inspection Report No.
Response
81-07-07 G01-81-424 82-04-01 G01-82-0412 82-04-02 G01-82-0412 82-04-03 G01-82-0412 82-07-01 G01-82-0415 82-07-01 G01-82-0717 Paragraph 3 -
- a. Technical Accuraci '
No Comment
- b. Need for Clarification No Comment
- c. Action Taken/ Planned No Comment j
j Paragraph 4 -
r
- a. Technical Accuracy No Comment s
~
- b. Need for Clarification
~
While the specifics are generally correct, the words exaggerate the condition and erroneously state that the contractor did not review procedures-for. departures from ccdes and standards. The failure to write an NCR an uninspected tark welds has been responded to as an l
item of nor.co.apliance (Letter Nos. G01-82-0415 'and G01-82-0717). It should also be noted that the failure to implement revised procedures also relates to the inspection of tack welds. A procedure was revised to inspect temporary attachment welds; -and tack welds were included with the temporary attachment welds. Further discussion of this topic does not appear to be appropriate since it has been discussed frequently with the NRC and has been the subject of considerable correspondence.
l *p%Itc i:
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I c.' Action Taken/ Planned As stated earlier, the CM had started reviewing the HVAC contractor's procedures prior to rampdown. It is anticipated that these proc.1dures i
will be reviewed at a later date and prior to the restart of construction.
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't Paragraph 5 - Also addressed in Attachment I.
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4 Based on substantive facts which show management, awareness and involvement, we do not believe that the word, "weakneds'.'"is. justified. i t.
Item 6 - Electrical Power Supply & Distribution x - t
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1
- a. Technical Accuracy
\\y i
1 No Comment t
d'
- b. g ed for Clarification i
'6 No Comment l
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- c. A: tion Taken/ Planned-
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No Ccm.nt I
Paragraph 2 -
3
- a. Technical Accuracy Factual
- b. Need for Clarification No Comment x
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- c. Action Taken/ Planned 5
No Comment
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Paragraph 3 -
l
- a. Technical Accuracy i
.P No Comment
- b. Need for Clarification i
l No Comment i
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J, No Comment Paragraph 4 -
3 N
- a. Technical Accuracy.-
' ' ' -,.., s '
s No Comment i
b.'Need for Clarification See Attachment I, page 7, relating to the electrical contractor's QA Manager.
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- c. Action Taken/ Planned Letter Hos. G0i-82-0549 and G01-82-0550 respond to the two enforcement items.
p Paragraph 5 -
a Aqqhni_S3[Accur[3cy A.fdressed in,Attchment I.
- b. Nees for C16rification Addressed in Atrachment I
- c. Action Taken Planned
\\.
Addressed in Attachment I s
Item 7 - Instrumentation and Control Systems No Comment - All Paragra its Item 8 - Licensing 4ctivities.
No Comment - All Paragraph s
Item 9 - WNP-4 Deferred Construction i
No 'somment - All Paragraphs T
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S::cticn VI - M:nagement Issues That Apply To Mora Than One Functional Area Paragraph 1 -
- a. Technical Accuracy No Comment
- b. Need for Clarification The NRC's subjective perception that the " Supply System does not appear to be responsive to NRC issues of long standing", ignores management efforts which factually supported the Supply System's responsiveness.
- c. Action Taken/ Planned Specific actions are identified in Section IV (Item 5, paragraph lc) of this Attachment.
Paragraph la -
- a. Technical Accuracy Facutal
- b. Need for Clarification No Comment
- c. Action Taken/ Planned Specific actions are identifed in letter G01-82-0411, dated 7/2/82.
Paragraph lb
- a. Technical Accuracy Factual I
- b. Need for Clarification Responded to in Section IV (Item 5, Paragraph 4b) l
- c. Action Taken/ Planned l
l No Comment l
l I
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l Paragraph Ic -
- a. Technical Accuracy Factual I
- b. Need for Clarification Responded to in Section IV (Item 5, Paragraph 4b) i
- c. Action Taken/ Planned No Comment Paragraph Id -
- a. Technical Accuracy See Below i
- b. Need for Clarification There were only six (3 per unit) UllSI fabricated, installed and completed plenums as of 3/81. These plenums were all on elevation 399 1
of GSB. There were no otner plenum under f abrication or installations i
at that time.
(3/81). There are other plenums (i.e., exhaust, and end plenums) associated with prepurchased equipment. None of these were in the process of being fabricated / installed as of 3/81 and none of these were completed and accepted by QC as of 11/2/82. It is apparent that a nisunderstanding exists since there are only 3 plenums per unit, at one elevation in one t,ailding.
all l
No evidence was ;ocated to support the inference that 100% rein-spection was not going to be performed. The UNSI letter to UE&C (UMUE-81-5119) of plenums by 4/3/81". states in part "UNSI will perform a 100% reinspection A Supply System letter to NRC (G0-01-81-81) i states in part, "UNSI will perform 100% reinspe tion of plenums by j
4/3/81".
c It is noted that NRC Reports 81-02 and 8106 state in part, " random reinspection of other plenums". It would appear that commitments made at an NRC exit meeting to randomly reinspect other plenums should not 4
have been made since 100% reinspection had previously been performed, i
However, additional plenum fabrication may have been in process at the j
time of the NRC exit meeting which resulted in this commitment.
- c. Action Taken/ Planned 1
j No further action necessary.
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J Item 1.e. -
- a. Technical Accuracy See Below
- l
- b. Need for Clarification The Supply System has been actively involved in the qualification testing of the kNP-1 Target Rock valves since the first quarter of j
1981.
I In reviewing the I.E.
Headquarter's Report (99000906/82-01) issued July 29,~1982, it was found that corrective actions had been taken when appropriate, e.g., installation of additional test instruments and measuring devices.
However, due to test failures, the Supply System has not accepted the subject valves for use in the WNP-1 Containment. Letter G01-82-0760, i
dated November 9,1982, has been sent to R. F. Heishman and describes j
further actions which are being taken. This letter states in part:
"Because of the importance of this test program, the occurrence of previous discrepancies in testing, and recent revisions in the i
East-West Technology QA Program, the Supply System will ensure implementation of the East-West QA Program through surveillance i
and/or audit prior to and during the testing phase of the program.
" Target Rock has recommended three options to qualify the Supply System's solenoid operated valves. These were presented to and discussed with the NRC at the May 24, 1982, meeting in Bethesda.
i l
The Supply System is currently pursuing the option for an upgraded l
valve and retest. As soon as final test arrangements are made, the Supply System will inform the NRC.
" Based upon the lesson learned from this test... vendors have l
implemented the following corrective measures:
e Target Rock has hired a QA engineer with test experience exclu-sively to interface between the test lab and Target Rock engineers, AETL, the parent company of East-West Technology, has expressed e
an intention to hire a QA manager to supervise testing. This QA manager would directly interface with the test lab to assure that lab performance is adequate and meets contractual commit-ments."
- c. Action Taken/ Planned Addressed in letter G01-82-0760, dated November 9, 1982. -.
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Paragraph lf
- a. Technical Accuracy Factual j
- b. Need for Clarification None
- c. Actions Taken/ Planned l
If a bulletin, notice, or circular requires a future action during the startup or operation of the plant, the action is added to the Operations Commitment Tracking System. These open actions will then be used as input to the development of plant operating and maintenance procedures, l
i Item 2 -
l Paragraph 1 - Addressed in Attachment I, pages 2, 3 and 4.
l Item 2.a. -
t
- a. Technical Accuracy j
Addressed in Attachment I.
However, as we had r.oted during our November 3, 1982 meeting, it appears that Table 4 cf your report is in error because it shows no response received from the Supply System. You indicate in the applicable inspection report that l
subsequent prompt corrective action to resolve the noted matter and j
effect training of personnel appeared to have been adequate.
Therefore, no Supply System written response was required. The l
analysis of timeliness excludes the perspective of extenuating i
circumstances which justified the late response, and advised the NRC that responses would be late.
i
- b. Need for Clarification i
See Above l
- c. Action Taken/ Planned See Above 1
Item 2.b.
2
- a. Technical Accuracy See Below t
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- b. Need for Clarification We believe that the observations that are presented regarding the safety feature actuation set-points are not totally complete or indicative of all the factual circumstances involving the action taken i
to inform the NRC of this particular concern.
The initial identification of this concern was made by the system designer (B&W) with full knowledge of the reporting requirements stipulated by the Code of Federal Regulations. In this regard, the Commission's records will show that B&W's official notification of this particular concern was performed during the last quarter of-1981, 1
i and the Supply System immediately thereafter received official notification from B&W that this item had been reported to the NRC.
Knowing this, our Project activities then progressed with a full understanding that commitments for early notification of potenital deficiencies had been properly addressed.
At the tiae of this situation, it was the Project's interpretation i
that dout:le reporting cf deficiencies, i.e. report a deficiency as a 10CFRS'L bM) even th zgh it was reported as a Part 21, was not 4
required. However, upon clarification of this ambiguous area, we willingly submitted our March 15, 1982 report. Therefore, we take exception to the refere:1ced weaknesses and, in particular, to the implication that the Project was knowingly withholding information.
As you Pad mentioned during our November 3,1982 meeting, the NRC is in the prccess of issuing clarification to the reporting requirements of 10CFR50.55(e) and Part 21, and this clarification will remove the i
need for double reporting. Until such time that we receive official NRC clarification, we will continue to report Part 21's as 50.55(e)'s
]
when it is applicable.
The initial construction deficiency report, 10CFR50.55(e), which was submitted on the General Service Building (GSB) flooding provided a generalized category identification of the types of equipment involved, e.g., pumps, valves, pipe, etc., and also provided a general identification of the corrective actions which would be initiated for the categories of equipment. It is the Supply System's position that, since the specific pieces of equipment were identified on Bechtel Nonconformance Reports (BNCR's) and would be part of the 50.55(e) file maintained at the Project which is available for NRC review, a similar detailed accounting of the corrective action for each item identif'ica-tion number was not required to be submitted to the NRC. It should be noted that the approach taken for this 50.55(e) report was consistent i
with other reports which involved a large population of items, i.e.,
the details are maintained at the Project and are available for NRC review and closecut.
Please notify us if there has been a change in the NRC's interpre-I tation of reporting of 50.55(e)'s. i
,,-..._i
_. _. - _. _. __., ___ _ _~ _._,,_ _.. - _,. _
- c. Action Taken/ Planned No Comment Item 2.c. -
Addressed in Section IV, Item 3, subparagraph 3b - Weldolets, and 3c -
Washers Item 2.c. -
Subparagraph 2 -
Addressed in Section IV, Item 3, Subparagraph 3b - Weldolets and 3c -
Washers.
Item 3 - Ineffective Corrective Action Paragraph 1 -
- a. Technical Accuracy No Comment
- b. Need for Clarification No Comment
- c. Action Taken/ Planned See Section VI, item 6, Paragraph 1(f)
Item 3.a. - All Paragraphs
- a. Technical Accuracy No Comment
- b. Need for Clarification See Section IV, Item 5
- c. Action Planned /Taken See Section IV, Item 5 Item 3.b. -
The tone of this paragraph, with its reference to the eleven procedure t
violations, implies that procedural violations were pervasive and wide-spread. The project experience is to the contrary especially l
considering the high level of construction activity. It can be demonstrated that a positive trend exists, especially as it relates to the severity of problems and the quality of documentation. l I
3 l
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- a. Technical Accuracy
- For Items 1 and 2 - See Clarification Below
- For Items 3 No Comment
- b. Need for Clarification
- 1. Item No. I was identified during the previous SALP period should not be referenced here.
and
- 2. In item No. 2, been based on the contractor's QFR.the words, " extensive disrega rately described the condition.
The contractor's QFR inaccu-
- 3. For Items 3-11, No Comment
- c. Action Taken/ Planned Addressed in response to the specific item of noncompli ance.
Itcu 3.c. -
- a. Technical Accuracy Factual
- b. Uced for Clarification No Comment
- c. Action Taken/ Planned No Comment Item 3.d. -
- a. Technical Accuracy Factual
- b. Need for Clarification No Comment
- c. Action Taken/ Planned Actions taken were described ance (Letter G01-81-424).
in responses to the items of noncompli-l -
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Item 3.e. -
- a. Technical Accuracy No Comment
- b. Need for Clarification No Comment
- c. Action Taken/ Planned Actions taken and clarification were described in the revised response to the item of noncompliance. (See Letter G01-82-0716)
Item 3.f. -
- a. Technical Accuracy No Comment
- b. Need for Clarification No Comment
- c. Action Taken/ Planned Corrective action ccmplete - see NRC Report 82-05.
Item 3.g. -
- a. Technical Accuracy Factual
- b. Need for Clarification No Comment
- c. Action Taken/ Planned No Comment item 4 -
- a. Technical Accuracy Factual
- b. Need for Clarification No Comment ----m--
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- c. Action Taken/ Planned See responses to Items of Noncompliance (Letters G01-82-0187 and G01-82-0142).
Item 5 - Design Control
- a. Technical Accuracy Factual
- b. Need for Clarification No Comment
- c. Actions Taken/ Planned The A/E has an ongoing program for implementation of design changes initiated in the construction process into the design documents. This program is known as the Nine and Ninety program and is currently planned to be fully active during construction deferral. Further, the computerized field change tracking system which is part of the computerized Document Control System (DCS) is constantly being up-graded during the deferral period to provide accurate listings of incorporated and outstanding design changes.
Additionally, the A/E has an ongoing program and procedure for recon-ciliation of contractors' "As-Builts" even during the delay period to provide accountability of design changes to plant structures, systems components and processes. Discipline-specific appendices, used for checking of contractor "As-Built" drawings, are under development and review by the Owner and the A/E. Preliminary and final Design Verification will be integrated with the above program.
l Management attention to Design Change Control and "As-Built" design verification will continue.
item 6 -
l
- a. Technical Accuracy No Comment i
- b. Need for Clarification 1
The Supply System had conducted a special review of the UESC Vendor Surveillance Program in July 1981, which resulted in improvements and enhancements to the existing program, however, no conditions were identified which appeared to warrant any additional management l
attention to this area. --
4 Based on the Project Inspector's request, the ten (10) examples j
identified in Report 82-11 were used to determine if a generic problem j
existed with vendor-supplied hardware quality. It was determined from the evaluation made that no further additional measures were required for vendor-furnished items. This determination was generally based on one or more of the following:
e Inspections / tests which exceeded accepted manufacturing codes /-
standards requirements would have had to have been performed to identify the identified defects.
l The defects were determined not to exist in WNP-1/4 equipment or e
i
- material, i
j e Initial corrective action was adequate and comprehensive to resolve the initial identified condition.
e Unusual reinspection /NDE would have been required to identify the I
deficiency during vendor surveillance or receipt inspection.
1
- c. Action Taken/ Planned t
l No Comment Item 7 -
- a. Technical Accuracy
)
Addressed in Attachment I, pages 5-7. We are requesting that the term
" weakness" be removed from the report due to lack of substartive i
supporting evidence.
I j
- b. Need for Clarification l
Addressed in Attachment I, pages 5-7
- c. Action Taken/ Planned l
l Addressed in Attachment I, pages 5-7 I
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