ML20065K854
| ML20065K854 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Marble Hill |
| Issue date: | 06/30/1980 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML082180535 | List:
|
| References | |
| FOIA-82-261 NUDOCS 8210080159 | |
| Download: ML20065K854 (9) | |
Text
.
l MARBLE HILL Evaluation Period: 7/1/79 - 6/30/80 I
GENERAL During the SALP-1 appraisal period the licensee has developed and implemented a formal program specifically designed to improve the regulatory performance.
These included staffing and organizational 4'
~,.
changes, quality assurance program development, and the identifica-tion and resolution of problems.
Incremental resumption of safety-4h:..
related construction, subject to the approval of the NRC, commenced
?
c y
,7j subsequent to the evaluation period as described below.
v _. ?.>.0 i
f' The Director of IE authorized the 3
M following activities:
o d.V ? ' [.
PSIs resumption of receipt inspection.
07-07-80
.s_
w CjfU PSIs contractors, Cherne Contracting Corp.
11-13-80
'1 ~
./ D.: 1 (CCC) and Commonwealth-Lord J. V. (CLJV)
' Sl to resume receipt inspection.
.y;,}l:c.4.y i
""i CCC and CLJV to resume mechancial, piping 12-05-80
'3, ' _.,j and. electrical work.
.D
. y;,F.,
9; L.Q?f Resumption of all safety-related work in-03-27-81 Ih ;;gt jplg cluding concrete placement.
~:;.;;p
@Q:M,
.g The Order remains in place.
w ~~'M II SPECIFIC vi; I
A.
CONTENTION:
"The license'e's activities prior to and during the early part of the evaluation period displayed evidence of Project Engineering, Quality Assurance, and Construction Management L
weaknesses."
l L
- 1.
- Basis
~
g I:
During inspections conducted in April 3-6 IE Inspection Reporta
?
and April 30-May 3, 1979, problems were No. 50-546 and identified relative to the placement and 547/79-03, 79-04, repair of concrete. A Management meeting 79-05, 79-08 l
with PSI was held on May 15, 1979, to L
discuss these findings. On June 12, 1979, the NRC received information that a former worker of the Marble Hill site had alleged improper repairs of honeycomb areas in con-crete.
The allegations were contained in a
~
~
sworn statements submitted to the office of Nuclear Reactor Regulations (NRR) through
(.-
an attorney representing an Indiana'in-tervener group.
Subsequently, Region III received a copy and initiated an inves-tigation ~on June.-22, -1919. -
8210000159 B20712 PDR FOIA UDELL82-261 PDR
- a. u.
l
(~
On June 26, 1979, a second meeting was IAL 06-27-79
(
held with PSI officials to discuss the findings of the investigation at that point and the fact that the deficient repairs of concrete had been identified.
As a result of this meeting PSI agreed to stop concrete activities for safety e-related structures, perform non-destruc-tive examinations of various concrete structures, identify and evaluate re-
.i, paired areas for adequacy and review O, ila their entire program for concrete ac-MM tivities onsite.
An Immediate Action Y~;F.
Letter (IAL) dated June 27, 1979, was d'f3 issued confirming this agreement.
M':M On June 27-29 and July 2-7, 1979, inspec-IE Inspection
@Q;@@d gr.
tion was conducted relative to Items 1, Report No. 79-07 i-74 2, 3, 4 and 5 of the IAL.
Based on the N XN results of this inspection, Region III jfydj concurred in the resumpt. ion of concrete
%W'? -
placement for safety related structures.
..c;t;d One item of noncompliance was identified SMi with regard to failure to assure purchased
'Mi services conformed to procurement documents.
%:y M
@?.3 Initial results of'the inspection con-IAL 07-23-79, IE ducted during the period of " July 9 Inspection Report
' -agd through July 27, 1979 lead to a site No. 79-09
?,pfyrj management meeting on July 20, 1979,
.m. J.
and an understanding that the licensee I
would again stop concrete activities for safety related structures. A second Immediate Action Letter (IAL) dated July 23, 1979, was issued docu-menting this understanding.
Five items of noncompliance were identified with regard to:
inadequate QC inspection, six examples; inadequate specification of quality requirements, four examples; lack of or failure to follow procedures, four examples; failure to take effective corrective actions, three examples; and lack of adequate training.
On July 25, 1979, Region III learned that IE Inspection Report a team from the National Board of Boiler No. 79-11 and Pressure Vessel Inspectors had con-ducted an inspection on June 12-14, 1979,
~
at the Marble Hill site during which numerous items of noncompliance with the
. ASME Code were found. As of the result
(
of the National Board's inspection and
\\
the Region III fi0 dings.a comprehensive team inspection was conducted during the,
d
-._..,--.-.m,
._._..:....__.u..-
~
(" ~
period of July 26-28, July 31-August 3, 1979. The purpose of this inspection was to identify the underlying causes leading to the concrete and ASME Code Deficiencie:.
and to determine if they were symptomatic of problems in other areas. The results of this inspection indicated that problems and the Quality Assurance / Quality Control (QA/QC) program in concrete construction
,,' y activities extended to other construction
- l areas as well.
Four items of noncompliance wero identified:
failure to sufficiently S
implement the QA program; failure of estab-lished measures to assure the conditions adverse quality were promptly identified and corrected; failure to assure the special
~
processes, including welding...are control-s.
led...by... qualified procedures; and failure "w:, M; to properly control materials...which do not I ' '
, y-conform to requirements.
- .,.i 2.
NRC Actions m u2 NRC actions following the identifica-7(E -,'
tion of problems relative to placement J.Gd j
'and repair of concrete and prior to this 7". M
- Q; SALP evaluation period are described in j g;-l qp Paragraph 1, Basis.
Il Region III issued a second IAL Letter 07-23-79 N]
which confirmed that PSI would again stop concrete activities for safety-related structures.
As a result of findings prior to this IE inspection Report
~
evaluation period Region III conducted No. 79-11
- a. comprehensive team inspection during the period of July 26-28, July 31-August 3, 1979. The results of this team inspection are as follows.
' NRC concluded that effective implementa -
tion of the documented Marble Hill Quality Assurance program for all safety-related construction had not occurred.
PSI and their contractors had not sufficiently complied with its fundamental commitment to conduct all of these construction activities in accordance with the re-quirements of 10 CFR 50, Appendix B, and other required codes and standards.
~
'(
The principal causes of these adverse
\\
conditions and noncompliances were:
'(1J insufficient m aagement and manage- -
..n.-
l l
i ment support, (2) insufficient number of personnel, (3) insufficient technical qualification of personnel, and (4) in-sufficiently experienced personnel.
i l
The secondary but significant contributing J
causes were:
(1) failure to adequately c
identify PSI's task or mission regarding i
the verification of the adequacy of work done by contractors, (2) failure to devise l
a system to co'aprehensively account for and evaluate cl1 identified nonconform-ances occurring on the site, (3) failure to recognize the generic implications of l'
recurring, deficiencies, (4) failure to lp recognize that fixed price construction
~
7 contracts, while not inherently defective, are likely to place heavier demands on yfi the licensee verification of construction j
adequacy, (5) failure to delegate sufficient j
authority to QC inspectors and their
/3 managers regarding stop-work authority, (6) failure to institute employment M
(manning) and compensation practices 7
which would attract adequately qual-
$j ified and experienced job applicants, S
gg.)
(7) failure of corporate management M
- m. )
to recognize the need to be more d
responsive to site QA/QC mgpning A
request, (8) failure to be respon-lT:
sive to and recognize the importance and authority of construction code I
enforcement bodies, and (9) failure l
to recognize that the use and at-tempted upgrading of laborers to supplement unavailable journeyman
, craftsmen requires more coniprehensive l
training and oversite.
The above findings by their nature involved all safety-related construc-tion activity by PSI and their contractors at the site. Without extensive corrective actions, there was little likelyhood that continued construction could be accomplished with adequate assurance that quality requirements would be met.
At the request of PSI, representa-IE Inspection. Report tives of Region III and PSI No. 79-14, as.d management met again on August 1, Order 8-15-79
('
1979, to discuss PSI's planned ac-
\\
tions to correct the programmatic
- l l
QA/QC problems at the Marble Hill site. Meeting included a discussion of the desirably of stopping all safety-related construction activities at the Marble Hill site until such time as the licensee demonstrates that it has an affective QA program e
acceptable to the NRC.
The licensee issued a stopwork order on August 7,
.,,t 1979, for all safety-related construc-A-
tion. An order confirming this v.,
suspension of construction was issued M4; ',
on August 15, 1979, by the NRC. A M i.:
meeting was held with PSI management
[*'
in the Region III offices on August 15,
?
1979, to discuss the conditions of the
.J' confirming order.
L: s y f.).[9 Numerous management conferences were IE Inspection Reports
, i.
held during this evaulation period No. 79-24, 79-28, ph J.
after the issuance of the order.
80-05, 80-07, 80-12, HR X l these conferences occured on the 80-17, 80-24.
S..i following dates:
11-08-79, 12-10-79, u.-iff s; 01-21-80, 02-20-80, 02-27-80, 03-31-80, LiehWi 04-30-80, and 06-27-80.
On 03-25-80 a M?s!)
public meeting was held in Madison,
!$Q%il Ma.
Indiana to discuss the licensees re-b
.sponse to the August 15, 1979 " Order W{i Confirming Suspension o,f Construction."
g4pl -
Upon issuance of the order an aug-08-15-79 i
1.,,,.
~
mented inspection. program to verify ccmpliance with the order was initiated.
A full-time senior resident inspector 12-03-79 was assigned to the Marble Hill site.
A formal briefing on resumption of 05-07-80 construction of Marble Hill was presented to the NRC Commissioners.
The Director of IE issued a document 05-15-80
.l' titled " Graduated Recission to the August 15, 1979 Order." This docu-l ment prescribed a graduated rescission I
process for implementation at Marble Hill to assure that the licensee's corrective actions were implemented and effective. Construction ac-tivities at the Marble Hill site resumed in a graduated, step-wise fasnion with review by the NRC at
}-
appropriate stages.
r
-~ ~
Ca 3.-
Licensee Corrective Actions Licensee Corrective Actions relative to each Immediate Action Letter (IAL) are documented in the inspection reports referencad in Paragraph 1, Basis.
The correc-tive actions relative to inspection findings that resulted in the issuance of the August 15, 1979 Order s4 and those items identified in the Order are documented in virtually all of the inspection reports issued since
-7, that time and during this SALP evaluation period.
In i
addition the following documents which are available in the local Public Document Room describe the licensees
{
corrective actions:
J;ii if Report SL-3753, Evaluation of Inplace Concrete, Marble Hill Nuclear Generating Station Units 1 9;
]q and 2, prepared for PSI by Sargent and Lundy Engineers, November 20, 1979.
Revision 1,
?M November 21, 1980.
3 February 28, 1980, DISCRIPTION OF LICENSEE ACTIVITIES d
ADDRESSING ORDER CONFIRMING SUSPENSION OF CONSTRUCTI J
April 28, 1980, CONSOLIDATED DESCRIPTION OF QUALITY q
fSSURANCE PROGRAM.
s September 12, 1980, CONSTRUCTION AND MATERIAL VERIFICATION 7_,
'M f PROGRAM, FINAL REPORT.
REPORT REVISED May 15, 1981.
B.
Contention
~
a "The licensee had not sufficiently implemented Quality Assurance
}
and Management Controls."
1.
Basis M.ajor examples are the same as identified in Coittention A.
I 2.
NRC Actions
[.
Major examples are the same as identified in Contention A.
l 3.
Licensee Corrective Actions Major examples are the same as identified in Contention A.
C.
Contention "There were ineffective controls over civil and mechanical
~
construction."
1.
Basis k
Major examples are the same as identified in Contention A.
2.
NRC Actions Major examples are the same as identified in Contention A.
3.
Licensee Corrective Actions Major examples are the same as identified in Contention A.
D.
Contention
~
"There were ineffective controls over stored equipment and components."
1.
Basis
,Y
~
During an inspection on November 14-20, IE Inspection Reports 1,..
1979, one item of noncompliance ident-No. 73-25 and
~
7:.
ified relative to failure to provide No. 80-03 proper storage and maintenance of 7,.
material with 19 examples.
Six other
'c items of noncompliance were identified during an inspection on January 7-31, 1980 with the following findings:
i; failure to include quality storage require-
' ?:
ments in procurement documents; failure to j;;
prescribe a quality storage activitiy in
@1
%(fj) d documented procedure; failure to adequately implement (verify conformance) a storage 3
inspection program; failure to trovide K
adequate storage / preservation instructions f
and to provide such instructions in timely' manner; failure to adequately identify storage nonconformances; and failure to provide prompt corrective action for storage nonconformances.
. 2.
.NRC Actions i
.yl Same as identified in Contention A.
IE Inspection J
Report No. 80-43 3.
-Licensee Corrective Actions The licensee developed an extensive material control program which was implemented subsequent to this SALP evaluation l
period.
1 l
E.
Contention
" Quality Control inspections by contractor personnel were not performed effectively."
1
(-
1.
Basis
\\
Major example ~s are thi-same'gs_ identified in Contention A. 4 l
2.
NRC Actions Major examples are the same as identified in Contention A.
3.
Licensee Corrective Actions Major examples are the same as identified in Contention A.
F.
Contention
" Conditions adverse to quality were not corrected prior to concrete placement."
1.
Basis i
Major examples are the same as identified in Contention A.
2.
NRC Actions Major examples are the same as identified in Contention A.
3.
Licensee Corrective Action Major examples are the same at identified in Contention A.
G.
Contention h)bh
'ICorrective actions were not taken for discrepancies."
u
~
1.
Basis Major examples are the same as identified in Centention A.
i 2.
NRC Actions Major examples are the same as identified in Contention A.
3.'
License ~e Corrective Actions Major examples are the same as identified in Contention A.
H.
Contention
" Marble Hill received a relatively large number of items of non-compliance when compared to other construction facilities under construction."
l 1.
Basis l
The number of items of noncompliance were IE Inspection Report l
high, however, in view of the fact that No. 80-45 i
safety-related construction work was
~
suspdnded by an NRC order for most of the appraisal period, there was no tasis to l
! l
compare the licensee's regulatory perform-ance with other plants under construction.
The majority of items of noncompliance dealt with activities in progress before work was suspended, except those discussed in Contention D.
2.
NRC Actions Same as identified in Contention A.
3.
Licensee Corrective Action Same as identified in Contention A.
I.
Contention "There were instances where the licensee required escalated NRC enforcement action, frequent management contacts, and stopwork orders to assure compliance with NRC requirements.
An order suspending all cafety-related was issued in August 1979, because of NRC concerns over the adequacy of the licensee's quality assur-ance program and controls over construction activities."
1.
Basis Major examples are the same as identified in Contention A.
2.
NRC Actions Major examples are the same as identified in Contention A.
t t
3.
Licensee Corrective Actions Major examples are the same as identified in Contention A.
1
= - -
mg
- 3 9_
...