ML20065K865

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Systematic Assessment of Licensee Performance Notes Re Facility Evaluation for Aug 1979-Jul 1980
ML20065K865
Person / Time
Site: 05000000, South Texas
Issue date: 07/31/1980
From:
NRC
To:
Shared Package
ML082180535 List:
References
FOIA-82-261 NUDOCS 8210080163
Download: ML20065K865 (13)
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{{#Wiki_filter:.. .a South Texas Project 1 & 2 Evaluation Period: 8/1/79 - 7/31/80 I. General 'i The licensee has taken positive action to correct areas of weakness ,Q. 9 identified by the NRC. ~~ ~ The licensee has changed the Houston Lighting and Power Company (HL&P) and ",,, N. Brown and Root (B&R) QA organizational structurP, adding a quality }; 'A. ' assurance (QA) engineering group to the site organization. Experienced personnel have been placed in key positions in HL&P and B&R management, e f.['/-.. engineering and QA organizations. Senior management has become sufficiently 343;d involved with site construction operations to be aware of problems and to 7'M '1 better control the project. Extensive training has been accomplished from W the worker level to the senior management level. A zero defects program k*p%g$;, is in place to emphasize a " quality first approach." Implementation of l recommendations resulting from a Bechtel Audit, dated July 24, 1980, has $4 resulted in an improved QA program in the following areas: (1) Procedures, G.k.1 (2) Documentation and Analysis of Defects, (3) Training and Qualification M'. W,-Q. ,of Personnel, (4) System Controls,'(5) Audit System, and (6) Management .. m, Involvement. ,r %lM) Region IV NRC inspectors, especially the RRI, have had daily contact with personnel from the Senior Management level down to the worker level. In 4M1 general HL&P an'd B&R managers have demonstrated a very cooperative $$$j /N.. attitude relative to correcting any deficiencies identified and resolving v.wN Q7;' conditions which might lead to violations of requirements, procedures, or M,%gl.y ^ ccmmitments. Key senior management,.who were convinced they had a very 4 good program before receiving the Order to Show Cause and civil penalty, % J.y now recognize they fell into some pitfalls that were experienced by many other licensees in the early 1970s. Management appears to be determined to avoid similar pitfalls in the future. Key management personnel, who have had a great deal of experience at other nuclear sites, are confident that they can eliminate mistakes caused by the previous lack of experience in nuclear construction. The RRI and other inspectors have had numerous contacts with workers, inspectors, supervisors and managers. The consensus has been that there is no problem now relative to QC inspectors being pressured, harassed, threatened and intimidated. T give adequate support to QC in,he new QA/QC managers and supervisors spectors. l. Region IV inspectors have reviewed the licensee's and contractor's j corrective action relative to Category 1 structural backfill, safety-related concrete structures including embedments, welding and non-destructive examination and found the corrective action or implementation of commitments to be adequate. II. Specific (Contentions A through J below are examples of the more general contention, .( "The South Texas Project facility displayed evidence of management weaknesses in the areas of Qu.ality Assurance and overall construction management." pojo g 63 020712 UDELL82-261 PDR

. ~.. - 1 A. Contention "The licensee had not sufficiently implemented Quality Assurance and management controls." 1. Basis References Ouring the period August 1,1979 through IE Reports c,' July 31, 1980, 36 items of noncompliance were 50-498/499, 97 identified, 22 of which depicted inadequate 79-13, 79-14, implementation of direct management control. 79-15, 79-16, , 1 :.: 79-19, 79-20, ' '/.? 80-01, 80-05, .'.u;4 & 80-07 L ;: Allegations of QA/QC program irregularities IE Reports ! ' '-l s: ; were substantiated during the evaluation 50-498/499, ~

',j period substantiated during the evaluation 79-13, 79-19, w

7-period. 80-14, & 80-21

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Significant civil / structural problems identified 10/4/78 - ,;f ,:{ and reported to RIV by the licensee were in Dimensional

'Ob3 effect at the beginning of and during the Error in Base

.IL evaluation period. Slab MEAB-2 ffi 6/18/79 - Voids N'l'.o 't}[g)- Lift No. 8, r'" 9 RCB 1 w.m.d - NSI 2/4/80 - Nonconforming a e Backfill Material f Unit. - 2 l 1 2/7/80 - RCB 2 Liner Bulge 3/12/80 - Rejectable Indi' cations in RT of ECW Piping 3/12/80 - Voida Under Cross-ovc; Leg Embedments Unit 1 6/4/80 - Break = down in QA l . ( Concrete Placec Program for ment CIl-W90 s r - ', - ~ (Unit 1)

6/5/80 - ~ Excessive a Lift Thick-ness of I Concrete Placement DG1-W3A (EDG J." Building) U 6/13/80 - Breakdown T;; in QA Program 9 Procurement +a ..N Cycle cf Purchased a# Materials M M. -c:M 6/20/80 - Minimum / Maximum MT Soil Density Tests on . Cid! ECW Piping Backfill ,~ '3 ' Material

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7'tj Two Immediate Action Letters (IAL) involvir,g IAL 6/22/79, 6/29/79 & ' fy stop-work were in effect or issued during the 12/31/79 s 1.j evaluation period in regard to placement of IAL 4/17/80, 6/10/80 & ?@p viQ safety-related concrete and ASME & AWS weld-7/17/80 f q%j ing. These stop-work orders, issued by the ~w licensee were a result of NRC's concerns in a4 J$$ regard te voids in the Unit 1 Reacter Contain-ment Building shell wall, qualification of welding procedures and improper welding activities. 2. NRC Action A special investigative effort conducted IE Report 50-498/499, over the period of November 10, 1979 to 79-19 February 7, 1980, concluded that procedural and programmatic inadequacies in the HL&P and B&R organizations resulted in failure to systematically identify quality prcblems ~ and failure to routinely correct and prevent recurrence of identified problems. Meetings were held with the licensee on 12/28/79 - Licensee Letter December 28, 1979 and January 24, 1980 to discuss the investigation findings. On April 30, 1980, the licensee was issued a -~ Civil Penalty and an Order to Show Cause. 2/7/80 - Licensec Letter-The licensee responded to the Notice of Violation. on May 23, 1980 and to the Order y to Show Cause on July 28, 1980. ( w

P ~ Subsequent inspections have monitored the 2/28/80 - Licensee Lets licensee's progress in the implementation of the corrective actions related to the May 23 4/30/80 - and July 28, 1980 responses. These inspec-Notice of Violation tions have revealed adequate corrective actions to date. 4/30/80 - Order to'Show- .f ./ As stated above, Region IV issued IALs on Ml~ c' June 22, 1979 and April 17, 1980 to confira l. actions planned and specify steps where < 1,' ;C : resumption of work would be subject to NRC approval. Letters of December 12, 1979 llE~'. - s f for the first IAL and June 10, and July 17, 1980 (. confirmed action: taken in the cases of the stop-(6'c,;, 3 work orders. p :., sh 3. Licensee Corrective Actions N All M 659 'O'$ 3 The licensee provided detailed corrective 5/23/80 - Licensee Let9 .. r@e;-4 actions in his responses of~May 23, and V) July 28, 1980. He also provided Region IV ~~' h.Q (,[;; on September 18, 1980 with a listing of 7/28/80 - Licensee Let9 1:nca ; SM,.y.( the comm.itments inclnded in his response with a schedule for ccmpletion and respons-

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MP11 t} ibilities for the comme ments by various 9/18/80 - Licensee LetQ =w ") members of his organizatiin. The licensee n 4.W designated contacts within the, HL&P organi-ThbJaySJ zation for the various areas to interface 11 with Region I'/ inspectors. m ar B. Contantion " Personnel training regarding Quality Assurance was-inadequate." It Gasis References i A special investigation conducted over the IE Report 50-498/492 ( period of November 10, 1979, to Febru ry 7, 79-19 1980, revealed that a lecture given by the E&R QA Manager on January 4, 1980, to B&R QA/QC personnel and construction personnel repeatedly overemphasized the B&R QA/QC crganization's responsibilities to minimize poject cost and maintain the construction i l m hedule. The lecture also emphasized that the B&R QC inspector's decisions l - ~ - ~ v ere subject to question, challenge, and uupervisory review and reversal. (. 2. .NRC Actions The NRC issued an qrder to show cause on 4/30/80 - Order to 5 j April 30, 1980, whicti included requirements

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.._..~. ~.y that the licensee destroy or revise a 'j videotape utilized in the January 4, 1980 lecture; republished a QA program brochure IE Reports 50-498/491 which reflects fundamental philosophies of 80-04, 80-18 10 CFR 50, Appendix B; and conduct new training on fundamental philosophies and 7/28/80 - Licensee Le9 standards of the QA program. . a(r 2 The licensee's July 28, 1980 response to the ' 1: order to show cause was reviewed and the pro-r;. L :.? posed corrective action was found acceptable. 42%'i W55 Subsequent NRC inspections have monitored .l$$$ licensee progress in implementution of corrective actiens related to the licensee response to the order to show cause. The licensee's corrective

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]'.NhW.!) action was acceptable. ~ p@MS'/h 3. Licensee Corrective Action

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,$jQG The licensee has rescinded the previous 7/28/80 - Licensee Le9 / Wis. QA program brochure and has removed the 2 ',DM video tape from the site. A new QA program My$d brochure has been published and issued to 5MN site personnel. Training seminars have been conducted ~on the cbjectives and standards of 97%iM@ fb the licensee and B&R QA programs. j 29 m L/$ M s. $$$;y.y C. Contention Peferences gg " Construction pressures thwarted Quality Control functions. There were threates, harassment and intimidation of Quality Control Inspectors and the 4/30/80 - Order to licensee (who was knowledgeable of these problems) Show Cause failed to take effective corrective action." 1. Basis Prior to Investigation 79-19 and the Order to IE Reports 50-498/ Show Cause, Region IV inspection and investi-

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/, gations documented several instances where QC 77-08; 78-09; 78-12 inspectors had been harassed, verbally and 78-13; 79-09, 79-14 physically abused, and had not been adequately supported by their QA/QC managers. Region IV i management met with HL&P Senior Management to ~ express concern that even though many allegations could not be substantiated low morale was evident because of perceived pressures by construction ~ workers and perceived lack of support when sub-jected to such pressures. (- l l l

- - = The Special Investigation, initiated November 10, 4/30/80 - Order to f, 1979, resulted because of multiple allegations Show Cause given to the Resident Reactor Inspector (RRI) on November 2, 1979. During this lengthy investi-IE Reports 50-498/49( gation,(November 10, 1979 - February 7, 1980) 79-19 the investigation team was able to substantiate that undue pressures were placed on QC personnel. The results of intervisws indicated that some civil r quality control inspectors were: (a) subjected to production pressures, (b) not always supported by the QC management, (c) harassed, (d) intimidated, and (e) threatened. ~ 2. NRC Action y. On April 30, 1980, the NRC issued IE Report 4/30/80 - Order 50-498/499, 79-19; a Notice of Violation, a to Show Cause. proposed civi1~penrity amounting to $100,000, ' {lS and an Order to Show Cause, requesting the IE Report 498/ R. l." licnesee show why work should not be stopped 499, 79-19 p p. 90 days from the date of the order. Region IV conducted a public meeting on August 19, Public Meeting ,c 1980 to discuss the licensee's rcaponse to the Transcript l M,: l Order to Show Cause. 1.W d.Rd JQ On August 20, 1980, a Region IV NRC Task Force IE Report WW G started a series of follow-up inspections. 50-498/499, ,.6% Follo<-up on. pressures, harassment, threats, 80-25 %k intimidations and lack of suppsrt was docu-mented in IE Report No. 80-25. In addition, l. the resident inspector has-had many informal L'M interviews with HL&P and B&R personnel during the last year and it appears that the perceived or real pressures, threats, harassment and intimi-dation have almost disappeared. 3. Licensee Corrective Action On December 28, 1979, about the midpoint of the 12/28/79 - special investigation, the team briefed HL&P of Licensee preliminary findings. As a result HL&P proposed Letter and implemented corrective action in a nine point plan. On January 24, 1980, the NRC Special Investigation 2/7/80 - Team held an exit interview with HL&P and B&R. As Licensee a result HL&P proposed and implemented a 13 point Letter Corrective Action Plan. The licensee took correc-tive action on their own initiative before receiving the investigation report, Order to Show Cause and the proposed civil penalty i \\

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-..__m.. ~ On Nay 23, 1980, the licensee provided a comprehensive response to IE Report 79-19, Appendix A violations. The corrective actions, proposed and subsequently implemented, brought the licensee into compliance. A On July 28, 1980, the licensee paid a $100,000 7/28/80 - Je civil penalty which had been proposed by the Licensee A ly.E the NRC and provided a very detailed and compre-Letter y: hensive response to the Order to Show Cause, ..Nh, Section V A(1)-(10). New seminars were held to "VV describe the QA prograti philosophies. The response d gave clearer direction and authority to stop work. N 4."2 These steps were aimed at taking the pressure off QC inspectors. g,pf.,gj m l.b $ iNps% M. On August 19, 1980, the licensee discussed his Transcript. ~ f response in a public sceeting in Bay City, Texas. of Meeting. gfgp"j Licensee acthn is complete on Contentions C. 9/28/80 - .e Licensee

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Letter e ,v. ni D. Contention y @;. ~Q d M "There were numerous instances of failure to follow procedures in the MI areas of docume'nt control, material storage..." Contentions with respect M@),ig

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to instances of failure to follow procedures in areas of " concrete place-2;., Wy ment" and " welding" are discussed in Contentions H and G, respectively." ipmg ggy,j 1. Basis References L,. _.4 p ~ 2.g There were several instances of failure to follow IE Reports 50-498/ procedures for document control. Examples

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include failure to maintain currect Pittsburg-79-13, 79-19 ~ Des Moines QA Menuals, failure to destroy or l stamp " void" a deleted B&R QA procedure, use . of ap expired interim change to an NDE procedure and B&R QA manuals did not contain the latest C'M Document Change Notices or interim changes. There were several instances of failure to follow IE Reports 50-498/ V proceudres for material storage which were identi-

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~ fied as unresolved items. Examples include 79-13, 79-22, 80-02 inaccurate storage and maintenance instructions, 80-10, 80-18 l inadequate protection of equipment from sand-blasting debris, inadequate level B storage facility, disconnection of electrical power to heaters in electrical motors and inadequate tagging and/or segregation of nonconforming ~ materials. Failure to provide protection for a weld preparation was identified as an item of noncompliance in IE Report 50-498/499, 80-07. l l L

2. NRC Actions Implementation of licensee corrective action IE Reports 50-498/ : relative to document control was monitored

499, during subsequent NRC inspections.

Licensee 80-06, 80-24, 80-25 corrective actions were acceptable. 81-06 11/2/79 - Licensee l I Letters ) 2/26/80 - n 5/23/80 - .M Implementation of licensee corrective actions IE Reports 50-498/, l-relative to material storage was monitored

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'y e;,. during subsequent NRC inspections. Licensee ' 80-35, 81-01, 81-06 correctve actions related to maintenance of 81-20

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required environmental conditions in storage 5/23/80 - Licensee [W-:.;f, areas were found to be inadequate and NRC Letters

%1 findings were escalated from classification as 4/13/81
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unresolved items to a Severity Level V violation 5/28/81 n ,A! ,F W in IE Report 50-498/499 81-01. Licensee corrective S actions related to the other material storage pro- . _ J. j blems were' found to be acceptable during subsequent di:$. :il j NRC inspections. .1 .1 .,,M4pl {. 3. Licensee Corrective Actions SiM b. m r... The licensee has taken corrective action 11/2/79 - Licensee Letter relative to document control including 2/26/80 - Licensee Letter revision of procedures, assignment of IE Reports 50-498/499,' additional personnel and increased sur-80-06, 80-24, 81-06 l veillance by QA. - The Jicensee committed to and has taken 5/23/80 - Licensee Letter corrective action relative to protection IE Reports 50-498/.459, of weld preparations including changes 80-35, 81-01, 81-06, 81-20 to procedures, increased surveillance by QA, and repair of the damaged weld pre-l pration. Unresolved items identified were not addressed in formal written responses; however, verbal discussions related to implementation of corrective action were held with members of the Region IV staff during site inspections. E. Contention " Audit and surveillance programs were improperly implemented." l

1. Basis References The special investigation team reviewed the HL&P 4/30/80 - Order to and B&R audit / surveillance program to verity Show (1) that the subject audits reviewed objective Cause evidence, (2) the audits assessed the effective-IE Report 50-498/491 ness of the QA Program, and (3) program noncon-79-19 formances were identified and corrected. The team found a weak audit and surveillance program: (1) HL&P and B&R management did not become suffi-h.,.,q cently involved when audit deficiencies / noncon- -a j formances were not corrected, (2) neither HL&P ..',[ nor B&R performed supplemental audits despite the 3p; n fact that allegations continued from mid-1977 through 1979 regarding civil activities and despite the fact that significant structural $2..h; CQ(!, deficiencies, large voids in the Unit 1 containment shell, were evident in early 1978. The voiding was ]$Ep,Ef still occurring in late 1979, (3) HL&P and B&R $fM f.cr.3 audits were mainly a paper review with little or Mjnyj no attempt to relate records to work results, (4) B&R construction was not audited in 1977, 1978, W and 1979, and (5) HL&P surveillances were ineffective.

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d. ',5;Q The NRC Resident Reactor Inspector (RRI) identi-IE Report 50-498/4s M :.

o fied continuing audit program problems during the 80-18

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j July 1980 inspection period. Senior Management was W<;22M still not sufficiently involved with the audit-Vt process to assure resolution of impasses regarding NO $$hM audit findings and timely corrective action. hw m k, '.' l 2. NRC Action

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Following the special investigation findings IE Report 50-498/G described in paragraph 1 above, the NRC issued 79-19 a report which contained violations, a proposed 4/30/80 - Order ts civjl pena.ty. and an Order to Show Cause Show Cause and i Civil Penalty. L H L Commitments to improve the audit program were Transcript of discussed with the licensee and contractor during meeting the public meeting held on August 19, 1980. All noncompliances, described in Appendix A of IE Reports 50-493 Report 79-19 and 80-18 have been corrected. NRC 80-18, 80-25 l follow-up inspection relative to audit deficiencies i began in July 1980. Additional deficiencies found during follow-up inspections have been identified and corrected. ~ l The NRC followed up and verified that licensee l commitments described in the HL&P letter, dated { September 18, 1980, were implemented.

l. 3. Licensee Corrective Action The licensee took corrective action in response 12/28/79 - Licensee to a management meeting in December 28, 1979, Letter described in a Nine Point Plan documented after 2/7/80 - Licensee the meeting. Further corrective action was taken Letter as documented in a Thirteen Point Plan immediately after the NRC exit interview on January 24, 1980. i. On May 23, 1980, the licensee officially responded IE Reports 50-498/ ~ to special Investigation Report 79-19 and described

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,i t their corrective action taken or to be takne rela-80-18, 80-25 Y tive to Appendix A, Items 14, 18, and 19. i s On July 28, 1980, the licensee responded to the 7/28/80 - Licensee l Order to Show Cause, Section V.A.(9). A public-Letter ..>3 meeting was held to discuss this response on Public Meeting 6K,i August 19, 1980. Transcript O @C b b' On October 23, 1980, the licensee responded.to an IE Reports 50-498/ item of noncompliance written because corrective

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[. M dN. action relative to 79-19 was not adequate. 80-18, 80-25 f... i~h/] On September 18, 1980, the licensee summarized IE Reports 50-498/41 ,1 commitments made to the NRC. The RRI inspector 80-27, 81-04, 81-07,- l t cW has followe'd up on each commitment to assure 81-12, 81-23 proper implementation. j G j{ F. Contention W UA ! %4 "The licensee had a breakdown in the implementation of the Quality Assurance program and management-controls for safety-related... welding." The contention of breakdown in implementation of the QA program and mangement controls for safety related concrete powers is discussed in contention G. 1. -Basi s. References There were several breakdowns in the imple-IE Report 50-498/49s mentation of the QA program and management 79-19 controls for safety-related welding activities. Examples include: welding being performed without adequate protection from the atmos-pheric conditions; improper radiographic techniques; improper interpretation of radio-graphic and liquid penetrant examination results for weld quality; and design changes to welding requirements without proper review and approval. 2. NRC Actions A special investigation was conducted between IE Report 50-498/493 November 10, 1979 and February 7, 1980, regarding 79-19 ( alleged intimidation of quality control inspectors 4/30/80 - NRC Lettet and to assess the effectiveriess of'the QA/QC 7/28/80 - Licensee ~ ~ Letter

( program for ongoing activities. On April 30, IE Report 50-498/' ( 1980, the licensee was issued a Civil Penalty 80-24, 80-28, 80-for the NRC identified items of noncompliance 80-35, 80-36, 80-and an Order to Show Cause why safety-related 81-03, 81-06, 81-a construction activities should not be stopped. 81-14, 81-21. The licensee's July 28, 1980 response to the SCD Order to Show Cause was reviewed and the pro-posed actions to correct the welding problems ,1-f.i;[, l,- have been found acceptable. s, O f@..N Subsequent inspections have monitored licensee W-progress in implementation of corrective actions g, ;)g. related to the Order to Show Cause response. f. c, ngl-3. Licensee Corrective Action r,9. y 'f7 N " In response to the NRC Order to Show Cause, the 10/3/80-NRCLet] N.'d' 4,i licensee committed to an extensive re examination 11/21/80 - NRC Lev " ?' ' i program to establish the adequacy of the existing gj,.., q welds and a gradual re-start of safety-related " c z.u' NL welding on a controlled basis. The re-examination / #'M program and gradual restart was initiated on g October 6, 1980 and is ongoing. h.N G. Contention m.wed

p MWi cgp#1 "The licensee mangement had a breakdown in the implementation of the M6d

$gg Q ^ quality assurance program and managgment controls for safety related concrete pours....." . n.v .,y n ',1 1. Basis References There were voids discovered behind the liner IE Reports 50-493 ,~ plate in the Unit 1 Reactor Containment Build-

499, ing wall in concrete lifts no. 8 and 15. On 78-16,79-04,79j October 20, 1978, the licensee notified Region 79-12, 80-06, 80-IV of the existence of voids in the concrete in

., '. F '. n,: lift 15 of the Unit 1 RCB. The deficiency was b,,, ' ' ]- reported to have been caused by the compounded effects o_f inadequate planning, an unusually long placement time, longer than normal. pump discharge lines and concrete pump breakdown. l. In addition, the procedural provisions for stopping of work due to problems were not exercised by construction or quality control. On June 18, 1979, the licensee reported voids in the concrete lift of the Unit 1 RCB. These l ~ voids were discovered during the amplified investi-gation of the remaining concrete lifts of both units. These voids occurred beneath penetrations gnd beneath liner plate stiffeners. ( . -,. ~

.m.. / 2. NRC Actions p Following the October 20, 1978 and June 18, 1979 6/22/79 - NRC notifications, discussed in 1 above, the NRC Letter issued an IAL on Juae 22, 1979 to confirm actions IE Report 50-498/ taken or planned to be takne by the licensee. A 499, 79-19 special inspection was conducted between 4/30/80 - NRC Letter November 10, 1979 and February 7, 1980 which in part addressed management and procedural controls in the area of concrete placement. As a result of this inspection, an item of violation was identified, " Failure to Correct Inadequate Concrete Practices." On April 30, 1980, the licensee was issued a Civil Penalty and a Show Cause Order requiring a review of safety-related concrete structures to determine whether previous concrete ' work was properly performed. The licensee's o ' r. ;; July 28, 1980 response to the Show Cause Order and u,e - 4 their May 23, 1980 response to the violations were reviewed and the licensee's actions and proposed f c; actions to correct the problem have been found W 'l acceptable. 4; g Subsequent inspections have monitored licensee ': ~ S progress in implementation of the corrective actions

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related to the placement of concrete in safety 3 fj -:g c related structures. =.4

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gj 3. Licensee Corrective Actions .:n i27 The licensee has taken specific corrective IE Rpts. 50-498/499, actions in response to the' identified viola-81-16, 81-22 tion and the Show Cause Order. Construction and inspection procedures and necessary engineering design documents have been revised to reflect the recommendations contained in the report,of the. deficiencies. The repairs to restore the concrete shell to its originally designed structural integrity have been completed. The repair methods used were thoroughly tested and analyzed prior to their use and after the repairs were complete. H. Contention " Extensive NRC investigation of licensee activiti.es resulted in numerous items of noncompliance, escalated enforcement, frequent mangement contacts, and an NRC show cause order to assure compliance with NRC requirements." g (See Contention A, NRC Action) s

o I. Contention " Incremental resumption of safety related concrete placement and welding has been subject to the approval of the NRC." (See Contention A, NRC Action) m O e e '?: y? I I O t 7 y ,y7 7

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^~^ ^ Washington Nuclear Pro.iect No. 2 Evaluation Period: (4/1/79-4/1/80) I. General .T,. ,-[. On June 17, 1980, NRC issued a 10CFR50.54(f) inquiry on quality assurance, simultaneous with a notice of violation and $61,000 1.A M',. civil penalty, as a result of serious deficiencies in the sacrificial t S,.~% J '.} shield wall, pipe whip restraints, and other construction deficiencies. The 10CFR50.54(f) inquiry required the licensee to provide information (f. on the steps to be taken to provide reasonable assurance that the L. g;:e f,, approved quality' assurance program has been implemented and the W r;~ < steps to be taken to strengthen management control of the project. 1 -Qi..;B On July 17, 1980, the licensee responded to these enforcement I ;9;yh ? t actions by halting work by the prime mechanical contractor. The i.? Oj M iffj licensee also stopped work by all site contractors pending an g y pj evaluation of their detailed work methods to assure that there would be no quality problems upon their return to work. The following hM~ * 'm w, nine months were spent on the planning, mobilization, and operation wr G W; ff) of three task forces to implement the corrective acticns outlined hMf.f } in the response to the 10CFR50.54(f) inquiry and notice of violation. d aq k-@Md Task Force I.was established to expedite resolution of the outstanding 2x @n problem backlog at WNP-2. The task force performed an initial MAT m review of outstanding problem areas which resulted in recommendations Sl to improve controls over backlogs and short term goals for reduction g-o_2%. of backlogs. These recommendations.were assembled into an action e [M g-mNNIE, plan for implementation which is essentially complete. g T~

i. 4 Task Force II consisted of a restart plan to ensure that contractor quality controls were effective and that any resumption of work P

would have minimal risk of quality problems and would not preclude reinspection of completed work. These efforts were essentially completed by the end of March, 1981 with most contractors released to start work.. Task Force II also consists of a program to reverify e ~ } the adequacy of completed safety-related work. Detailed plans for accomplishing this activity are being formulated. 5 i Task Force III was established to disseminate the lessons learned

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at WNP-2 to other licensee projects and to review and evaluate the management systems of site organizations, including site contractors. These efforts are continuing. Following the appointment of Mr. R. L. Ferguson as Managing Director in June,1980, substantial Supply System and WNP-2 organizational changes were announced. These changes include the establishment of a site-based Program Director for WNP-2 who is responsible for the ~~~ construction, startup, and initial power generation of the facility. f Other actions inclucid a change in the reporting relationship of the WNP-2-Project Quality Assurance Manager from the Corporate C-Quality Assurance Director to the WNP-2 Program Director and the . establishment.af a new Coyporate Directorate of Nuclear Safety. W [ 0%M3Ck

h< In March, 1981, it was announced that Bechtel Power Corporation would assume the function of Construction Manager, including Quality v Assurance, effective June 1, 1981. Bechtel is also functioning as systems completion contractor and will perform the reverification of completed safety-related work. As systems completion contractor, Bechtel may be assigned responsibility for completion of a contractor's work package. This provides a clear alternative to a contractor whose performance may be unacceptable. The integrated WPPSS/ Burns and Roe, Inc. organization has been ~~ abolished with Burns and Roe retaining the function of Architect- ' i Engineer. The licensee is now performing quality assurance overview. The licensee has also withdrawn from' direct involvement in engineering activities specific to the project, assigning these functions to I. the Architect-Engineer. The Architect-Engineer moved more engineering q - _ functions and personnel to the site and opened an office in the nearby town of Richland. This supports evaluation and disposition Rd of engineering questions relating to deficiencies found during the 7 G reviews of detailed work methods and backlogs of nonconformance ?~M documents. .E:p II. Specific Y Nj A. Contention ,j v.

'E.y The tacility disp' layed evidence of weakness in the area of " quality A2 EA assurance (including management and training)."
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Basis' M-j.k. ':- u Thirty-three items of noncompliance were identified during the L appraisal period, representing a significant increase from previous years. In terms of inspection manhours per noncompliance, the enforcement history indicated a deterioration in licensee performance. For the first half of 1980, the noncompliance rate was 21 inspection manhours per noncompliance, compared g 51 hours / noncompliance in 1979 and 142 hours / noncompliance in 1978. All of the current items of noncompliance related to work performed by the licensee's contractors. ThispegrmancetrenddevelopeddespiteanNRCEnforcementConference in 1978 and subsequent manageme 39eetings in 1979 which addressed 1ess than satisfactory performance Of the 33 items of noncompliance identified during the current appraisal period, five were repetitious of previous NRC findings, indicating a weakness in the licensee's ability to effect lasting resolutions to quality concerns. Sixteen of the items of noncompliance involved work which was performed during the 1976 to 1978 time frame, raising questions about the effectiveness of the licensee's quality assurance program during that time. i l ~ While two of the items of noncompliance related specifically to inadequate qualification of personnel, the repetitive l nature of some findings, and the more general deficiency of poor procedure implementation indicated a weakness in the / licensee's emp,loyee traini7g and indoctrination program. 9

[, In summary, the significant incease in the number of items of \\. noncompliance, including the repetition of five items of noncompliance, disclosed ineffective quality assurance program implementation with inadequate control of contractor's ar.tivities. A below average rating was, therefore, assigned to the area of V: quality assurance. ,. :W O. 2. NRC Actions ~ ~^ - NRC actions during the appraisal period included a management ' ~ 7E meeting in April 1979 reiterating NRC concerns with the lack ~ Rd of effectiveness of the licensee's quality assurance program (concerns which were previously expressed in an Enforcement 1'. w ,2.@:d Conference in May 1978). i ( lj,g Other actions included a major investigation relating to the pipe whip restraints. g of the sacrificial shield wall and fabrication and erect Two "Immediate Action Letters" were Qf. S,@.3$ issued in November 1979, effectively stopping further construction Jf?$2d activities in those two areas pending NRC veri.fication that AWT effective control measures were implemented for correction and [N.jf repairs. h Based upon the results of the above investigation and the ,4 'C~#T2id $61,000)sasleviedonthelicensee.galty(intheamountof routine inspection program, a Civil In addition, a 50.54(f)

7-r@y 5%

request was issued to obtain further information regarding the .k t M adequacy of previously completed work and whethgcurrent an1 3 %1 future work is (will be) adequately controlled. The NRC

Mgh also assigned a resident construction inspector to the WNP-2 site to monitor licensee corrective actions.

q N' 3. Licensee Actions The licensee has undertaken major organizational and personnel changes in addition to the development of a new quality assurance program. The organizational and personnel changes included the assignment of a new Managing Director, and a project completion contractor (Bechtel). The new quality assurance program is currently under NRC review. This program includes additional management actions to assess the acceptability of previously completed work; examigion of work procedures; and .panded training requirments. B. Contention The facility displayed weakness in the area of " safety-related structures." 1. Basis Du, ring the appraisal period, eight items of noncompliance were . ( thereactorvesselsacrificialshieldwall).gs(primarily issued which relate to safety-related struct The most y 9 _. _.-----,e ..._..m. ..-.,,_y .,_m m-

4% r significant noncompliance related to the failure to properly ( weld the sacrificial shield wall together, a condition which (if it had gone undetected) would have left the structure accidentconditions.gngtheshearforcespostulatedduring incapable of withsta Other items included work on strt.ctures without qualified procedures, failure to qualify inspection personnel, and failure to maintain adequate records.(4) y f, 3 2. NRC Actions n ',: I NRC actions are summarized under item A.2. above. In addition,

c,. ~

the NRC perfntmed a detailed technical review of the licensee's assessment of the structural adequacy of the sacrificial ~, shield wall as well as the licensee's proposed repair program.(8) ~ C-3. Licensee Actions t

m i

[N In addition to the programmatic corrective actions discussed

"1 in A.3 above, the licensee has performed:

a 100% reinspection !, 2.h of all accessible surfaces of the sacrificial shield wall;

_ 7?" '

extensive technical analysis of the defects and wall integrity; and a thorough examination of all records related to the erection and inspection of the structure. q 3P.WN . JrT i C. Contention e a y$ ) $j% g".} The facility displayed weakness in the. area of " piping and pipe q 26 supports." EMSM 1. Basis ' S.h.w I Q. Duringtheappraisalperio'd,fourteenitemsg)ncncompliancewere issued relating to piping and pipe supports. Major deficiencies i-were identified in pipe whip restraints used inside the containment to minimize the detrimental effect of a major brer' in a steam line or other pipe. Analogous to the problems identified with the sacrifical shield wall, the NRC noncompliances pertained to: work ~ ontherestraintswithoutqualifiedprocedures;failuretoquagy ^l inspection personnel and failure to maintain adequate records. Other noncompliances issued during the appraisal period included: waterpipewelds;g)postweldheattreatmentofmainsteam improper control of pipe supports and attachments to pipe The subject of inadequate' controloverpipesupporterectionandinspecti[IO3[ggitieswasthe basis for nine previous items of noncompliance, i 2. NRC Actions In reference to the piping post weld heat treatment problems, ~ the NRC retained an independent consultant who performed metallographic tests on pipe welds to determine the acceptability of the hardware. It was concluded that, for those welds ( examined, the improg heat treat controls did not result in l damage to the pipe.... The licensee's performance in the area l

^^ ~ ofpipingandpipesug3rtswasaddregdinmanagementmeetings(1) 9 and the Civil Penalty and 50.54(f) correspondence. Licensee corrective actions are being monitored by the NRC Resident Inspector at the site. 3. Licensee Actions 7~.g The licensee has committed to perform further investigations .g'h and technical analyses to verify the adequacy of the post weld t. heat treatment procedure used. . - Q:'.M w- ~ 1.M Other reviews and analyses are underway to address the problems 1 related to pipe whip restraints and pipe supports. Deficiencies h[.c,:.; 7:L; -1 in pipe whip restraints have been identified by nondestructive testing and the licensee is evaluating the feasibility of Rfi,g,.d*.2 onsite repair of these deficiencies. The reverification y gg program will include detailed reinspections of pipe supports and restraints. ,.gg +::.e m D. Contention 4p-] ':'Ht, ']j.:j Weaknesses were identified in the area of " electrical equipment." [Mh 1. Basis L fd.d Q Licensee weaknesses in the area of electrical equipment contributed MW 7 A;,h; j-(M to three items of noncompliance during the appraisal period; failure to properly install emergency battery these g : OS.? t breakers,gproper identification of safety-related circuit P%j}.'}, g~. racks; andtheinstallationofnonqualityeggI instrumentation into the reactor protection system 2. NRC Action The NRC has monitored the licensee's actions taken in response to the specific items of noncompliance. These actions are l sti11 in progress so that a final assessment in this area has ~ not been reached. ~~ l. 3. Licensee Action The licensee has initiated actions to properly resolve the '~ ~ ' items of noncompliance including proper identification of safety-related circuit breakers; procurement of new battery racks; and verification that the requisite quality characteristics have been specified for reactor protective system instrumentation. l The Architect-Engineer has increased the size of the onsite electrical. engineering organization which is now reviewing and rewriting FSAR Chapters 7 and 8 and evaluating the degree of compliance with regulatory requirements. E. Contention- . Weaknesses were identified,ir) the area of " electrical cabling (trays \\ and wires)."

..=. -

e. 1. Basis While only one item of noncompliance relating to electrical cable installation was identified during the appraisal period (cable identification coding), a significant item of concern relating to electrical cable separation has remained unresolved. In 1978 and 1979, the NRC expressed concern to the licensee about the lack of definition {g4gg)1icensee'srequirementsforelectricalcable separation. From the NRC perspective, it was not assured that final cable installations would be in accordance with industry

v..

standards (IEEE-384) and the NRC Regulatory Guide (RG-1.75). During V the appraisal period, it was determined that installed cabling was not in full accordance with these documents. The technical accept-y ability of the as installed configurations has not been finally determined. l:,,, NRC Actions

x. d '

C 2. %, ' i. N' E" 3.'i The NRC verified proper resolution of the incorrect cable 1.; identification coding. The Office of Nuclear Reactor Regygtion $pj has reviewed the licensee's proposed separation criga f-and has taken exception to several of the criteria.

.y -

.m 3. Licensee Action !$.hl! The licensee has properly resolved the item of noncompliance h.rA involving cable identification coding. A revised separation WNHM ? criteria has been developed and submitted to the NRC as a part EE?M PisiM1 of their FSAR. As indicated abase, the NRC Office of Nuclear MAiMWN Reactor Regulation has taken exception to some areas of the nWy-{.j revised separation criteria. The licensee is now evaluating .f.gs these exceptions to determine their degree of compliance to i ~ N ". the NRC position. r F. Contention Weaknesses were. identified in the area of " instrumentation." 2 .i 1. Basis During the appraisal period, six items of noncompliance relating to instrumentation were identified. Four of these items were S repetitive items of noncompliance involving the failure to maintain cleanliness of instrumentation tubing and piping. j The remaining items involved welding and inspection of instrumentation piping. 2. NRC Actions Therepetitivenaturgygfthenoncomplianceswgg)discussedin(6) management meetings, and the Civil Penalty and 50.54(f) correspondence. Correction of the specific items of noncompliance is being monitored by the NRC staff. l ( l

_ ___ u. r -.. _. : & s. ~ 3. Licensee Actions The licensee's response to the items of noncompliance and the 50.54(f) letter included actions to ensure that procedures adequately reflect the requirements of applicable codes and standards and that contractor personnel are adequately trained to these procedures. The restart of work by the instrument contractor has been accompanied by heightened quality assurance surveillance. Protection has been provided for instruments and startup personnel have been instructed in the maintenance of instrument system cleanliness.

5... a; s

} G. Contention "The area of quality assurance was characterized by ineffective program g(- , implementation and inadequate control of contractor activities." w.~ jth (See Contention A) EkH [NN H. Contention

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,.'xd?tl. c; "There were numerous items of noncompliance involving procedure and drawing .ww.j adherence, control of special processes (welding and NDE), and maintenance ggg of quality assurance records." 3.p:~ Q,Q (See Contentions'B and C) f W>,)g c. ww I. Contention khj "The licensee had extensive difficulties in installation of safety-related pipe whip restraints, and in the erection and welding of the sacrificial .n. t.7y shield wall." (See Contention C regarding pipe whip restraint problems and Contention B regarding erection and welding of the sacrificial shield wall problems) J. Contention, " Licensee sutimittals to NRR displayed technical weaknesses and the licensee was not responsive to NRC technical requests on various occasions." 1. Basis The staff rejected in June 1977, the PSAR which was tendered in March 1977 partially on the basis that Chapter 7 was unacceptable. Specifically, this section was completely outdated and did not reflect the as-built plant or licensing progress on similar plants (LaSalle,Zimmer). FSAR was retendered (3/78) and docketed in June 1978 with deficiencies still in Chapter 7. Prior to the NRC action (see below), it appeared that the applicant had given inadequate in-house manpower to the I&C (Chapter 7) material supplied by the NSSS, which was not current.

2. MRC Action First, NRR requested that the more deficient portions of the FSAR be rewritten to conform to Reg. Guide 1.70 and the SRP. Next, we requested that WPPSS conform its application to the guidance / examples provided by responses of other applicants to staff questions and positions and to conclusions in our SERs. Finally, we requested that where practicable, resolutions developed by other OL applicants for similar facilities be applied. We trans-mitted these requests to WPPSS in our letter of March 28, 1979. 3. Licensee Corrective Action In response to the staff's requests, the applicant submitted or completely revised Chapter 7 in July 1980. Additionally, the applicant hired more technically qualified people and assigned them to the task of implementing both the spirit and the letter of the staff's requests on this matter. This included signifi-cant hardware changes in the plant to conform to the appropriate IEEE standards and the staff requirements on similar plants. As a result of the firm action by NRR in the I&C review at the beginning of this evaluation period, the licensee took actions in this period which corrected most of the serious deficiencies slightly after the end of this evaluation period. O t mW l = = = t

.. ~. References (1) USNRC RV WNP-2 SALP Rpt No. 50-397/80-11 (2) USNRC RV WPPSS Enforcement Conferences Rpts 50-397/78-04; 78-06 (3) USNRC RV WNP-2 Inspection Rpt 50-397/79-08 (4) USNRC RV WNP-2 Investigation Rpt 50-397/80-04 (5) USNRC (Stello) to WPPSS ltr of 6/17/80 - Civil Penalty (6) USNRC (Stello) to WPPSS ltr of 6/17/80 - 50.54(f) Request for Info. (7) WPPSS ltr No. G02-80-153 to NRC (Stello) of 7/17/80 Response to 50.54(f) Request for Info. (8) USNRC RV to WPPSS ltr of 1/20/81 - Work Release - Sacrificial Shield Wall ~ (9) USNRC RV WNP-2 Inspection Rpt 50-397/79-10 (10) USNRC RV WNP-2 Inspection Rpt 50-397/77-07 .h (11) USNRC RV WNP-2 Inspection Rpt 50-397/78-03 (12) USNRC RV WNP-2 Inspection Rpt 50-397/79-04 (13) USNRC RV WNP-2 Inspection Rpt 50-397/79-16 (14) USNRC RV WNP-2 Inspection Rpt 50-397/78-10 (15) USNRC RV WNP-2 Inspection Rpts 50-397/79-04; 79-09; 79-16 (16) OIE:RV to IE:HQ ltr of 4/29/80 - WNP-2 Cable Separation (17) USNRC: NRR to WPPSS ltr of 5/4/81 - WNP-2 Cable Separation e 4}}

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