ML20078P474
| ML20078P474 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/07/1982 |
| From: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | |
| Shared Package | |
| ML20078P458 | List: |
| References | |
| NUDOCS 8311080071 | |
| Download: ML20078P474 (173) | |
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'[] SEABROOK STATION H REPORT OF A q
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SELF-INITIATED CONSTRUCTION PROJECT EVALUATION n
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.T:rst.it m mm L M U PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE l
- J SEABROOK, NEW HAMPSHIRE a
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a i U PUE5LIC SERVICE *"
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Companyof NewHampshre 1671 Worormw Rood Framinchom. Massachusetts 01701
.; (617) - 872 8100 J
Deceraber 7,1982
~l SB - 14696
.! T.S. A.10.8.99 l .
Mr. David G. Smith
_ Institute of Nuclear Power Operations 1820 Water Place d Atlanta, Georgia 30339 7
Dear Mr. Smith:
I
,s Construction Project Evaluation j
" Enclosed for your information and review are two copies of the Report of a Self-Initiated Construction Project Evaluation for the Seabrook 1
Station. Also enclosed is one copy of the Observations prepared by assessment team members, documenting pertinent facts observed during a the course of the evaluation. The Observations are for your infor-mation only, and are not considered part of the Construction Project Evaluation Report.
We propose to submit the report to the NRC for their information following your review and/or by the end of the year.
a If you have any questions on the Report, feel free to call A. M. Shepard at (617) 872-8100, Extension 2230.
7 y Very truly yours, a
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-: . , OL Arthur M. Shepard D rector of Quality Assurance a R . .V ~
, JohnDeVincentis( ~ /
Project Manager (
AMS/aed Enclosure \
cc: W. P. Johnson J. H. Herrin A. M. Shepard D. G. McLain '
B. B. Beckley D. E. Moody R. P. Pizzuti G. S. Thomas A. M. Ebner 9
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SEABROOK STATION 7
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, REPORT OF A SELF-INITIATED
! CONSTRtITIGN PROJECT EVALUATION a
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.O PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE e
SEABROOK, Nth HAMPSHIRE
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TABLE OF CONTENTS
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.J I. INTRODtrTIGN 1 t
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- II. PtRPOSE 2 i
III. SCOPE 2
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IV. SlM GRY 3 i
U V. RESULTS 4
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CA - Organization & Acministration 8- 17 OC - Design Control 18 - 60
, CC - Construction Control 61 - 103 (3 PS - Project Support 104 - 123 TN - Training 124 - 138
, QP - Quality Programs 139 - 156
.c TC - Test Control 157 - 169 fl .
VI. REFERENCES
~l A. Performance ODjectives & Criteria For Construction j Project Evaluations (cevelopec by INPO)
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- 1. INTROD(ETIUN Tnis report presents the results of a scif-initiated evaluation of the
.m engineering and construction activities relateo to the Seabrook Station, Units 1 & 2 (DN's 50-443 & 50-444), conductec during the q period October 25 thru Novemoer 5, 1982.
I' The evaluatton was accomplisnea by the station's principal owner, the
._, Public Service Company of New Hampshire, and the Yankee Atomic Electric
. Company, acting as agent for the owner, in a joint-venture arrangement with Nortneast Utilities (Millstone III). The evaluation team was incepencent of the project and was comprised of 15 senior technical anc
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management personnel from Northeast Utilities and Stone & Webster
_l Engineering Corporation. Team coordination was provided by two senior engineering personnel from Wited Engineers & Constructors, Inc. who
.<. took no airect part in tne evaluation process.
The station is locatec in Seabrook, New Hampsnire, approximately 40 miles nortn of Boston, Massachusetts. Both units employ a four-loop 1,198 Mme Westingnouse pressurized water reactor. Plant construction
_3 for Unit 1 ano common facilities is approximately 76% complete; Unit 2 is approximately 20% complete. Fuel loao for Unit 1 is presently seneouleo for Novemoer, 1983. Principal parties associateo with the project are:
Principal Owner / Licensee -
Public Service Company of New
,' l Hampshire (PSNH)
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Agent of Licensee -
Yankee Atomic Electric Company
'] (YAEC)
Arenitect-Engineer -
(Alted Engineers & Constructors Inc.
(UE&C)
Construction Manager - trited Engineers & Constructors Inc.
., (UE&C) a The nigh standards contained in the Performance Objectives and Criteria for Construction Project Evaluations developea oy the Institute of n toclear Power Operations (ItPO) were usea as a basis for the ,
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evaluation, altnough not to the exclusion of any other pertinent I industry stancard or g000 practice. The stancards set hign levels of I
, , , excellence in the performance of the work, often in excess of those l
! necessary to meet minimum requirements, and this philosopny was enoorseo curing the evaluation. Accordingly, areas of weakness (Findings) 10entified as a result of the evaluation are not necessarily inaicative of unsatisfactory performance.
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II. PURPOSE The purpose of tne evaluation was to assess tne project's performance In achieving and maintaining nign stancaras of excellence in the
^ control of engineering and construction activities and to identify ano institute appropriate action relating to any areas of weakness. It was also the purpose of the evaluation to recognize good practices, those areas of exemplary performance, or where tne project institutea a
,, particularly effective or unique method to perform the work. From a broaoer viewpoint, tne evaluation shoula contribute towarcs acnieving ano maintaining tne nign stancaros of quality required by the nuclear inaustry.
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III. SCOPE
) Tne scope of tne evaluation (except for areas listed celow) inclucea all aspects of the project - from licensing commitment thru engineering implementation, construction, ana test and startup. Tne evaluation was performance-oriented, witn considerable empnasis placed upon an assessment of whetner appropriate procedures haa Deen developea to control tne engineering and construction activities, whether tne n procedures were ceing properly implemented, and whether they were
- effective in assuring a finished product of nign quality built in accoraance witn tne cesign documents.
The following were not evaluatea:
A. Tne acequacy of the construction facilities ano equipment (INPO CC.2) because all such facilities were already in place and ao
,; not affect tne safety or licensability of the station.
, B. Incustrial Safety (INPO PS.1) was not specifically addressed since it aces affect the safety or licensability of the station.
Attachment A presents in greater cetail the scope of the evaluation and i ioentifies the organizations evaluated for eacn Performance 00jective.
The evaluation team spent two weeks (1,000 MH) preparing for tne evaluation by reviewing pertinent project and contractor work 4
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procecures, licensing occuments, tne organizational structure ano otner relevant cata, ano preparing aetailed work plans ano an overall scheaule. In accition, training in the evaluation techniques was provicea by the team coorainators. Two (2) weeks (approximately 1,400 s- MH) were spent actually conaucting the evaluation. .
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IV.
SUMMARY
I Based on tnis evaluation, from an overall stanapoint the engineering J ano construction activities are ceing satisfactorily contro11ea and tne stancaros contained in tne referenceo Performance Ob,)ectives are ceing
'I achieved. However, several specific aspects of the project shoula be
,, strengtneneo. These primarily relate to:
- r, A. The Piping Contractor's activities - the most significant area of
,j weakness ioentified curing the evaluation.
B. The implementation and/or content of several project procedures.
1 ij C. A recomencation to implement or expand job-specific, non-mancatory training.
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- j D. Senecule considerations relating to cesign verification programs.
. _ , The concerns with the performarce of the' Piping Contractor had been recognizec by the project prior to this evaluation, and were also
- 2 inaicateo in tne NRC CAT Inspection #50-443/82-06 performed in June, 1982. The areas of weaknesses iaentified by this evaluation reinforce
['s the need for the project to continue to monitor closely work performea
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by tnis contractor and to consider otner remedial actions tnat woula prove effective in improving work quality ano schedule performance.
ln Areas of weakness relate to control of occuments, including cesign
i cnanges, work planning and supervision, craft training, and quality control. These concerns are accressea under the Construction Control
. ano Project Support sections of the report.
d Several oesign guioelines for component supports snould be upgraded to account more thorougnly or clearly for certain specific loaa pi applications, ano consiceration should be given to ceveloping otners to
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improve the control of several aesign change and interface activities.
These concerns are accressea under the Design Control sections cf the '
... report.
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iJ wnile tne requirements of mandatory training, principally QA relatea,
(. are being satisfactorily acnieved, more specific jou-related training 4' is recommended. This recommendation applies to both craft personnel at u the site to improve job skills and productivity and at the A-E office where reinforcement of several work procedures should promote broacer y understancing and more uniform compliance. These concerns ana h recommenaations are aiscussed under the Training section of the report.
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The various oesign verification programs plannea or underway on the project will upgrace tne confidence in the design of the plant. l L However, it is recommenced that relatec schedules be integrated with '
l the overall project scheoule and an assessment maae of the potential H '. impact on plant oesign ano construction to assure a timely completion ano a cost-effective progression of the work.
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V. RESULTS
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Conclusions basea on information oeveloped curing this evaluation, together with specific areas of weakness and Good Practices (Finaings),
if any, and/or recommencations are presentea in the report for each
' INPO Performance Objective. The " Detail" sheet (s) for eacn objective present a broader cescription of the Finding followed by other pertinent facts resulting from the evaluation.
Consistent with tne project policy for similar evaluations and audits, each area of weakness will be evaluated for 10CFR50.55e and Part 21 implications ano reported to tne NRC in accoraance with establisnea
-, proceoures.
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ATTACHMENT A rS ORGANIZATION EVALUATED f ARCHITECT / SITE ORGAN- OWNER'S ENGINEER IZATIONS AGENT OWNER r,
INPO PERFORMANCE OBJECTIVE (UE&C) (SITE) (YAEC OFFICES) (PSNH)
,, Organization & Aaministration
- OA.1 Organization Structure X X X X l
'3 OA.2 Management Involvement X X X X
& Commitment d OA.3 Role of First-Line Super- X X X visors & Miocle Managers Design Control DC.1 Design Inputs X X
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,. DC.2 Design Interfaces X X 1r3
'j DC.3 Design Process X X
- DC.4 Design Outputs X X 1
d DC.5 Design Cnanges X X n
- Construction Control p CC.1 Construction Engineering X
.i CC.2 Construction Facilities
.-. & Equipment CC.3 Material Control X (including off-site storage facilities) b CC.4 Control of Construction X (incluoing second shift work) ,
Process l I CC.5 Construction Quality X Inspections
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ATTACHMENT A ORGANIZATION EVALUATED l ARCHITECT / SITE ORGAN- OWNER'S J
ENGINEER IZATIONS AGENT OWNER INPO PERFORMANCE OBJECTIVE (UE&C) (SITE) (YAEC OFFICES)
.. (PSNH) l Construction Control (cont'd). :
} CC.6 Construction Corrective X Actions
) CC.7 Test Equipment Control X b
Project Support A
PS.1 Inoustrial Safety PS.2 Project Planning X X X X PS.3 Project Control X
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,j PS.A Project Procurement X X Process t PS.5 Contract Administration X X PS.6 Document Management X X i
>J Training
'g TN.1 Training Management X X X Support l TN.2 Training Organization X X X s
& Aaministration TN.3 General Training & X X X Qualification
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TN.4 Training Facilities, X X X Equipment, & Material
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4 ATTACHMENT A D
L ORGANIZATION EVALUATED m
i ARCHITECT / SITE ORGAN- OWNER'S ENGINEER IZATIONS AGENT OWNER
-, INPO PEF ORMAN'E C8.JECTIVE (UE&C) (SITE) (YAEC 0FFICES) (PSNH) 9., Quality Programs
-] QP.1 Quality Programs X X X QP.2 Program Implementation X X X QP.3 Incependent Assessments X X X QP.4 Corrective Actions X X X Test Control TC.1 Test Program X
,. , TC.2 Test Group Organiza- X
- tion & Staffing TC.3 Test Plan X 0
j TC.4 System Turnover for Test X
.,. TC.5 Test Proceoures a X
'1 Test Documents TC.6 System Status Controls X
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'I PERFORMANCE EVALUATION SLNMARY Construction Project
'; Seabrook Station
'; Performance Area: ORGANIZATIONAL STRUCTLRE Objective No. 0A.1
., Evaluator (s) W. Ramsoen & W. Willougnby (with Team contributions) i I. Performance (bjective
.j The Owner's corporate organization ano all other project organizations responsible for tne cesign, engineering, planning, scheculing, licensing, construction, quality assurance, and testing of a nuclear
- plant shoula provide an organizational structure that ensures effective project management control.
3 II. Scope of Evaluation The organization ano acministration of the project, including the stancaras and criteria contained in Performance Objectives OA-1 thru OA-3, was evaluated by the review of pertinent organizational charts, oiscussions, ana interviews witn appropriate management ana supervisory 3 personnel, and from the observation of ongoing work, both engineering and construction, from which assessments of the organizational and management effectiveness were cerived. The organizations evaluated
'l were UE&C, YAEC, and PSNH. Approximately 45 manhours were expenced for OA-1 thru OA-3.
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u III. Conclusion
, The stancaros of tnis Performance Objective are being achievea.
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'I PSRFORMANCE EVALUATION DETAILS Construction Project
.,, Seabrook Station i !
Performance Area: ORGANIZATIUNAL STRUCTURE Objective No. DA.1 j Other Information That Supports The Summary
- 1. PSNH, YAEC, ano UE&C all have effective organizational structures l to implement their intenced functions. Eacn of the organizations is headeo by a qualified Project Manager, who exercises good management control.
'n j 2. PSNH ano YAEC staffs are closely allied. In fact, many PSNH staff memoers are integrated into the YAEC staff for Seabrook
, project activities.
-s 3. Project Managers' relationships with their higher corporate
managers was evidenced by tne frequency of personal contact ano meetings.
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- 4. Reviews of the respective organizational enarts inoicates clear definition of the relationsnips and lines of
. responsiollities/autnorities. In aodition, integrateo charts show the interrelationsnips between the organizations.
-I ' 5. The following managers were interviewed to oetermine their place j
in the organization, responsibilities, authorities, mooe of operation, interface with otner organizations ano commitment to 3 training:
o Executive Vice President PSNH g, o Site Manager PSNH
't o Project Manager YAEC o Director of QA
- YAEC o Project Manager UE&C
,j[i Construction Manager o UE&C o Resloent Construction Manager UE&C o Site Engineering Manager UE&C 6
o Engineering Manager UE&C (nome office) o Site Support Engineering Manager UE&C (nome office) o Deputy Project Manager UE&C (home office) 11 The aoove managers unoerstood their relationship with the project m.
and were aware of their responsibilities and authority.
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'_ ) PERFORi%tCE EVALUATION
SUMMARY
Construction Project Seaorook Station r'
Performance Area: W\NAGEMENT INVOLVEMENT & Objective MJ. DA.2 C0tNITMENT TO QUALITY
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Evaluator (s) W. Ramscen & W. Willougnby (with Team contributions)
I. Parformance Oojective Senior ano micale managers in the Owner's corporate office, cesigner's
-- office and at the construction site wno are assigned functional
'i responsiollity for matters relating to tne nuclear project should exnibit, througn personal interest, awareness, ano knowleoge, a cirect
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involvement in significant decisions tnat could affect their responsioilities.
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II. Scoce of Evaluation Refer to OA.i.
-) III. Conclusion
'! Tne Performance 00jective is ceing met. One Good Practice concerning j the cepth ano dedication of senior management involvement in the project was noteo.
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- i j PERFORMAtCE EVALUATION
SUMMARY
Construction Project
.c, Seaorook Station
', ,! Performance Area: MANAGEMENT INVtX.VEMENT & Objective No. 0A.2 COM4ITMENT TO QUALITY a
IV. Areas of weakness & Corrective Action; Good Practices
!'] Finoing Tne following Good Practice was noteo. Senior manage-
,, (OA.2-1) ment representing PSNH, YAEC, ano UE&C displayed an extraoroinary interest and awareness of tne project's
- -- progress and problems. This awareness is attributed to
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'" tneir oirect involvement and first-hand knowleoge of the project activities.
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i PERFORMANCE EVALUATION CETAILS Construction Project Seabrook Station
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Performance Area: MANAGEMENT INVOLVEMENT & OoJective No. 0A.2 C0!+41TMENT TO QUALITY l
'i OA.2-1 A. The PSNH Executive Vice Presloent is personally engaged in tne following activities:
o Daily contact witn tne PSNH Project Manager ano the YAEC Vice Presloent l~\
.J o Attenoeo seneculec montnly meetings with the senior mat agement of YAEC ano UEaC j o Tours tne joo site oi-weekly o Atcenas quarterly meetings for joint owners, progress ano quality review o Reviews progress reports, reportaole items (50.55e) and 4
senecules
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- 6. The PSNH top management also takes an active interest in Quality
> i Assurance. Tnis is demonstrated oy attencance at quarterly meetings by tne PSNH Cnairman of the Board, Executive Vice 3
Presloent, Nuclear Project Manager, ano tne YAEC Vice Presicent, Director of Quality Assurance, Construction Quality Assurance il Manager, and tne Field Quality Assurance Manager.
U In accition, quarterly Q. A. evaluations are forwardea cirectly 7, from tne YAEC Director of Q. A. to the P99H Cnairman of the board. -
C. YAEC management is very neavily involvec with tne cay-to-day
, activities, as well as long-range Project airection. The Project
.i Manager oisplays a keen awareness of tne project's status ano proolems.
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PERFORMANCE EVALUATION DETAILS Construction Project
- rs Seacrook Station U Performance Area: MANAGEMENT INVOLVEMENT & Cojective No. 0A.2 Cot 441TME.NT TO QUALITY II t4 0A.2-1 D. The UE&C top management is involvec and takes an active role in tne project. Inis is evicencea oy tne following action taken by
!il UE&C. The most critical proolems icentifiea oy tne planning anc senecuiing montniy analysis are investigated by a team composed
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of Vice Presicent Power Division, Manager of Planning ano 1 Seneouling, ana Manager of Cost and Controls. Tne investigation
- l;] consists of a site tour of tne proolem areas / systems and interviews witn tne appropriate first line supervision. Tne
- investigation team recommenos resolutions, ioentifies
.i responsioilities and estaolisnes completion dates. Tne vice Presioent Power Division forwarcs a report of tnese prooiems
,, directly to tne Presicent of UEaC, with distrioution to appropriate managers.
.2 As a result of tne above action, the most critical negativity on
/ tne seneaule nas oeen reouceo.
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. i 1 PERFURMANCE EVALUATION
SUMMARY
Construction Project Seacrook Station 3 Performance Area: THE HOLE UF FIRST LINE 00jective No. 0A 3 SUPERVISORS & MIDDLE MANAGERS UtJ Evaluator (s) W. Ramscen, G. Rearoon, B. Gatlin, R. McMellon
" l, I. Performance Oojective Tne project first line supervisors ano middle managers snould ce I
- qualifieo Oy verified cackground and experience and nave tne necessary j autnority to carry out tnelt functional area responsiollities. ,
- 11. Scope of Evaluation Refer to UA.1.
III. Conclusion s
- Except in one area, tne first line supervisors and middle managers are satisfactorily meeting tne standaros of tnis Performance Oojective.
r1 Tne supervision of tne Piping Contractor's work shoulo oe j strengthenea. Weaknesses in tne area of senecule awareness ar.a oirect supervision of tne work were noteo.
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PERFORMANCE EVALUATION SUMARY Construction Project Seabrook Station
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'J Performance Area: THE ROLE OF FIRST LINE Objective No. 0A.3
- y. SLPERVISORS & MICOLE MANAGERS s[J IV. Areas of heakness & Corrective Action; Good Practices Finding Piping Installation Contractor supervisors are not suf-(OA.3-1) ficiently involved in the control, performance ana
_, airection of project activities. This is evloenceo by a 1
- l lack of scheoule awareness and is also supported by the observation of craft personnel requesting and receiving airection from QA/QC personnel regarding performance of fI work activities.
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Corrective Project Management is currently restructuring all activi-
'j Action ties being performed by the Piping Contractor, to aooress specific weaknesses relating to cocument control, the
_, cevelopment of construction aloes, craf t supervision ano
{ training, work scheouling, proouctivity ano quality s
control. Corrective actions commensurate with the significant of these weaknesses have been aevelopeo and
[ will be implementeo as soon as possible.
Tne Piping Installation Contractor is presently increasing his staff to afford increasea surveillance. It will be re-emphasizea in a directive from the Construction
{2I Superintencent that tne piping foremen are responsible for cirecting, supervising ano expediting the work. Progress
- } ano results will continue to be closely monitorea.
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Any airection given to the craftsmen will be through supervision to the general foreman and the foremen. Any airection, other than encouraged communication on acceptance stancards, given the craftsmen by QC inspectors
., will be minimized. A cirective will be issueo by the l contractor's QA/QC Manager to this effect.
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pw t J e, I PERFORMANCE EVALUATION DETAILS Construction Project
.. Seabrook Station
~ Performance Area: ROLE OF FIRST LINE ODjective No. 0A.3 SLPEr< VISORS & MIDDLE MANAGERS c-i- 0A.3-1 A. Tne Piping Installation Contractor's supervisors / foremen for pipe support work in the Primary Auxiliary Building are not adequately
{] involvec with and airecting tne work activity in their area.
o work pacxages for pipe support installations do not identify an estimatec completion cate or total time for
}' completion. Tne foreman assigns a Joo and permits workers to perform witnout specific completion requirements. Time i management does not exist at the joo level. Tne foreman feels that the work is being oone in an expedient manner
.J ano, tnerefore, sees no need to expedite work activities.
o Joo airection is availaole from the foreman ana/or the
hanger engineer. However, tne workers statea that they rely on tne in-process "QC Inspector" for direction, 4
Decause ne knows wnat is requirea. Botn the foreman ana i
tne QC inspector verified tnat tnis is tne acceptea work pnilosopny.
o wnen a foreman estaolisnes a work team (usually one welcer ano fitter), ne usually matenes one "experiencea" person with a new or relatively new nire. Blis is the pnilosopny for introcucing new people to " Nuclear" work and for
- > sustaining work progress witn minimal supervision.
However, of the six (6) work teams observea curig a walk-tnru inspection witn one foreman, the "experiencec"
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_j person naa, in some cases, less tnan tnree (3) montns work experience at Seaorook. The foreman stated tnat
- experiencea people are in snort supply, cecause of a nign turnover rate.
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o Training for pipe support craft personnel, other than tnat l
l required by tne contractor QAM (i.e. , Q. A. and Security is Incoctrination Courses 001/002), is provideo at the aiscretion of tne foreman. However, the foreman relies upon tne in-process Q.C. inspector to identify to nim wnich of nis personnel need furtner job-relatea training. Tne foreman ana Q.C. inspector agree to tnis arrangement. Tne
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foreman also sees no neea to keep training recoras for his craft people ano, insteaa, relies upon the training to cepartnent for recora keeping, 4
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- Ii PERFORMANCE EVALUATION DETAILS Construction Project Seabrook Station l'.
'.. ) Performance Area: ROLE OF FIRST LINE Onjective No. 0A.3 SLPERVIbONS & MICOLE MANAGERS
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.i i"I Otner Information That Supports Tne Summary
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- 1. The following first-line supervisors ano miodle managers were
.; intervieweo:
7- o Senior Project Engineer (YAEC) o Leao Meenanical Engineer (YAEC) o Supervising Nuclear Engineering (UE&C Home Office) o Supervising Mecnanical Engineering (UE&C Home Office)
.l o Manager Planning & Seneouling (UE&C Home Office)
J o Manager Planning & Seneauling (UE&C Site) o Supervisor Project Controls (UE&C Site) o Area Superintencent (UE&C Site) c, o Construction Training Acministrator (PSNH Site) o Area Superintencent, Piping Contractor o Supervisor Planning & Scheculing, Piping Contractor
] o Foreman, Piping Contractor This level of management was found to be generally satisfactory f{ ano possesseo tne autnority to carry out their responsibilities.
- 2. Review of the organizational cnarts with the supervisors inoicated that tne supervisors generally were aware of their (j areas of responsioliities ano project relationsnips, except as discusseo in QA.3-1 aoove, f!> 3. Tne supervisors were generally qualified tnru previous working experience ano had receiveo at least tne minimum training and inooctrination, m
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- i PERFORMANCE EVALUATION
SUMMARY
Construction Project Seabrook Station a Performance Area: Utb1GN INPUTS 00jective No. DC.1
.,3 tj Evaluator (s) C. Fonseca, M. Blancaflor, H. Setni, R. Glynn, C. Asnton
, l I. Performance Oojective l l
Inputs to tne design process should be oefined and controlled to
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acnieve complete quality cesigns.
n II. Scope of Evaluation The evaluation of Design Control (DC.1 thru DC.5) involved tne
,, expenditure of approximately 400 mannours.
. Tne evaluation of tnis area extended tnrough the various Engineering anc Design cisciplines, incluaing On-Project and Off-Project / Staff Groups at tne A/E neacquarters office and the Site Engineering
,j Organization, as ciscusseo in CC.l. Specific attention was oevotea to seismic cesign, structural cesign, piping analyses, component supports
- c. (incluaing pipe, HVAC, I/C, caole tray, concuit, ano equipment),
j' Electrical, HVAC, piping, and I/C systems incluaing in-line equipment ano appurtenances.
Discussions were concucted witn responsiole engineers ano cesigners, b tneir supervisors, anc tne project ano oepartment managers.
A cetaileo review of applicable documents and procedures was also concucted. This inclucea Corporate ana Project Design ano Engineering Control Proceoures, various Design Documents and Calculations, FSAR
, Commitments anc Regulatory Requirements, and NSSS anc otner Supplier's Documents, as reflected in the attacned Performance 5 valuation Details
-- section.
III. Conclusion The activities evaluated under tnis performance objective were
, generally satisfactory. Responsioility for control of design inputs is c- cefined ano unoerstood and inputs are controlled and used in a way tnat
!, is consistent with Corporate and Project Procecures.
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PERFORMANCE EVALUATION StJ4 MARY Construction Project Seabrook Station
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- f i; Performance Area: DESIGN INPUTS ODjective No. DC.1 j[j Evaluator (s) C., Fonseca, M. Biancaflor, H. Setni, R. Glynn, C. Asnton
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I Conclusion (cont'c).
..i A concern was icentified (see DC.1-1) tnat indicates the neea to assess 7] tne conservatism tnat is ouilt-in to tne structural cesign cases for
- l , emoecceo plates ano pull out capacity of emoecced studs.
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- r' (j Performance Area: DESIGN INPUTS Oojective No. DC.1 "1 IV. Areas of Weakness & Corrective Action; Good Practices tl Finaing Analysis was not eviaent to justify the
- l~1 (DC.1-1) conservatism in two (2) procecures contained in tne
,; guidelines used for emoecced plate and component support cesign. These proceoures relate to a case plate flexibility aesign ana the pull-out capacity of emoedaec
,! stuas.
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". s Corrective Appropriate investigation will be undertaken to evaluate Action the conservatism of the guidelines and procecures for pipe support design in the above identified areas. If
", necessary, tne guicelines will be modifiea ano appropriate "j
reanalyses uncertaken. Tnis will be completed by the enc of February,1983.
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Seaurook Station y, Performance Area: DESIGN CONTROL Oojective No. DC.1 F DC.1-1 A. The guidelines for pipe support design specify a flexibility factor of 1.2 for tension ano moments for cotn expansion colts and Nelson studs used for emoeoced plates. Tne factor of 1.2 for R expansion colts is justifieu by finite element analysis ana will
- j oe furtner suostantiated by tests. Use of the 1.2 factor for emoecceo stuas is not suostantiatea consicering the nigner p.. stiffness of stuos in tne analyses.
J
- 6. Design of studs is caseo on the N.lson stua catalogue, wnicn uses mean value test cata. The use of mean value test cata is not M consistent witn tne general practice of ACI Coce #318 wnich uses U minimum value test data.
?
g Otner Information That Supoorts The Summary
- 1. Engineering anc cesign information for two (2) representative f.,l HVAC systems was reviewed in detail. The two HVAC systems chosen
-)
were the Containment Enclosure Cooling HVAC System and the Control Room Complex HVAC System. The Final Safety Analysis F Report, System Description, P&ID, ductwork layout drawings, and
- lj} representative calculations were reviewed for eacn system. All of tnese were founo to De tecnnically acequate for the intenced
,q purpose. Design output via the drawings was consistent with the y input.
- 2. Vencor/UE&C engineering correspondence concerning various I!
centrifugal fans for tne project was revieweo. Technical information transmitted via tnis correspondence was accurate and proper. Fan performance test reports within tne files were o properly prepared and reviewed. Purchasing cocuments were j reviseo, as necessary, to reflect technical requirements. All otner accumentation was properly routed and controllea.
- 3. The control of cesign inputs in tne I&C aiscipline was evaluatea v
Dy reviewing the cevelopment of tne ESFAS system. NRC
" Circulars", " bulletins", "Information Notices", and the UE&C ano
[' client responses were reviewed, as well as the following crawings:
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- ,, Seabrook Station
.; Performance Area: DESILN CONTROL 00jective No. DC.1 Otner Information That Supports The Summary LJ -
0 ESFAS " Loop Diagrams" i
_j o Logic ano schematic olagrams of various aevices such as containment isolation valve #FV-4609 and pressurizer steam c:
- 1 sample isolation valve #FV-2830 The aoove crawings inaicated tnat the requirements of tne NRC IE
,_, Information Notice 80-06, "ESFAS Reset Controls", were complieu ml witn and appropriate cesign inputs reflected in the final cesign.
- 4. The seismic monitoring system was reviewed to aetermine how cesign inputs sucn as R.G. 1.12, 1.69, and IEEE 344-1975 were
,_; incorporatec into the design cocuments. Detailed review of SD-92 anc Specification 259-19 indicated that these design inputs were
, acequately contro11ea. The format of the system cescription and
' tne stancara specification were effective in ensuring tne inclusion of all aesign input information.
F] 5. Tne PA6 crawings used for tne development of the ARS were
'j compared with tne current crawings ano found to be consistent, witn one exception. Figure 8 on Page 53 of 65, of Calc.
' 58-SAG-6PB & 9PB, attacnea to Memo #8638A cateo 3/3/82, shows an erroneous almension wnen comparea to the orawings. Further review of tne calculation snowed tnat tne properties were calculated witn tne correct aimensions. Figure 8 should De fl; correctea, nowever it nas no effect on the results.
The aesign input was clear, in sufficient detail, and consistent witn current oocuments.
~~
- 6. Tne input for pipe support / design was reviewed starting with a L, load sneet from tne Piping Group, tne associated support cetail drawings ano several support calculations. Tne design input was LJ providea witn sufficient detail ano clarity to De useaole and i
uncerstancaule by persons using the input.
, 7. The ARS input related to the design of HVAC auct and I&C tray design was reviewec. A controlled ARS accument was in use.
, The values of the maximum span of the auct to meet 33 Hz frequency was received from MAG and was being used.
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,n Seabrook Station U Performance Area: DESIGN CONTROL Oojective No. DC.1 1
j Other Information That Suoports Tne Summary c, Design input was detailed and clear enough to be properly used by ji tne responsible persons and input was being properly used in tne J
calculations.
] 8. A report was suomitted to tne NRC in April,1982 covering Branen 1 Tecnnical Position APCSB 9.5-1, position C.4.3(1). Tne P&ID's nave oeen color-coceu, markea to indicate Train "A" & "B", as r, have fire zone plans, electrical senematics, ana one lines.
I' J Computer printouts were tnen generated listing, among otner tnings:
y o Raceways ano tneir associatea fire zones u
o Safe snutcown raceways ano associateo cables oy fire zones
)
j These lists inoicatea 710 cables would nave to oe analyzec. Tney were analyzeo oy fire zones anc by fire area (wnicn coulo cover multiple fire zones). Tnis is an ongoing program wnicn is well
[!
U cocumentea. Tne metnocology is prescrioed in "Procecure for Review and Report Preparation for 10CFR50 - Appendix R". Fire p protection of safe snutcown capacility is being satisfactorily implemented.
- 9. System descriptions are used to translate the requirements of f.i SAR, Reg. Guices, cesign criteria, etc. Tnese are reviewea and J stampeo oy affected project personnel, as well as indepenaently reviewea by tne Cnief Engineer or nis appointee, accorcing to O procedure. Cable Trays, ana conauit were examinea at lengtn.
They were eneckea against the following cocuments:
a o CaDie Tray Systems - notes and typical details o Conouit Systems - notes and typical details Sucn tnings as acceptable metnoas ano materials are celineateo in great detail. Caole tray splice plates, clamps, support cesigns, L means of attacning to supports, Oracing, slip-fits, flexiole connections, anc requirements for connecting conduit to caole tray ur tray supports, etc. are among those details.
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- J Otner Information That Supports Tne Summary Tnese accuments were founa to ce well definea, complete, ongoing occuments, generally current, ano are Deing followea ciligently.
_ 10. Tne primary component cooling system requirements, design ff commitments, ana limitations were reviewed witn tne Project
's Supervising Nuclear Discipline Engineer (SDE) and the Rsponsicle System's Engineer (RE). This review inclucea:
'l mj o System Description 50-23, Revision 4
-- o FSAR Sections 7.1.1, 7.4, 6.2.4, & 9.2.2 o Regulatory Guide 1.48 o General review of reference calculations " Project File
- 4.3.7, Cales. #F01 thru F23" ti o P&ID #9763-F-805016 o
Except for tne weaknesses icentified, tne reviewer founc tnat aesign inputs sucn as cooes, stancards, Regulatory Commitments anc requirements, criteria, and design cases are properly
- ioentifiea, clearly oefined, ana well occumentec. Calculations were founc to oe concise, clear, and easy to follcw, witn
~t conclusions that are consistent witn items listed aoove, ana
- , fully supportive of tne Primary Component Cooling System cesign.
., 11. Pipe stress analysis oesign criteria is governea oy Detailea Procedures DEDP-2607, "Procecure for Computerireo Piping Analysis", DEDP-2609, "Proceoure for Simplified Piping Analysis",
l- anc Meenanical Analysis Tecnnical Document, " Qualification of Lug E Attacnments on Straignt Sections of ASME Class 1, 2, & 3".
~
These occuments were reviewed for compliance with the FSAR
<- commitments, applicaole ASME Section III, 831.1 Coce
! requirements, anc Regulatory Guides and stancaros.
6: :
Except for weaknesses identified unoer DC.3-4 & DC.3-5, these
- ]
cocuments satisfy tne FSAR commitments and comply with applicaole requirements of the ASME Secticn III and 831.1 Codes. These procecures are generally very g000 and complete.
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- 12 PERFURMANCE EVALUATION
SUMMARY
Construction Project Seaurook Station
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Performance Area: DESIGN INTERFACES Oojective No. DC.2 m
a Evaluator (s) C. Fonseca, C. Asnton, M. Blancaflor, R. Glynn, H. Setni
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,1 1. Performance Oojective a
Design organization external and internal interfaces should De ci ioentifiec ano coordinated to ensure a final cesign that satisfies all input requirements.
J
.; II. Scope of Evaluation Tne scope of the evaluation is definea under DC.1, anc was accomplisnea r- oy concucting interviews, review of proceaures, calculations, crawings,
-i" ano specifications to assess tne cegree to whicn external ana internal interfaces were coorcinatea, uncerstoca, ar.o implementea.
i
> III. Conclusion Basea upon tne items evaluated for tnis Performance CDjective, internal
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ana external cesign interfaces are cefinea and uncerstcoa by all engineers, cesigners, ano tneir supervisors. In one instance a cesign r, interface with an outsice organization nad not been performed (see
.. Fincing DC.2-1).
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-, Seaurook Station 7-Performance Area: DESIGN INTFRFACES 00jective No. DC.2 r
- . IV. Areas of weakness & Corrective Action; Good Practices y_ , Finoing In one instance, tne design interface witn an out-(DC.2-1) sice organization (valve manufacturer) naa not Deen a performeo. Tne manufacturer's concurrence of restraint loaos imposed on the valve operator naa not been occumentea. ,
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Corrective It is tne policy of UE&C to contact equipment manufac-c) Action turers for concurrence when loaos are applieo to tneir
- equipment. The valve manufacturer referenced in the above
'd Finoing <ill ce contactea for loading concurrence ano a review completed to assure compliance witn similar T' situations.
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'] ] _. Performance Area: DESIGN INTERFACES Objective No. DC.2 J DC.2-1 As a result of tne pipe stress analysis effort for tne small Dore piping, tne stress analyst had specifiea tnat tne operator of motor-operatea or control valves be seismically restrained. Tne j'
restraints were aesigned by the Pipe Support Group (PSG). Tne valve u manufacturer naa not ceen contacteo to ootain nis concurrence, to ensure tnat the operator casing ana valve performance would not be affectea oy the loacs imposed by the restraint.
J Otner Information That Supports Tne Summary 1
L 1. Tne limits of respor. .iollity and authority are well oefinea in
" Design Guice of Electrical Organization, Responsiollity
^
Assignments, & Filing Systems", Rev. 7.
Several cocuments were reviewed from receipt / conception to
, acceptance / issue ano founa in accoraance with Administrative
- Procecure #29 (except for tne four week turnaround cate of J cocument control receipt to issuance in case of vencor prints).
Tne four week requirement is probaoly unrealistic, but provices a p target.
Examination of several oesign review logs revealed acequate g control anc cocumentation of the flow of information.
1 bl 2. Corresponcence relatea to the Containment Enclosure Cooling HVAC anc Control Room Complex HVAC Systems was reviewea. Meeting notes, client comments on engineering documents, various
[jl L transmittals, and other information was inclucea. It was notea tnat a system of controlled corresponcence distribution exists r and is effectively useo. This shows vet interfaces are properly
[ controlled anc cnanges are coordP4 d effectively witn all aisciplines. Interviews with tN F .ervising Discipline Engineer
_ and responsiole engineers a-0 9 air .rs, witnin the Mecnanical Services Group (HVAC), tene:C tu i. 43rm tnis ooservation.
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- 3. Acout 50 representative Engineering Change Authorizations (ECA's) from the HVAC area were revieweo. .Tne oesign change information t_ was founa to De effectively coordinated and controlled. Proper interaisciplinary review ano approvals were ootainea from tne
,y affecrea interfacing groups in accoraance with Procedure #AP-15.
ll Transfer of documents from tne site to tne nome office was snown to be proper. An effective means of tracking status for
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incorporation of enange information into final project arawings exists and is usea to estaD11sn priorities. The overall
_j interface process is g000.
- 4. Tne AKS controlled cocument was compared against the actual calculation output in SAG's calculations for the PA8 at tnree (3) elevations, i.e., elev. 108, N-S-SSE; elev. 81, N-S-08E; anc
, elev. 108, vert. SSE, anc founc to be consistent.
_. Revised loading aiagrams issued for revision of the ARS were
~
comparea witn those actually usea and founa to De consistent.
^
Tne flow of aesign information between internal groups was contro11ec and timely.
] 5. MAG activities concerning tne nanaling and distribution of a
interim issue of revisea ARS were reviewec. These revised ARS are cistrioution to tne lead engineers by the CSD Dy contro11ea 7 memoranca anc are filed in books witn tne supervisor, for record purposes. Tnis recora is maintained until a new revision of the contro11eo ARS cocument, implementing those revisions, is issuea. Two (2) recently issued revised ARS were tracked througn the system and found to be properly filed anc c'ontrolled. Tne transfer of aesign information from one group to another was l orderly ano maintainea in suen a way tnat it was available to p persons working in the group.
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- 6. The specific functions and Dreakocwn of responsiollities of tne
.; Pipirg Group were reviewed in detail. The Piping Group was q selectec cue to its various ano complex interfaces, both internal (witn tne various projects and staff groups), anc external (witn tne various Piping, pipe supports, and piping appurtenances, faoricators, ana suppliers).
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- b PEHFORMANCE EVALUATION DETAILS Construction Project Seauruck Station
.n! [ Performance Area: DESIGN INTERFACES 00jective No. DC.2 Otner Information Tnat Supports The Summary J
Discussions were nelo witn the Supervising Discipline Engineer
.] (SDE) ana various piping engineers (RE's) responsiole for tne b various specifications, interface control, anc contract management. Tnese aiscussions (reviews) inclucea the following:
1 i o Review of Piping Specifications 9763-006-248-1, d 9763-006-248-43, & 9763-006-248-51.
f~} o Transmittal of Isometric Dwgs./ Piping Dwgs, anc recommencea L; support locations to the stress analysis group.
,- o Review of stress analysis results with tne Pipe Support Group.
[
o Review of vencor interface (Grinnell, Corner & Lada, anc 3
Dravo), inclucing foreign print review, accumentation, ano
.; transmittal of aesign anc faorication information to vencor.
r)
!i o Control of enanges cotn internally (UE&C) originated or vencor request for ceviation anc/or cesign enanges.
[ o Review of fielo originatec cnange process and control LJ incluaing interfaras with appropriate cesign disciplines, p o Review of latest ARS information and comparison witn tnat u t usea oy MAG for the pipe stress analysis, including oocumentation of compliance or request for reanalysis, n
i Tne reviewer found tnat the functions performed by tne Piping L group were very complex and numerous. The SOE and RE have oeen in tne group for five (5) or more years and tne process has
" become routine. A proceaure, nowever, cocumenting the design y interfaces and respons10111 ties woula ce helpful.
q 7. A valve ano pump specification were reviewea. Empnasis was
- placea on tne interfaces between the various project ano staff groups, as well as applicable interfaces with the various ;
manufa.cturers. These reviews included:
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P L PERFORMAtCE EVALUATION DETAILS Construction Project Seaurook Station
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- Performance Area
- DESIGN INTERFACES Objective No. DC.2 l Other Information That Supports The Summary
'J o Compliance witn General Procedure GEDP-0015 m '
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o Review of comment sneets and verification of incorporation / resolution 1
o Proper format, incluaing P.E. stamp o Design conditions, including seismic / environmental
"]' requirements o venoor interface, including review and documentation of
,- foreign prints, manufacturer's stress ano seismic reports.
It was founo tnat tnese specifications are consistent witn Procedure GEUP-0015, tnat cesign conoitions nao been clearly icentified, and tnat all inputs and comments nao been properly
_ reviewea anc incorporatec.
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1i PERFURMAtCE EVALUATION
SUMMARY
Construction Project Seacrook Station r' 00jective No. DC.3 id Performance Area: DESIGN PROCESS P
d Evaluator (s) C. Fonseca, C. Asnton, M. Blancaflor, R. Glynn, H. Setni U I. Performance 00jective u
ine management of tne cesign process snould result in designs that are p safe, reliaole, verifiaole, ana in compliance witn the oesign requirements.
II. Scope of Evaluation h'
u Tne scope is cefined under DC.1 anc was accomplisned oy selectea,
~, review of oesign activities, from inception tnru implementation. Tnis J review incluceo evaluation of tne design process logic, implementation of this process, metnoas of reviewing design, resolution of cesign proolems, proper use of inputs, generation of outputs, and proper j' documentation and aistricution of drawings, calculations ana specifications.
[i Conclusion V III.
Ine majority of tne activities evaluatea under tnis Performance
!ql Cojective were satisfactory ano tne stancarcs of tne Performance
' Uojective were ceing met. The work performeo was professional, complete, anc consistent witn project requirements. Tnere were several areas of weaknesses ioentifiea tnat indicated a need to strengtnen L] certain proceoural implementation ano enforcement aspects and to improve a specific General and Detailec Design Procecure oy proviaing p aaditional cetails/cirection to ensure consiceration of all pertinent L cesign parameters
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L, PERFORMAtCE EVALUATION
SUMMARY
Construction Project Seaurook Station
$ Performance Area: DESIGN PHOCESS 00jective No. DC.3
.J
~l IV. Areas of Weakness & Corrective Action; Gooo Practices Fincing Detailea aonerance to all tne requirements of the (DC.3-1) project proceaure controlling the preparation of design calculations was not evident. N;merous instances of a primarily acministrative violations were noted. Tnis fincing also relates to training, TN-3.
7 1 Corrective Tne importance of proper references ano detail
-- Action in calculations nas been ciscussea with supervising
- engineers anc will be empnasizea again witn tne supervising engineers at tne project meeting November 24, 1982.
In one instance of calculation PIN-97o3-SQ-120-1-2007, the necessary norizontal "g" values will oe reviewed and correctea, if necessary, oy Decemoer 21, 1982.
~
The cover sneet for MCD #550.15 inaicates tne enclosures in tne pacxage ano functions as an inaex of tne package contents. This will De reviewed to aetermine acequacy by j Decemoer 21, 1982.
Training and empnasis in tne preparation of calculations 1 nas oeen aiscussec above.
)
,_ Finaing The qualifications requirea by 10CFR50, (DC.3-2) Appendix B, of the inaepenaence of ladiviauals who check ana verify crawings, calculations, ano specifications is not clearly oefinea in tne related project procedures.
Corrective The project nas committed in tne FSAR to comply with L- Action R.G.1.64, " Quality Assurance Requirements for the Design
- of Nuclear Power Plants", wnicn references ANSI N.45.2.11.
L- These occuments cefine clearly the inaepencence of the enecker/ reviewer ano the project is complying with these f' requirements. Accoroingly, revision to tne.referencea .
t
, GEOP's is not considerea necessary. .
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_j PERFORMAtCE EVALUATION
SUMMARY
Construction Project Seabrook Station q
It Objective No. DC.3 Performance Area: DESIGN PHOCESS o IV. Areas of weakness & Corrective Action; Good Practices Il Altnougn an approvec controlled issue of a procecure for
~;.
Fincing (DC.3-3) the cesign of HVAC duct supports has been oeveloped, an uncontrolleo copy was ceing used by the design supervisor anc cesigners coing the work. An unapprovec, uncontrolled U guiceline was oeing used in the design of I&C supports.
r, j Corrective Approved, controllec proceaures will be issued ana useo Action for the design of HVAC cuct support and I&C supports oy mic-January , 1983.
a Finaing The Detailec Engineering and Design Procedure relating to 1 (DC.3-4) the cesign of piping systems (DEDP-2607) is an excellent j cocument. However, it is not always being followea as it concerns location of lumpec masses for dynamic analyses.
Fl
' Corrective UEAC nas concucted an extensive review of tne analytical Action tecnniques presently oeing followea ana is satisfied tnat
] they are proper and correct. The procedure GEDP-2607 will J oe mocified to reflect current tecnniques by the end of Marcn, 1983.
F' Fincing DEUP-2607 coula ce improvea by proviaing accitional airec-(DC.3-5) tion to accress several areas of piping analysis. These l _'
areas relate to handling of jet impingement loacs, L decoupleo seismic analyses at coce bouncaries, ana woroing clarifications.
7, b Corrective DEDP-2607 will oe reviewed and revised as appropriate
,., Action consicering the above mentioned recommencations. Tne l, review will ce accomplished by the ena of Feoruary, 1983.
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PERFORMANCE EVALUATION
SUMMARY
Construction Project Seaurook Station Performance Area: DESlGN PHDCESS ODjective No. OC.3 I
- IV. Areas of weakness & Corrective Action; Good Practices
$l Finding some discrepancies anc non-uniformities were notea in (DC.3-6) tne oesign of emoeacea plates. The provisions in the cesign guicelines were not always being followea.
.I Corrective These discrepancies or deviations from tne aesign
-, . Action guicelines will ce evaluated for tneir significance anc
,j impact on the cesign of emoeccea plates. Designs will De reviseo, as necessary, and a more thorougn implementation
., of tne gulaelines stressea curing future training
, sessions. Tne proximity effects of emoeacea plate aesign
- will ce accressea auring tne Emcedoec Plate Verification Program (as-ouilt).
Finaing Tnere was a concern for the acceptacility of procea-
, ( DC.3-7) ures ceing usea auring the Seismic Design verification Program. The concern relates to peak spreading criteria u; for moaifiea Amplifiec Response Spectra (ARS).
I
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, Corrective The Seismic Design Verification Program will be re-
- Action evaluatea relating to tne above concern and appropriate
_, action taken if necessary. UE&C presently considers the procecure Deing followec in tnis regard to De acceptacle.
1 i Finding HVAC duct design procedure does not provide complete (DC.3-8) direction relative to auct stiffener cesign requirements.
Corrective Tne effects of axial forces in the design of HVAC duct Action stiffeners and local stresses at proue or other penetrations will be evaluatec, the guidelines moaifiec as l1 requirea and design revised if necessary. The effects of
'" these forces and stresses on the design is.considerea negligiole and recesign is not anticipated.
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PERFORMANCE EVALUATION DETAILS Construction Project Seabrook Station Performance Area: DESIGN PROCESS ODjective No. DC.3
[]
O DC.3-1 A. Several caole tray, concuit support, ano equipment qualification
[j calculations were reviewea:
o All pages were not ioentified oy calculation set numoers J o References were not always ioentifiec, such as ARS taole ana revisions P
L o Microfilming was not always cone per procecure q c Damping values were missing in Spec. 9763-S0-120-1 i
U o An unqualified computer program was being used to comoine other computer output stresses (output was eneckea
- manually, nowever) ana justification was lacking for tne
_j selection of tne maximum stressed memoer wnicn was the casis for oesign of non-incivicual designed memoers.
R j o Acequate backup cata oefining tne source of seismic amplified response spectra data relating to conduit and caole tray support and equipment qualification calculations
{ was not consistently presented or referencea on the J calculations, q o In one (1) instance, tne seismic criteria used in tne j
l design of a conouit support was incorrect. The horizontal "g" value was less than tnat actually requirea. Tne vertical "g" values were correct. Reference jl PIN-9763-SQ-120-1-2007.
a B. Pipe stress calculations MCD #573.20 anc MCD e50.15 were
] reviewed. nnile clear, complete ano easy to follow:
o Tne calculation inoex nad not Deen preparea o Pages were not sequentially numoered L :
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!l PERFORMANCE EVALUATION DETAILS Construction Project
,'J Seaorook Station Performance Area: DESIGN PROL'ESS 00jective No. DC.3
.lJ DC.3-1 o Results of certain calculations relating to some stress comoinations and lumpec mass determinations were presentec
, in tacular form anc backup calculations were not present in calculation package.
C. Several HVAC calculations relating to neat loaos, pressure crop, j
anc fan sizing were reviewed:
o Many calculation steps aid not identify the revision of
~1 referenceo drawings or applicaole tecnnical Dooxs l
o Some calculations cia not reference the cesign drawing on
-, wnich tne calculation was based i;
U o Not all indicated the metnod used to develop the calculation (e.g. , equivalent pressure drop, Daley
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formulation, etc. ) .
a All Final Primary Component Cooling water System reference D.
calculations (Cales. #4.3.7.F01 thru 4.3.7.F23) were revieweo.
Cales. 4.3.7.F07, F09, F.14, & F15 nac been voideo ana were not J reviewec.
o Calc. 4.3.7.F22 was not listed in tne index. Tne status,
._] contents, or its existence, coulo not De ceterminea.
- o Calc. 4.3.7.F01 identified information received from
,; inciviouals oy name; it cia not aefine the document numoer, document status, or revision tnat supported this information.
U Calc. 4.3.7.F11 referenced foreign print #50576 without L o l
accressing the issue / revision numoer.
Il o Calc. 4.3.7.F13 referencea preliminary Calc. 4.3.7.PO4.
D Tnis calculation nad been superseded.
O Cales. 4.3.7.F16 and F17 referenced the use of:
o Computer program "LIQSS" witnout any' identification of program version, level, status, run numoer, or cate.
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PEHFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station
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U Performance Area: DESIGN FROCESS Objective No. OC.3 9 DC.3-1 o Foreign prints and NSS documents witnout defining tne
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applicaole issue / revision numoer.
, : o Heat Load Tables without specific reference to their
- source or how tney were oevelopea.
7 DC.3-2 There appears to ce incomplete qualifications of tne incepencence
- j requireo of the cesign verifier responsible for cesign verification.
g o Criterion III of 10CFR50, Appencix 6, requires that cesign acequacy of safet.y-relatea structures, systems, ano components ce verified. Consistent with these requirements, UE&C's Topical Report, Amendment 5, Section R 17.1.3.4 commits to " design verification is performeo oy an O incependent cesign verifier (not tne designer's supervisor) wno is a tecnnically competent individual not directly
- q involved in tne aesign task unoer verification review".
II J Procedures GEDP-0013, 0005, & 0015 define the process usec for enecxing crawings, calculations, and specifications.
]' These procedures accress independent review witnout adequately cefining the reviewers qualifications for incependence.
yU DC.3-3 Details not considered necessary.
-, DC.3-4 A. Procedure DEDP-2607 estaolisnes tne criteria for placing lumped
! masses along pipe runs for the aynamic analysis structural mocel J representation. Tnis criteria requires tnat " masses snall De lumpeo at piping directional enanges",
t 3 e. Contrary to this requirement, tne review of calculations MCD
- 573.20 a MCD #550.15 inoicatea tnat masses nave not been lumpec at tne airectional cnanges. Tne closest lumpec mass points to
' tne alrectional cnange point ranged from 3" to 5'-0".
OC.3-5 A. Procecure DEDP-2607 coes not have provisions for incorporation of
'l jet impingement load effect upon the piping in tne piping stress
- analysis. Hanaling of tnis effect, required inputs, load anc stress comoinations criteria ana output format and distrioution
., to otner disciplines is not cefined.
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j PERFORMANCE EVALUATION UETAILS Construction Project Seabrook Station i Performance Area: DESIGN PRLCESS Objective No. DC.3 A more detailec aiscussion and direction, pernaps with some DC.3-5 m.
.! examples, is requireo in Procedure OEDP-2607 to define tne acceptaDie procedure, including load and stress combinations, Dencing, and torsional affects ana pipe support loaa cevelopment, when using tne common overlap option for decoupling two (2) ofnamic stress mooels. Similarly, more airection is requirea to cecouple a seismic pipe run from a non-seismic continuation of the same run where tne tnree (3) restraint (x, y, & z) option is
- useo.
C. Procecure OEDP-2607 makes clear distinction between supports, restraints, nangers, ancnors, springs, etc. These terms,
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nowever, are used indiscriminately in the body of the proceoure.
A review of tnis procecure is in order to ensure usage of proper
, terminology ano avoid potential confusion. In one case, the proceoure requires tnat..."at least one lumped mass snall De placed cetween any two (2) restraints", wnen it ooviously means tnat it sna11 oe placea oetween any two (2) support points.
j DC.3-6 The oesign guiceline relating to emoecced plates was reviewec for
, consistency with cesign calculations. The following was noted:
J o A discrepancy was noted regarcing the consiaeration of tne worst location of support attachment for design of stuas.
1 Calc. Nos.1307RG-55 & M/S 366-SG-8 were reviewed, anc tne
_; worst location of tne attachment was not considerea.
r- o Some non-uniformity in the use of lever arms for cetermining the tension in tne stuos cue to appliec moments J was noted in Calc. Nos.1307 RG-55,1307-SG-56,1307-RM-53, ana SV-54. The lever arm usec was not consistent witn guicelines witn respect to "2t" provision.
I o Tne affect of close proximity of other emoecment plates was not being taken into account in all cases. Proximity may reduce Stuo allowable values.
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- j PERFORMAfCE EVALUATION DETAILS Seabrook Station Objective No. DC.3 ;
Performance Area: DESIGN PROCESS
? DC.3-6 o A criteria for defining the allowable tolerance (1/2") in Ll locating pipe supports in the fielo, from tne centerline of the emoeoment plate, is ceing aeveloped. At the present time, tne calculations for emoeament plates ao not consicer
.1 tne effect of tnis tolerance in tne aesign. In accition,
" supports installed prior to tnis criteria will require verification of tneir location ano suosequent emoecoea plate review for acequacy,
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o DC.3-7 The Arts usea in tne aesign of the plant are systematically Deing m verifiea to account for actual as-ouilt equipment weignts, locations, ano structural masses. This is oeing cone as part of tne Seismic g
Design Verification Program. The verification spectra is compared to tnat usea in tne present design, wnien includes peak spreading, to confirm tne acceptacility of tne plant aesign. Prior to tnis
- 4 comparison, tne peaks of tne verification ARS are not Deing spreaa.
The verification (unspreaa) spectra is consicered acceptacle proviaing it is enveloped oy tne spread ARS usec in the present design.
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DC.3-6 A. The HVAC ouct plate is oesigned for ouckling. Stiffeners, however, are Deing designed for moments only witnout q consiceration of axial forces for loacing pressure. Stiffeners
" axial force stress shoula De checked against allowaole cuckling l stress.
' r' Localized stiffening of cucts at in-line velocity proce locations i e.
nas not oeen consioerea or evaluatea, m
- .1 Otner Information Tnat Supports The Summary P&ID's, auctwork layout drawings, specifications, anc 1.
O calculations in tne HVAC ciscipline were reviewea. Items were properly reviewea, eneckec, approvec ano properly verifiea in
'- accorcance witn project proceoures.
- 2. Personnel from tne HVAC 01scipline including tne Supervising Discipline Engineer (SUE), ResponsiDie Engineers and a oesigner c3 were intervieweo. Frort the discussions and work ,Deing reviewed, j;
u it was evident tnat personnel were acequately qualified to perform HVAC engineering and design. Both supervision and p cesigners exnioited a nign oegree of involvement in the cesign 9
quality ano timeliness of engineering and design response to F project neecc.
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- PERFORMANCE EVALUATION DETAILS SeaDrook Station i
Performance Area: DESIGN PROCESS 00Jective No. DC.3 9
Otner Information That Supports The Summary
' 3. To assess tne awareness of tne IkC personnel regarding the use of project procecures, tne Power Engineering Department Manual, Aaministration procecures, GEDP's, anc DEDP's were examinea with selecteo personnel. Discussions witn tne SOE's and RE's as to now tney utilize and keep abreast of these procedures revealec l the following:
"1 o A controllea set of procecures was in the SDE's office.
Changes to proceoures are communicatea to the group througn
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meetings.
' o The oesign process is well accumented. The I&C personnel had a good knowleoge of the existence of these procedures and, in general, follow them, d
4 The cevelopment of Specification 173-1 " Specification for Control
- Valves", from initial issue to present revision, was tracep to assess now well a specification was prepared and reviewed. The ,
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following coservations were mace:
o Specification was in accorcance witn tne GEDP-0015 format.
.L Interdiscipline comments were well documentec in tne o
" Document Review Request for Comment" forms, o Calculations for valve sizing were cone in accordance with GEUP-0005.
t o Ranoom samples of vendor calculations were comparea witn A/E's calculations anc were founa to be consistent.
o Interoiscipline comments tnat were acceptea were inclucea in the revised specification.
Baseo on tne above observations, tne control for this design
-- process appeared acequate. ,
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b! Performance Area: DESIGN PROCESS ODjective No. DC.3 lg Other Information Tnat Supports The Summary
-. 5. During a review of structural calculations, it was noted that tne containment internal concrete floor was assumed in rigid range i and, tnus, no floor amplification considered. Tne assumption was verifiea from tne ARS curves developed to evaluate frequency cnaracteristics of concrete floors. The calculations ano l7j analysis clearly specified the assumptions ana they were verifiec from gener.ic referenced material.
] 6. No masonry walls are oeing usea in any of the safety-related U structures.
R 7. Calculation PS-14 for PAb floor elev. 53 was checked. The input
'!j from SAG matenes tnat usea in the calculation (thougn latest SAG results received in 3/82 nave not oeen incorporated). Floor amplification is taken into consiceration and reinforcing steel
, designea accoroingly.
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- 8. Calculation Pd-51, SB TK.40 for a flash tank in PA8 was checked.
l Loads issuec Oy MAG were used in tne oesign of foundation ana J ancnor bolts. Ancnor bolts were cesignea oy criteria other tnan Appendix F (reference DC.5-4) and, to date, no eneck has been q made for compliance.
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" The palculations were developea anc checked with proper references to tne appropriate comuter run used.
_J Based on tne above, the Calculations were judged to be Complete and understandaole, performec Oy tecnnically qualified personnel; 7 however, design changes are not oeing implementea in timely
.g manner and implementation is not oeing ensured (reference OC.5-1).
- 9. Several pipe support calculations were reviewec. The stiffness and frequency criteria given in guicelines was ceing usea, as was o tne appropriate aesign check list.
1 Friction forces were being usea as requirea by the criteria.
j Design control, in cases sucn as procecures ana eneck. lists, were oeing followea, except for tne critical location and lever arm
, criteria (see DC.3-7).
J 10. Calculation M/S-328-SH-07 anc ECA-2510534F were checked. The oesign was found in oroer.
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~1 PERFORMANCE EVALUATION DETAILS Construction Project Seabrook Station
" Performance Area: DESIGN PROCESS Oojective No. DC.3 Otner Information Tnat Supports The Summary
-, o Supplementary steel for pipe support and auct support was oeing designea cased on frequency and stiffness guiceline criteria requirements.
'l o Class 2 & 3 cuct supports were being designeo for a frequency 33 Hz. Category 1 cucts were being aesignec for actual frequency anc correct ARS "g" values.
i o A cuct support frame was analyzed by a computer program
" wnicn also enecked memoer stresses (except torsional), wela checks, and NF code checks.
) o A Class 2 duct support was reviewed anc found to be in arcer. Tne cesign of an embeament plate was reviewec ano was being oone in accorcance with the guicelina/proceoures using appropriate tables.
Basea on these ooservations anc reviews, the related calculations
- and analyses clearly snow assumptions, inputs, references, ana
- metnoos ano results in a manner tnat can ce followed oy a tecnnically qualifiec person.
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'j 11. The IaC tuuing tray and support cesign criteria was reviewed anc comparea witn calculations. Tne designs were consistent witn tne
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criteria. Assumptions, inputs, methocs, anc results were clearly stateo.
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- 12. A detaileo review of a calculation of voltage regulation
, inoicated conformance with procecures but was still a " Preliminary", altnougn seven (7) years old. Tne Responsiole Engineer pointea out tnat in order to be truly final, a voltage regulation calculation requires test data of transformers ana
' otner final venoor information. A cneck of inputs to several
'-' computerized calculations revealed no mistakes.
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PEMFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station
.J Perfonnance Area: deb 1GN PROCESS 00jective No. DC.3 j Otner Information That Supports Tne Summary
- _ , 13. The activities of the Failure Modes and Effects Analysis (FMEA) group were reviewea. The group has been cnarged witn a cetailed J review anc cocumentation of tne pipe break postulation effort anc other responsioilities, incluaing concerns identified at Diablo
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Canyon. A detailed examination of tne FMEA' Groups' responsioliities, plans, approach, proposea occumentation format, anc work completed to cate was conouctea. It was conclucea that r, FEA's methods, criteria, approacn, anc oocumentation plans j (incluaing proposea interaiscipline review and approval) will
'- provide tne project witn a oesign effort that is consistent witn tne SAR commitments ana NRC Stancard Review Plan requirements. A
[' manpower concern was ioentifiea, reference PS.2-1.
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- 14. A cetaileo review of stress analysis calculations #573.20 anc
-. 550.15, for compliance witn procecure DEDP-2607 was performed.
l Tne following was reviewed witn the SOE.
o Nature and contents of inputs received from the Piping O group.
o Development of cynamic structural model -
! o placing of lump masses a
o location ano stiffness representation of supports
.j o ceginning and end of proolem 1 o decoupling criteria and application, including common j zone refinition ana representation
, o boundary restraint concept at seismic to non-seismic bouncary
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o jet impingement effects on pipe stresses ano support loacs o stress and supports cesign confirmation ana !
"as-ouilt" verification programs l l
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lm PERFORMAICE EVALUATION DETAILS Construction Project i Seacrook Station Performance Area: DESIGN FROCESS Oojective No. T.3 Otner Information That Supports The Summary o pipe break restraint effects on pipe stress (zero [0J gap restraints, cual function supports) o small core stress analysis o ASME Section III lines o Non-ASME seismic lines o Non-ASME, non-seismic I o nandling of motor-operated and control valves
" in small core analysis o vents, crains, ano test connections o nozzle loads, valve loacs, valve seismic qualification confirmation o load and stress combinations o
o use of nominal pipe wall tnickness vs. minimum wall thicxness o nanaling, documentation of assumptions, manual cales,
, preliminary /unconfirmea input o interfaces with Piping Group, PSG, FMEA, Piping Design, ano project Except for the weaknesses identifiec (see Finoing DC.3-4), it was concluceo tnat tne work cone oy tne MAG Pipe Stress Analysis
- Group was professional, complete, anc consistent witn project requirements. Generally a very good effort.
Tne organization anc general breakoown of responsibilities for the Nuclear Discipline Group was reviewea anc found to oe
- acequate.
Specific cetailed review was made of the following:
o Corporate proceoures (GEUP's & DEDP's) anc Project Acministrative Procedures i
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'i - PERFORMMCE EVALUATION DETAILS Construction Project Seabrook Station r-Performance Area: DESIGN PROCESS Oojective No. DC.3 Otner Information Tnat Supports The Summary o Piping crawings #F805214, F805215, F805230, F805295, ano F805296 l
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o Foreign Prints #20430, 50218, & 52238 m
, i It was concluoed tnat tne acove were properly documenteo and
' 'J controlled, had received appropriate and required reviews, and were consistent witn proceoures and design criteria.
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PERFORMArCE EVALUATION
SUMMARY
Construction Project Seabrook Station
! Performance Area: DESIGN OUTPUT Objective No. DC.4 Evaluator (s) C. Fonseca, C. Asnton, M. 81ancaflor, R. Glynn, H. Setni
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I. Performance Oojective Project cesign requirements should specify constructacle designs in
._ terms of complete, accurate, ano unoerstanoaole oesign requirements.
II. Scope of Evaluation
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Tne scope of tne evaluation is defineo under DC.1, ana was accomplisneo Dy a cetaileo review of various cesign output documents. These incluceo crawings, calculations, ano specifications.
III. Conclusion Baseo upon tne activities evaluated for this performance objective, tne design outputs were complete, clear, easy to follow, unoerstancaule, compatiole witn applicaole inputs, anc consistent witn tne design criteria and project requirements. Two (2) constructacility concerns were identified; one relates to cable termination difficulties at the containment electrical penetrations, and the seconc to inconsistencies between tne various construction tolerances and minimum clearances
, requirements. An aooitional weakness and a Good Practice nave also oeen icentifiea, m
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- l, J PERFORMAtCE EVALUATION
SUMMARY
Construction Project Seaorook Station 9
tj Performance Area: DESIGN OUTPUT Objective No. DC.4 IV. Areas of weakness & Corrective Action; Gooa Practices Finoing Examination of caDle tray ano support design at two con-
. (UC.4-1) tainment electrical penetrations raised questions about
.J constructability, operacility, and maintainaallity. Tne oesign cues not appear to allow for caole tcrminations and/or caule bends witnout great difficulty or removal of eq j some trays or tray supports.
~l Corrective The area near tne Electrical Penetration Bank in tne Con-J Action tainment tnat is referred to in this Finding is generically a congestea area. Optimum space cannot be obtaineo.
- r, Availaole space is governea by the layout of tne
- [; penetrations througn the Containment wall.
,, Caole terminations will not De extremely aifficult oecause tne covers on tne penetrations are removaole on all sides.
- In aoaition, tne two norizontal trays Delow the referenced penetrations are ceing lowered to provice more space for a caole pulling and terminations, a
-, Fincing There is not a uniform procecure or requirement for l (DC.4-2) all site contractors to follow relating to minimum erection
'" clearances Detween aajacent components and component supports. It was evioent tnat the lack of sucn a
[] requirement is causing some construction interference
.j proolems and tne potential for seismic clearance requirements to be violatea.
Corrective General Specification TP-8 " Separation Criteria" will ce Action issueo for all Contractors by the end of January,1963 ano a Dacxfit program instituted to assure required clearances
._; are maintainea on all completed work.
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J PERFORMAtCE EVALUATION
SUMMARY
Construction Project
-. Seabrook Station
.; Performance Area: DESIGN OUTPUT Objective No. DC.4 IV. Areas of Weakness & Corrective Action; Good Practices
$ Finaing Tnere is an inconcistency oetween a note on the Caole Tray (DC.4-3) Support Gaiceline anc tne related cesign calculations. Tne general note indicates the supports are designed for a 10'-0" span wnile several support calculations are basec on
, an 8'-0" span. Also, tne general notes do not define tne structures, or seismic zones, where the guicelines are
-, applicaole.
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.j Corrective The inconsistency on tne general notes will De clari-Action fieo ano support calculations reviewed ana moalfiec as necessary to assure consistency with tne guicelines. Inis will be completea oy tne eno of January,1983.
A reference indicating where tne guidelines are (seismically) applicaole will be accea.
.; Finaing The following Good Practice was noteo. The project has (DC.4-4) institutea a numoer of cesign verification programs relating to seismic design, structural aesign, equipment qualification, piping analyses, steam line breaks, emceccea plates, and anchor bolts. The completion of these programs will increase tne cesign conficence and enhance tne
.j reliability of tne plant. -
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PERFORMArCE EVALUATION DETAILS Construction Project
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Seaorook Station Oojective No. DC.4 Performance Area: DESIGN OUTPUT DC.4-1 A. Examination.and consultation witn field supervision confirmeo constructacility concerns in the area of tne "A Train" 7 Penetration Room - Level O'-0", and the "8 Train" Penetration a Room - Level 26'-0". At tne "A Train" Penetration Room, there appears to be no room for an electrician to terminate cables at penetrations H28, H29, H30, & H31. At tne "B Train" Penetration Room, tne same condition exists at penetrations Hol, H02, H03, &
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- ~l B. because of tnis problem, furtner investigation was conaucted at
!J otner potential proolem areas. In all other areas coverec, the constructacility was founa to have been well tnougnt out ana
'- implemented. The cesigners exnioited knowledge of, anc concern for, the proolems of constructaoility and maintainability ana workea towards tnat eno. It appears that this finding was an isolateo case. ,
J DC.4-2 A. The HVAC Installation Specification #9763-006-45-15 specifiea a recommencea minimum clearance of 1-1/2" oetween HVAC ouctwork ana l supports, and all seismic equipment, incluaing cable trays, cable
.j tray supports, piping, etc. Otner traces sucn as electrical anc piping do not have the same 1-1/2" clearance requirements, thus
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c, they are not preventea from locating their components closer than i 1-1/2" to erectec auctwork. Deviation from tnis requirement must
. I' L; B. Fifty (50) recent HVAC non-conformance reports were reviewed.
Four (4) out of tne fifty (50) were caused oy tne 1-1/2" minimum q
clearance requirements.
HJ C. A general specification, #TP-8, has been under devcicpment for some time to invoke stancaro clearance requirements for all
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contractors anc is currently issued for review ano comment.
.J Tnere is no evicence, however, that it will be issued in a timely manner to support construction or to remedy resultant r, constructaollity proolems.
DC.4-3 Details not considered necessary.
!' DC.4-4 Details not consicered necessary.
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PERFORMANCE EVALUATION DETAILS Construction Project Seabrook Station
. .. Performance Area: DESIGN OUTPUT 00jective No. DC.4 Other Information That Supports Tne Summary
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- 1. Project cesign crawings, including P&ID's, ductwork layout, cuctwork support drawings, ano logic diagrams for HVAC work were reviewea. The cesigns were prepared in sufficient detail and reflectec constructable cesigns. Drawings were kept up to cate
-, using a controlled process.
- 2. Several I&C output documents were reviewed to determine clarity, logic, and completeness of aesign information.
ii m; o Specification 46-1 w/attacnments, an I&C installation specification wnicn gives tne generic requirements for r' installation sucn as: slopes of pipes, seismic cata,
' support cetails in every area of the plant, thermal expansion, and otner stancaro metnous of installation.
O The Stancaro Instrument Schecule (SIS) - a computerizec
- list of all instruments with information sucn as:
manufacturers, types, reference drawings, etc.
o Installation cetails - stancard schematic arawings showing tne basic components of an instrument loop.
.r, j, o Specific drawings sucn as tne physical arrangement and
'" tuoing routes.
The aoove crawings gave sufficient information ana cetail for the
. .j contractor to prepare nis Installation /Faorication package.
Constructability was considered oy allowing tne contractor to
- route tuoings where there are no interferences. In special cases where tne routing and support locations are specified,
" interference arawings (" nit squad drawings") are preparea.
- 3. Specification SD-90 and Specification 172-1 (including attacnments for tne "Raciation Data Management System") were revieweo. Tne specification was prepared in accordance with
"- GEDP-0015. Tne tecnnical requirements for each component were statec; tne environmental and seismic conditions were specified;
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tne qualification requirements properly specifiec ano pertinent standarus referenced. The specification nac sufficient information and detail to allow a venoor to supply the system.
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~) Construction Project PERFORMANCE EVALUATION DETAILS Seacrook Station d Performance Area: DESIGN OUTPUT Oojective No. DC.4 m
] Otner Information Tnat Supports Tne Summary
, 4. To evaluate tne completeness, clarity, and logic of control loop aiagrams, logic olagrams, ano senematic ciagrams, sample arawings
" of tne Feedwater system were reviewec. Tnese crawings were founo to De complete, systematic, and coula be uncerstood oy a 7 qualifiec engineer /cesigner.
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- 5. Tne ARS occument was reviewed. The occument is controlled, kept
, current, is complete ana uncerstandable without neec for j interpretation.
- 6. A cetailed review of tne piping cesign functions was performeo.
I' The effort concentratea on the design process and, in particular, L. on tne procucts (output) generated. Various safety anc non-safety related work packages were reviewea. Each item was
- r enecxed anc tracked to its source.
It was concluded tnat all inputs were enecked and were cased on
, controlled infonnation. *
.- The piping isometric crawing, witn support locations, coupleo witn tne applicaole work package information provides all r, necessary inputs for tne piping analysis effort ana,
{-'j suosequently, tne pipe support effort. The reviewer was nignly impressea oy tnis excellent approacn. The piping designer must ootain anc use tnis information to perform nis work. Tnis input i is tnen enecxeo ano passed along to tne interfacing aisciplines -
- - Piping, Pipe Stress (MAG), Pipe Supports - insuring consistent cesign inputs tnrougnout the cesign process.
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'L The process itself is a very complex cne and has evolvea tnrougn tne years to wnat it is toaay. The Design Supervisor ana Leac
- ,. Designers seem knowlecgeaole and at ease with all the steps.
However, tnere was not a related written procecure or cetaileo
" oescription of work, or road map to follow wnich would ce nelpful in ensuring tnat all steps are properly uncerstood and appliec, cotn witnin tne group anc interfacing cisciplines, c
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PERFORMArCE EVALUATION $UMMARY Construction Project Seabrook Station
- PerfoImance Area
- DESIGN CHArtES Oojective No. DC.5 l!
Evaluator (s) M. whitelaw, W. Rotnerforth (with contrioutions from the rest of tne team members) 1 j1
'_, I. Performance ODjective Changes to releasea project cesign documents snoula De contro11ec to ensure tnat constructea cesigns comply witn tne most recent design
!"t requirements.
.3 II. Scope of Evaluation Tne scope of tne evaluation is definea unaer DC.1 and was accomplisnea tnrougn a oetailea review of tne various oesign cnange processes ano confirmeo oy examining tne appropriate oesign change cocuments.
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-.' III. Conclusion
, : Tne standaros of tnis Performance Oojective are ceing met. There were
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! four (4) areas of weaknesses icentifieo that inoicated tne need to streamiine Administrative Proceoure AP-15, consider expanaing the' scope y, of the Site Engineering Group, ana to implement a more effective
- control of two (2) cesign enange proceaures.
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SUMMARY
Construction Project Seabrook Station L Performance Area: DESIGN CHANGES ODjective No. DC.5 "I Areas of weakness & Corrective Action; Gooc Practices
- j IV.
q Fincing Tne Engineering response to requested cesign enanges is not
- (DC.5-1) always timely, oue to apparent difficulty in implementing
" Acministrative Procecure 15 (AP-15). Contributing factors appear to De tne restricted scope of tne Site Engineering
[ Group anc tne priorities of tne Site Support Engineering
+j (SSE) Group in tne UE&C Home Office, l Corrective The latituce of work assigned to the Site Engineering J Action Group to incepenaently resolve ECA's will De periodically evaluatec as tne size and capaollities of tne group continue to increase in accordance with seneduled plans.
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The priorities of tne Site Support Engineering (SSE) group n have oeen structured to accress the concern for prompt incorporation of ECA's onto design arawings, ana U significant progress is Deing made in tnis area. The concern is expectea to be resolved oy December, 1982 at
] wnicn time tne priorities of the group will be sniftec J towara greater support to fielo concerns, q The present AP-15 requires that Engineering incluce all
- Finoing
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(DC.5-2) affectec cocuments on tne ECA. A situation was aiscoverea wnere an affecteo Foreign Print was not referencea on tne
. ECA.
7 Corrective Tnere is a specific requiretrent in Aoministrative Proce-
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Action oure 15 tnat all affectea cocuments be listea in tne applicacie section of tne form. Engineering personnel are
., sufficiently knowleogeacie to icentify ana list tne foreign
.I pIints as affected documents. This Finding will ce J investigateo to oetermine if it represents an isolatec case or is inoicative of a more wicespread concern.
a"> In tne meantime, increaseo attention and a specific managenent airective will be issued to ensure that the
. . , requirements of AP-15 are being implemented.
A continuation sheet will be issued for the referenceo ECA to incorporate the missing affected documents.
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l PEHFORMAPCE EVALUATION
SUMMARY
Construction Project
-3 Seabrook Station Performance Area: DESIGN CHANGES 00jective No. DC.5 W,.
,, IV. Areas of weakness & Corrective Action; Good Practices I
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Finaing (DC.5-3)
Tnere is not an effective method to control the status of allowaole pipe support location tolerances. In various Instances, a portion of the allowable tolerance was usea
]J ouring tne oesign of tne support, anc no metnoa was evicent to prevent tne same allowaole tolerance from being useo again curing the erection of the support.
Corrective Tne pipe support locations on tne analysis isometric Action will De comparea with tne "As-Built" support locations.
'l This is currently specified in tnc "As-built" procecures.
LJ The procecures useo by the Pipe Support Group to relccate supports will ce reviewed oy tne project for consistency with tne intent of the "As-Built" review ano appropriate
]q cnanges mace as required.
O Finoing Tnere is not a formal procecure or metnoa to ensure that
- J (DC.5-4) all enanges resulting from mocifications to the structural Ivnplifiec Respunse Spectra (ARS) are trackea thru H implementation of aesign review. The current system uses contro11ea inter-aiscipline memoranca, wnich may De 1]"
effective if actively tracked by the responsiole engineers,
, out a more positive, controlled metnoa, sucn as an action log, woula provice greater visiollity ano assurance tnat tne enanges nave Deen consicered in the final cesign.
~l j Corrective The project will evaluate whether a more formal procecure Action is requirea in tnis regard and take appropriate action.
All equipment foundation bolts are presently aesigneo in accorcance witn general incustry stanaards and practice to meet tne design load requirements. As a uniform design 9 approacn, Appenaix F (presently lit craft form) will be L _. formally incorporated into the Structural Design Criteria, 50-66. Tnen all equipment founaation aesigns will be y verifiea per Appendix F.
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- j Construction Project PERFCRMAtCE EVALUATION DETAILS Seacrook Station 1
Performance Area: DESIGN CHANGES ODjective No. DC.5 l'1 l DC.5-1 A. Discussions witn site contractors, UEaC site engineering, construction management personnel, and YAEC site personnel resulteo in a recurrino comment that UE&C engineering resolution G of construction prooleins was not always timely to support j construction. Altnougn the discussion presentea nerein snoulo ce tempereo witn tne unoerstancing that it is caseo on interviews witn site personnel wno nave an oovious set of priorities not il
" necessary in concert with overall project priorities, it appears tnat tne following items
Dear consideration,
m o Implementation of Acministrative Procecure 15 (AP-15),
wnien controls engineering cesign cnanges, is proving to ce q
alfficult. All UE&C site engineering grcups with a neavy workload expressed this concern.
o Improper implementation of AP-15 may oe occuring as rs evicenceo by the numoer of Engineering Change 4j Autnorizations (ECA's) wnicn are generatea (approximately 300 per week) .
o The latitude provided to the UE&C Site Engineering Group to generate ECMs witnout Hame Office concurrence and/or action, as permitted in AP-15, may oe restrictive. This
, incluces the limitations on the " Minor ECA" list ano tne w excessive number of " Generic Major ECA's" which must ce issueo oy tne Site Support Engineering (SSE) group.
o The priorities of the Site Support Engineering (SSE) group are not necessarily ordereo to support construction. Tnis is evidenced oy the large numoer of crawing revisions to l
incorporate outstancing ECA's. Altnough tnis is recognizea J as a critical project activity, the work effort to support these crawing revisions utilizes the same people wno nave
'; tne responsioility to support construction oy interfacing
_j witn tne Site Engineering group. Statistics were studiec wnicn inoicateo tnat 50% of tne ECA's sent to the SSE group for action prior to issue of tne ECA nac a turnarouno time in excess of 26 cays. In many cases, questions must ce
~ referreo oack to project engineering oy SSE,. contributing to tne turnarounc time.
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. PEkF0kMAM'E EVALUATION DETAILS Construction Project Seaorock Station
.s j Performance Area: DESIGN CHANGES 00jective No. DC.5 I
DC.5-1 B. To illustrate the aoove concerns, the interface links between the li contractor, the UEAC site engineers, ano the UE&C nome office engineers relative to the HVAC portion of the project were
~; reviewed.
O Contractor personnel, including the P1oject Manager, Assistant Project Manager, Area Supervisors, anc foremen j indicateo tnat work has been celayeo by unresolvec
.i engineering proolems and aaministrative celays. They indicatea that the average delay was about 4 weexs. Tnis 1 makes effective work planning difficult. A subsequent
.j review of about 50 completed ECA's confirmed that an average of 4 weeks were requirec to resolve typical ECA's.
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C. A review of the Engineering Change Authorization (ECA) and Request For Information (kFI) logs on site inoicate a substantial numoer were in violation of Proceaure AP-15, Section 5.62, "the
'l Home Office SSE snall, witnin 10 working cays (auditable goal 30 i
- calenaar aays), perform sufficient analysis to estaolish wnetner the ECA is reasonaule, and provice a forecast cate of when tne
- ECA will oe officially concurrea witn, or replaced by, a
- ] correctea/revisec ECA".
DC.5-2 A. During an evaluation of QA/QC aspects of structural steel erection, it was founc tnat tCA #01/2793E ala not list tne
'J affectea foreign prints as requirea oy Procecure AP-15.
r As a result, at tne drawing control area in tne fielo, tne UEaC crawings correctly listed the ECA on the crawings, but tne faoricator (Cives) crawing, also founo in the Drawing Control Area, aio not reference the ECA.
- Both sets of drawings were applicable to tne same construction process.
Discussion witn the UE&C site engineering personnel and tne contractor's personnel inaicated that tnis was a weak area witn regara to use of erection crawings.
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- [ j PERFORMANCE EVALUATION DETAILS Construction Project Seabrook Station UtJ Performance Area: DESIGN CHANGES Objective No. OC.5
'l DC.5-2 8. UEAC Acministrative Procecure AP-15 requires that UE&C
- LJ engineering reference the affected foreign prints on tne ECA.
For cases wnere the design change is initiatea oy engineering,
.m ratner than tne contractor, tnere is concern tnat all affecteo
'! j foreign prints will not ce referenced. Tne Finding oesrioes a situation wnere a UE&C foreign print (structural steel faorication erection drawing) was not referencea on an ECA.
o Review of the HVAC Contractor procecure DP-1 indicates tnat tneir Document Control Center coes not incorporate ECA's
- r< unless an affectea foreign print (cut sneet) is referenced i on the ECA. The same concern expresseo aoove exists for tnis situation.
U OC.5-3 Details not consicereo necessary.
U OC.5-4 A. Changes in structural response issueo by SAG, via S8 SAG-968 &
rt 989 on 3/82, for the PAb, have not been evaluated or implemented
' t' j Dy tne structural oiscipline in the oesign of the PAB. This was verified by reviewing calculations PB-14 for Elev. 53'-0".
I$ B. Slab tnickness enanges at Elevation 25' in the Reactor J Containment Bulloing nave resulted in a slab weignt about 20%
larger than the weignt useo in the analysis. This weight increase has not Deen evaluated or implemented to cate oy SAG to l]j oetermine the impact on tne ARS and their use.
C. Appenaix F to tne Structural Design Criteria was issuea (draft)
{ for the cesign of ancnor ooits. Tnere are no systems or metnoos to track tne status of cesign review of all equipment founoations oesigneo prior to tne issue of this Appenoix. .This was verifiec C by reviewing one (1) foundation in PAB ouilding calculation JJ. #PS-51 for tank SB-TK-40.
, . D. The current ARS controlled document is Revision 5. Aoditional jl ARS nave since oeen generateo. MAG is committea to assess the impact of all AHS issued since Revision 4 for electrical tray ano conouit supports. Tnis effort is to start in January,1983, ano formal tracking of this effort is appropriate. .
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.J Construction Project PERFORMAtCE EVALUATIDN DETAILS Seabrook Station
,7 I Performance Area: DESIGN CHANGES 00jective No. DC.5 i
[j Otner Information That Supports he Summary
- 1. A major cesign maalfication to tne Unit I computer room air conditioning system was reviewed. The modification involvea tne
- 2 cesign and installation of accitional cooling equipment cue to revisec equipment requirements. Design enange cocumentation,
? incluaing drawings, applicable Engineering Cnange Autnorizations W (ECA's), calculations, ano corresponcence were reviewed anc found technically acequate. The scope of work was ciscussec with the r i Leaa Mecnanical Services Site Engineer anc the Responsible i Engineer at the home office. Responsiollities of each discipline
" were well-oefinea and implemented in a timely fasnion to meet a tignt construction schedule. Design Change Procecure #AP-15 was
' acnereo to. The coordination effort and final results were very
'a gooc, caseo on discussions in field and home office.
2. Several Engineering Cnange Authorizations (ECA's) were reviewea, jj All aispositions were tecnnically adequate, properly reviewea, approvec, anc incorporatec into. project accumentation.
Requirements of Procecure #AP-15 were also followed. Several
- Design Change Notices (DCN's) were reviewed. Preparation,
- review, approval, anc incorporation of these DCN's into final crawings meeet project requirements.
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'j 3. Tne aesigner from toe Site Support Engineering group wno was responsiole for incorporation of HVAC-relatrea ECA's ana DCN's was interviewed. Tne aesigner was knowledgeable aoout all aspects of the oesign cnange process. The metnou used to ensure
.s proper control anc timely incorporation of cnanges on documents was effective.
- 4. Several upgrace programs exist in the HVAC cis'cipline, including:
o A program to reexamine welas in approximately 600 auctwork
,' supports for unacceptacle uncercut with engineering disposition, as requirea.
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I ",I PERFORMAtCE EVALUATIDN DETAILS Construction Project Seacrook Station
i Performance Area: DESIGN CHANGES 00jective No. DC.5 U
"1 Otner Information Tnat Supports The Summary
} 'I o Upgrace of auctwork in several areas from Seismic, g Non-Safety Classification to Seismic, Safety Class 3.
. o Beam verification program for ductwork.
7 From ciscussions with responsiole engineers and review of sample
'{ ! cocuments, HVAC design personnel provice timely tecnnical response.
- 6. To evaluate now effectively oesign enanges are contro11ec, d several DCN's ano ECA's in tne I&C discipline were examinec. The
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cnanges were contro11ea in accoroance witn the GEDP-0032 and AP-15. Tne use of the forms and tne project log #4 appears to 3 acequately control design changes.
,, 7. Design Cnange totice (DCN) 63/0042A, "aca new MCC to Control blog., Elev. 21'-6"," was traced from first inoication of neea to
.ii final aisposition, an unaertaking covering approximately five (5) weeks. On 9/22/62, motors were aodea to the loao because of a
] client enange ano a meeting was nelo with affectea discipline, g On 9/27/82, a letter requesting client concurrence witn accing a new MCC on 10/13/82 (client concurreo letter 10/21/82). The DCN inter-discipline review was initiated on 10/15/82 and returned on i 10/22/82; purcnase requisition issuea on 10/22/82; tne DCN signed out on 10/27/82; and the incorporation of the DCN completed on 10/29/82. All steps were performed satisfactorily.
J There is a program for alerting all projects of innerent or generic proolems callec Electrical Tecnnical Bulletins. These may or may not ce incorporatec into existing procedures, spec
- [" guices, etc., out are availaole for reference as appropriate. .
Cooraination witn otner aisciplines is innerent within the DCN
. T ,t process as is tne consiaeration of cost & scneaule impact, J safety, ano quality.
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] PERFORMANCE EVALUATION DETAILS Construction Project Seabrook Station r1
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. Perfurmance Area: DESIGN CHANGES Objective No. OC.5 Other Information That Supports Tne Summary I.)}
- 8. ECA 73/3949A, requested a cnange in a base plate anc the location T! of tne concrete ancnors. PSG recalculatea the stresses in tne j plate ana tne ancnors and approvea the proposea change.
,+ ECA US-07982A & HF1 '760284A requestea by the field to allow acaitional single tubing in adcition to two (2) trays on Type R ll
' support for Control 8109. were reviewea. Tne necessary calculations were acequately performed.
fl Lj The cesign enanges were contrulled properly by the ECA procecure. The response was timely ano effective.
] 9. Various discussions were conoucted with the Nuclear Project Group (cotn Engineering ana Piping design), the Piping group, MAG, anc tne Site Engineering organization, incluaing a detailed review of
'l various DCN's, ECA's, and NCR's.
Except for weakness found as a result of vercal-unoccumented r, changes (see Finaing CC.4-6), it was concluced that oesign I, changes are properly nanaled anc occumentea. Tnis couplea witn tne various cesign verifications ano as-Dullt programs will ensure that final installations are consistent with, ana
. supportea Oy, the aesign documents.
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! PERFORMAtCE EVALUATION $UMMARY Construction Project Seaorook Station
- j Performance Area
- CONSTRLCTION ENGINEERItC ODjective No. CC.1
- q Evaluator (s) M. Whitelaw, W. Rotherforth, anc other team memoers
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] I. Performance OD.]ective Engineering and design performec under the authority of tne construction organization should be r:ontrolled as to consistency witn ylJ' tne casic cesign criteria to ensure compliance with applicaole coces, stancaros, ano regulatory commitments.
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1 y II. Scope of Evaluation n Tne evaluation of tnis area involved the review of applicable occuments lij (i.e., orawings, specifications, calculations, engineering enange l
autnorizations, requests for information) and procecures, a review of
, tne interface Detween tne construction management ano tne various
! contractors, and interviews at all levels with personnel from tne 4! Owner's Agent, tne Construction Manager, and the various contractors.
Tne evaluation incluceo essentially tne entire team at the joo site ano q requireo tne expenoiture of approximately 98 mannours.
E III. Conclusion 7
d In general, the activity evaluated unoer tnis Performance Oojective is satisfactory. Tnere is, however, an area of weakness relatea to r
contractor incorporation of design changes tnat neeos to oe j strengtneneo in orcer to provice greater assurance of acequate control of drawings usea for construction.
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b PERFORMAtCE EVALUATION
SUMMARY
Construction Project
(] Seacrook Station 1]
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Performance Area: CONSTRLCTION ENGINEERING Uojective No. CC.1 "I
ij IV. Areas of weakness & Corrective Action; Gooc Practices c Fincings Contractor engineering field change control does not
!)- (CC.1-1) always assure tnat engineering requirements (cesign cnanges) are incorporated into tne drawings usec for construction and final sign-off. A concern was identifiec
{j for construction aloes usec by the piping contractor ana
.a tne structural steel crection contractor (program for construction aices not yet approved).
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Corrective' For concerns regaroing construction aides usec Oy the Action Piping Contractor, refer to PS.6-1.
1 The Structural Steel Erection Contractor has ceveloped a program wnicn utilizes construction alces (weld maps) as part of the system for tracking the status of work in
,, process and final sign-off. The UE&C specification now allows tne use of tnese construction alces (composite
,, 1rawings) as a final checkout venicle. Tney will be so utilizea as soon as tne applicaule Contractor Procecure (AP lj 3.1) is approvea. This proceaure will incluae provisions to control tne incorporation of UE&C cesign enanges onto the construction alaes.
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-1 Ld-PEHFORMAFCE EVALUATION DETAILS Construction Project p) Seabrook Station Il Performance Area: CONSTHLCTION ENGINEERING Objective No. CC.1 Il
!J CC.1-1 A. For piping installation, tne contractor's erection orawings (construction aloes) are not acequately controlleo to assure that
-)i tney incorporate the latest revision or cnanges to the appropriate UEaC oesign drawings in a timely manner.
, _ , o when cesign cnanges or piping orawing revisions are
- } received from UE&C, the piping contractor prioritizes the
. J cnange for incorporation onto nis construction alces. The priority given to that incorporation may not coincioe with
,! tne priority of the area engineer in the work area.
o For a concern relating to the control of nanger installation drawings, refer to PS.6-1.
s B. The Structural Steel Contractor is presently developing a program
wnico permits use of construction aioes curing erection of structural steel. These aioes are not presently approveo for lj final sign-off. The presence of aides in the fielo raises tne concern tnat two (2) sets of crawings (aloes and UE&C crawings)
{,
are in tne work area. Since tnere is no apparent Control mechanism to incorporate UEaC oesign enanges onto the aloe, a concern exists tnat tne latest oesign information may not ce q,
consistently used for work activities.
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PERFORMANCE EVALUATION DETAILS Construction Project
(! Seabrook Station 5;
Performance Area: CONSTRLOTION ENGINEERING Objective No. CC.1 R
lj Other Information That Supports The Summary
,, 1. Tne UE&C site engineering group was recently expancea.
!I d 2. It was notea curing an interview with tne Systems Engineer that tne Site Engineering Library coes not contain many HVAC stancaras. l
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- 3. The HVAC support systems section of tne site Mecnanical Services engineering group seems to have an above average procecural i system for controlling engineering ana cesign processes. !
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- 4. Discussion witn site area engineering ano contractor engineering
^ personnel inaicate tne turn-around on ECA's is too slow, in many cases, to properly support construction. Tnis is discusseo ;
l j, furtner in Finoing DC.5-1. '
, 5. Site Fiela Engineering (UEaC) feels it is necessary to cevelop a i
a i process for more airect engineering resolution in tne fielo on major items, while running a eneck (ana processing the paper work) thru tne Home Office. Tnis is aiscussea furtner in Finding DC.5-1.
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- 6. Fielo engineers for Site Engineering'and the contractor felt that there were not enougn people in tne Philacelphia SSE group to i!
J efficiently do tne work.
- 7. The following samples of occumentation from the Mecnanical Services site engineering group were reviewea:
o Engineering Cnange Autnorizations (ECA's)
!n
'2 contractor-generated construction engineer / management-generated o Contractor Request For Information (RFI) o UEaC Fire Protection Reports (relative to HVAC items) w I
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b] PERFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station F1 Q Performance Area: CONSTHLCTION ENGINEERING Oojective No. CC.1 Utner Information That Supports The Summary ECA's anc RFI's prepared and processed in accoraance with r} applicaole proceoures, specifically Aoministrative Procecure U #AP-15.
- 8. A review of deficiency reports of the Piping Installation Contractor indicated no pattern of continuous repetition.
- 9. The Lead Meenanical Services Engineer, Leau HVAC Support F1 Engineer, and responsiole site engineers and designers witnin
~j tnese groups were interviewed. All personnel were found to De acequately qualified witn oetween 5 and 15 years of HVAC relateo t
experience. These personnel cemonstrated that change control is maintained and implemented in a timely manner, witnin procedural constraints.
'l 10. Tne Lead Hecnanical Services Engineer provideo a summary of ij guicelines usea in performing work within tne Site Mechanical Services Group. Tne guidelines provice useful information wnicn
,- ) effectively oescrioes responsioliities ano interface requirements i ; and guicance relative to use of aesign criteria.
- 11. The following samples of occumentation were reviewea at the site
- l Mecnanical Services group office
1 o Contractor-generated Request For Information (RFI) l- 0 Engineering Cnange Authorizations (ECA's) o UE&C's Fire Protection Report The ECA's and RFI's were properly prepared, reviewed, ano jl approvea in accorcance witn Aaministrative Procecure #AP-15.
.a Problem resolutions anc reviews were satisfactory. It was notea tnat UE&C nad accressed HVAC consicerations in tne fire report j>
accressing 10CFR50 Appendix "R".
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PERFORMAtCE EVALUATION DETAILS Construction Project Seaurook Station r;
1 U Performance Area: CONSTRtITION ENGINEERING Objective No. CC.1
- j. Other Information Tnat Supports The Summary
- 12. Conduit supports are located in the field by the contractor.
Supplementary steel, if requireo, is erecteo oy the contractor 1 ]2
. and an ECA is issued snowing location of supplementary steel.
Stanoard support types are used by contractors to cetermine beam
.; sizes. Tnis supplementary steel is eventually snown on i
i structural crawings when tne ECA is incorporateo. Field engineers are requireo to verify use of correct type of support ano size of supplementary steel.
,j An ECA giving supplementary steel information to the nome office was revieweo cno founo to be satisfactory.
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PEHFORMatCE EVALUATION
SUMMARY
Construction Project n Seacrook Station lU Performance Area: MATERIAL CONTROL Oojective No. CC.3 r
}l Evaluator (s) D. Hoisington, C. Asnton, R. McMellon, B. Gatlin .
r; lJ 1. Performance ODjective Material and equipment snould be inspected, contro11ec, ano maintainea i l to ensure the final as-ouilt conoition meets cesign ano operational 1- requirements.
T1 tj II. Scope of Evaluation i
The evaluation of tnis area involved the following activities:
o Review of applicaole procecures.
- ]i' o Observations at the site of in-place installations, faoricating facilities, bulk storage, warenouse storage, storage in work areas, ano nanoling Oy craftsmen.
l"f o Interviews /ciscussions with personnel at all levels of responsiollity from the Owner's Agent, the Construction Manager, ano the various Contractors.
U tj o Review of cocumentation (i.e., completeo construction process f arms, inspection reports, orawings, equipment maintenance files F' ano reports, engincering change autnorizations, ano
[ non-conformance reports).
, Tne evaluation included tne entire team at the joo site anc requireo lj L.
the expenoiture of approximately 110 mannours.
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, III. Conclusion i
Tne activities evaluated unoer tnis Performance Oojective were, for tne f, most part, satisfactory. Tnere were two (2) " Good Practices" ooserved, I
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namely the assignment (full time) of an indivicual to monitor all equipment on the site for cleanliness control and tne very professional manner in whicn the site central weld rod station is maintained oy the i ', Piping Contractor. Areas of weakness icentified include security in
'j tne oulk storage areas, storage of piping materials within the permanent plant structures, bulk storage of HVAC equipment, the limitec space allocated to the HVAC Contractor, and storage in the work areas.
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O d 1 PERFORMAtCE EVALUATION $UMMARY Construction Project '
[} Seabrook Station Performance Area: MATERIAL CONTROL Objective No. CC.3 C
ij IV. Areas of weakness & Corrective Action; Good Practices r1 Fincing Tne following Gooc Practice was notec. An indiviaual is
]j (CC.3-1) appointed by tne construction manager to specifically monitor cleanliness of in place equipment, including piping. This practice ennances tne protection of equipment
{a -j tnrougnout tne construction process from the effects of temperature, numialty, ano dirt.
.r' Finoing Tne storage of material and aquipment is not always con-
. (CC.3-2) trolleo effectively to preclude camage or improper application. This is eviaenced by identification of
!qi several cases of inacequate storage area or use tnerof, anc questionaole practice regaraing separation of material (ASME III vs. non-ASME III) storea in work areas in the permanent plant structures.
/J Corrective Acoltional HVAC site storage area is Deing maae avail-Action aole to ease tne present congestion insice tne snop.
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i All storage areas of permanent and plant material and
., proper energizing of motor heaters are routinely monitorec j, ano any occasional unsatisfactory conaitions that exist are
') promptly corrected.
- q. The recommendeo segregation of ASME III material will De
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completed by Novemoer 30, 1962 anc witnin two weeks tnereafter, all otner safety-related areas will be investigatea ano corrective action initiated as requireo.
ll Finoing Tne following Gooa Practice was noted. Weld roo material
- (CC.3-3) is issued to most site contractors oy the piping 9, installation contractor, from a central location. In acoltion to security advantages, tnis enhances control of issuance of correct material to the welaers. Tne area was l maintainea by personnel wno were knowledgeable ano aware of
- - operational procedures. ..
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PERFORMAtCE EVALUATION DETAILS Construction Project I Seaurook Station
[J Performance Area: MATERIAL CUNTHUL UDjective No. CC.3 9
I CC.3-1 UEaC nas a cesignatec cleanliness cooroinator who is dedicated to g monitoring equipment protection ano system cleanliness auring construction. This is a good practice.
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o Tnis inoiviaual tours tne entire site looking for sucn
" tnings as uncapped pipes, hazarcous or airty operations
{";! aajacent to equipment, or any condition wnicn coula compromise system operacility.
U If a He notifies appropriate area supervision of unsatisfactory conditions and follows up to insure correction of tne proolem.
^t i; o A tour of tra: site with the cleanliness coordinator inoicated that tnis job is performed in an orderly ana
,, effective manner. Problem areas related to equipment jj protection were encountered ano appropriate steps were taken to correct tne situation.
CC.3-2 A. The facilities provicea to tne HVAC Contractor for prefaorication
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activities anc temporary material storage are cramped and cause concerns regarcing efficiency ano safety of tne prefaorication
,p operation.
o A review of tne HVAC Contractor's prefabrication facility was performeo. It was notea tnat the building was crampea l, and congestea. Ductwork ano hanger prefaorication are cotn
... performea in tnis snop. welaing, grinding, ano assemoly operations were performed in close proximity to eacn other, with limited personnel protection. Safety nazaras from lqJ flying metal cnips ana welding areas were.evicent.
, o Limited storage area exists for partially or fully complete t work items. Several pieces of ductwork anc hangers were J temporarily placed on tne floor or in a small storage area, causing acaec congestion ana safety nazaras.
I ts . Material ano equipment storage, hancling, ano security in tne outsiae HVAC storage area are not adequate 1*y controlled to protect items from camage, contamination, or tampering.
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D li PERFORMAPCE EVALUATION DETAILS Construction Project Seaurook Station b Performance Area: MATERIAL CONTROL Objective No. CC.3 e
l] CC.3-2 o Several pieces of prefabricateo HVAC ductwork assemblies and nangers were storea out of ocors, without proper coverings or security measures. Several cuctwork pieces I were stackec upon eacn otner ano some were damagec. Rust (J was evicent on many nangers. Cartons containing small auctwork access coors were oroken with contents strewn on
] the ground.
O Tne storage location was protected by a ropeo off area, for p security. Tampering or unauthorizea removal of materials
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is possiole.
C. Storage of permanent plant material on site is not always
'i acequate to protect material.
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o Reinforcing steel ano emoea plates were off cunnage in numerous storage areas.
II o Reinforcing steel and other material stored close to roacways are splasnea with large amounts of muc. Little f
effort is made to eliminate tnis situation ano Q.C. no longer ioentifies cefi.ciencies in tnis area.
- , D. Piping materials are being stored within the permanent plant
" builoings witnout acequate regara for separation of ASME-III material from non-ASE-III material.
L], o At elevation (-7'), in the Primary Auxiliary Builcing, ASME-III material and non-ASE -III materials are stored intermixed on the same snelves.
{"q o The area around the component cooling water pumps in the u11t-1 PA8 is extremely congested witn piping material, ano
,, no attempt nas been made to separate ASME-III material from i ,
non-ASME-III material in the pipe rack near the component L1 cooling water pumps, r.
O The upper elevation of the North RHR neat exchanger cuoicle
" nas ASE-III ano non-ASME-III pipe, valves, ana fittings mixec and storea togetner.
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PERFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station
-k3 Performance Area: MATERIAL CONTROL Objective No. CC.3
'b ;; CC.3-2 E. On-site outdoor storage areas are not being controlled as requireo Dy ANSI stancaras.
h o ANSI Standara N45.2.2-1972, Section 6.2.1, states tnat
" access to storage areas snall be contro11ea and limitec l only to personnel designated oy the responsiole 7 organization.
'j o There is no metnod to control access to the outsioe level 0 g storage areas. Anyone acmittea oeyono tne access road gate iLj , coula enter tne outlying storage areas, o One contractor proceaure wnien was reviewed specifiec a
,n rancom cna11enge program to control' access. During tnis
j evaluation the evaluator was not challengea, nor was anyone else observed being challenged.
i F. During a walk-tnru in the PAB, it was notea that motor heaters
'l I for 1-CC-P-llB & 1-CC-P-11D were energizeo and those for 1-CC-P-llA & 1-CC-P-llc were not energized.
-b o Most motor heaters in the Equipment Vault Builcing (North),
on large motors, are not energizea (charging pump motors, RHR pump motor, and many large valve motors).
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o Suosequent investigation indicateo the above condition may nave oeen the result of the temporary outage of certain
, j, electrical circuits.
a CC.3-3 Aooitional cetails are not requireo.
Ii Otner Infonnation Tnat Supports Tne Summary a>
l, 1. The UEaC receiving program was reviewea and ceterminea to be J effective in properly receiving, ioentifying, and storing material ano equipment. The manufacturer's requirements are loentified prior to receipt ana storage level is determinea for
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eacn piece. .
- 2. Equipment location ana inspection status is kept in a file ano
.},[ also entereo into a computer. Tnis system proved to be effective.
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.J PERFORMAtCE EVALUATION DETAILS Construction Project q Seabrook Station Performance Area: MATERIAL CUNTHOL Objective No. CC.3 n
lJ Otner Information That Supports Tne Summary Fi 3. Personnel interviewea expressed an uncerstancing of tne program j -
requirements anc were properly implementing tnem.
4 Small items on hold were kept in separate nola areas wnile larger items on hold are identifiea by nold tags.
- 5. Tours of storage areas on site snowed tnat material was properly r;
storeo on ounnage marked ano segregated, with the exception of the Finaings in CC.3-2.
, 6. A tour of tne off-site storage area in Newington, where a large i amount of NSSS cumponents are storec, snowed tnat equipment was J
storea properly on dunnage, with some enclosures protecting Level D storeu equipment. Level B ana C areas, at tnis facility, afforcea proper protection, temperature and numioity control, ana jj access control tnrougn lockea oullaings.
,, 7. On-site Level A, B, a C areas were lockea with access control J
- witn a log for visitor sign-in. Badges were issuea to visitors so autnorized people could be readily ioentified. Temperature ana humioity controls were acequate to meet equipment ll; requirements. All storage areas observea were clean ana well maintainea.
p; 8. Storage by contractors in permanent plant bullaings was less
" contro11ea and, in some areas, was marginal in keeping material ,
out of walkways. Some aiscrepancies were oc;ervec in tne area of
,_, equipment protection, but tne program in place, wnereby the i
cleanliness coorainator tours the areas, nas oeen effective in U minimizing these and proviaing timely correction (see Finaing CC.3-1).
cn "j 9. There is an acequate preventive maintenance program in place in wnich vendor requirements are icentifiec, placed in folaers for ri each piece, ano also notea in a cara file with frequency i requirenents. Tne cara for each week laentifies what maintenance is aue on each piece of ecpipment. This group 14 responsible for ensuring neaters in electrical equipment are energized; however,
, several pieces of equipment in the PA8 ano equipment vault were
_. observea with tne inoicator lignts out.
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PERFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station t_f Perfomance Area: MATERIAL CONTROL Objective No. CC.3
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Otner Information That Supports The Summary ,
- 10. It was icer 'ied to the evaluators tnat the piping contractor
.b, had instali s some spool pieces and backfillec over them wnile
.i; tney were on nolo Oy UE&C. Since tne UE&C QA program is tracking the proolem, no furtner review was undertaken in tnis evaluation. Tne response to the corrective action request was
[n not availaole from tne contractor, so tne effectiveness of tneir action coula nut be assessed to cetennine if tne proolem is
- generic. '
L .s 11. A tour of.tne caten plant snowea that material receipt proceoures ano storage facilities adequately controllec receipt ano storage r of oaten plant material. Interviews witn UEK ano contractor
- j personnei incicated tnat tney uncerstood requirements ana were properly implementing tnem.
- 12. The following catch plant recoros were reviewea:
o NRKA cnecklist F o Calloration aata sneet (j o Form CT-13 o PTL QC-FSTC-1 o Drum 81 ace Wear Sneet All indicated tnat the cnecks and verifications were performed ana recorced at proper intervals.
lj 13. The HVAC contractor's shop faorication facility was reviewed.
welding, grinding, anc fabrication operations for assemoly of q ouctwork and nangers were witnessea. In spite of limited space jj availability identifiea in Fincing CC.3-2, the work process was observea to De well plannea and perfomea. Flow of material ana
,, inspection of work in process was well controlled. Personnel j morale was very g000.
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- ii 1J PERFORMANCE EVALUATION
SUMMARY
Construction Project n Seacrook Station
.I "sl Performance Area: CONTROL OF CONSTRUCTION PROCESSES 00jective No. CC.4 I'
'l' Evan,ator(s) R. McMellon, C. Ashton, G. Rearoon, D. Holsington, M. Wnitelaw, W. Rotherfortn, A. Cooper, A. Colello f
'o I. Performance Oojective 1 The construction organization snould monitor and control all j construction processes to ensure the project is completed to design requirements anc tnat a nign level of quality is achievec.
Tj II. Scope of Evaluation 7 The evaluation of tnis area involved the following activities:
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o Review of appliccole proceoures of tne Owner's Agent, the Construction Manager, ano all Contractors on the site.
1] 0 00servations at tne site of all Contractors in the performance of tneir various construction processes.
J o Interviews /cis;ussions witn personnel at all levels of responsioility from all organizations on tne site.
o Review of occume ntation (i.e., completed and in-progress construction process forms, inspection reports, crawings,
,. specifications, performance reports, non-conformance reports, ana l}
LJ engineering enange autnorizations).
Tne evaluation incluceo tne entire team at tne joo site anc required tne expenoiture of approximately 305 mannours.
{qJ III. Conclusion U Most of the activity evaluated under this performance oojective was generally satisfactory. There was one " Good Practice" coservec wnicn 1 involves tne metnoo used to locate rebar witnin completed concrete
,a structures. There were several areas of weakness identified effecting supervision of work, ceviations from approved procedufes, availaoility
,3 of necessary tools, ano possioly excessive inspections, i!
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!I 1J PERFORMAM'E EVALUATION
SUMMARY
Construction Project Seacrook Station p
jj Performance Area: CONTROL OF CONSTRUCTION PROCESSES Objective No. CC.4 IV. Areas of Weakness & Corrective Action; Good Practices Fincing The guicance proviced during work assignments 1 (CC.4-1) by the Piping Installation Contractor fails to provice
- ~ acequate instruction and aetail to assure efficient completion of the work effort. This is supported by the f, ocservation of craft personnel requesting anc receiving
]"j cirection from QA/QC personnel regarcing performance of work activities.
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,_ Corrective As was pointea out in the response to 0A.3-1, tne Piping Action Contractor is presently niring more Field Engineers wno e, will aid craftsmen in the sequencing of welos ana/or general installation of piping systems oy work packages.
Tne referenced Hilti Instruction (FI-177) is a contro11ec,
.' l nanowritten instruction ano is used for Hilti bolt 1j installation until Project Proceaure IX-1, Rev. 13 is approvec. Project Proceaures are referenced on all prut.ess sneets and are availaole for craft use.
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_ Finding A concern was laentifiea with the metnoo of acceptance l (CC.4-7.) of work performed by the Piping Installation Contractor.
.J This is evioenced by the duplication of in-process Q.C.,
engineering, and final Q.C. Inspections for pipe support
'r installations. This method ooes not provice for timely completion of the work effort. Proper planning, supervision, and in-process inspection should ennance acceptance of completea work, rather than auplication of post-installation inspection efforts.
n Corrective Reference Corrective Action 0A.3-1.
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, PEHFORMMCE EVALUATION
SUMMARY
Construction Project Seaorook Station Il
.] Performance Area: CONTROL OF CONSTHUCTION PROCESSES 00jective No. CC.4 n
lj IV. Areas of weakness & Corrective Action; Good Practices
] Finaing Construction activities are not always performed in
- . (CC.4-3) accorcance witn approved work proceoures. This was notea curing installation of Hilti bolts oy several site contractors.
L Corrective All Contractors' Hilti proceoures have been reviewed C Action oy Project Engineering and found to De satisfactory.
J Seneoulea training sessions will De strengthened, employing uniform metnocs and teacning aides to instruct all affecteo
- craft personnel in tne proper implementation of tne procedures.
It i1 Finoing Tne following Good Practice was noted. UE&C personnel n
(CC.4-4) locate reinforcing cars for all contractors to minimize the incidence of reinforcing bar interference during hole
,J, arilling operations. The personnel are knowledgeaole, the equipment of good quality, and the program is successful.
"I d Finoing Proper tools are not always availaole wnen requirec to (CC.4-5) assure timely completion of tne work effort. This is Tl evloenceo oy several cases of equipment unavailaoility or
_j use of improper equipment.
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Corrective The Contractors are constantly reviewing tool inventories Action and oraer required tools on a aaily casis. The concern will De furtner investigateo oy the Contractor's Construction Superintendents.
a Apparent misuse of a grinaing tool was caused by tne r development of an unexpectea proolem. The foreman has been 1; instructec to requisition ana have available proper touls for whatever conditions may exist. .
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- J PERFORNAtCE EVALUATION
SUMMARY
Construction Pro,)ect Seabrook Station
, Performance Area: CONTROL OF CONSTRtETION PROCESSES Objective No. CC.4 n Areas of weakness & Corrective Action; Good Practices
!j IV.
"I Fincing Construction activities are not always performed in accor-
! (CC.4-6) cance with tne current revision of crawings approved for construction. A situation was discoverea wnere work was
- oeing performeo using a nanawritten annotateo crawing without evicence of an official design change cocument "l
1 (ECA) or Request for Information (RFI).
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'3. Corrective The Piping Contractor will reinforce the program require-Action ments tnrougn a airective to tne Fielo making it uncerstood tnat cnanges to cesign cocuments or ceviations from f' ', proceoures and/or UE&C specifications are not permittea witnout official aesign change cocuments.
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PEHFORMAtCE EVALUATION DETAILS Construction Project y Seacrook Station Performance Area: CONTROL OF CONSTHLCTION PR0' ESSES Objective to. CC.4
[' J CC.4-1 A. The Piping Installation Contractor's pipe support installation proceoures ao not provice acequate oetail (e.g., work sequence,
_ tecnnique, etc.) to insure timely ano quality construction.
t; o Each pipe support installation job nas an associated work instruction package tnat typically consists of a pipe support arawing/ isometric and applicaole process sheets.
Process sneet usage is defined in Spec. JS-IX-6. Tne most commonly usea process sneet for pipe supports is Form 19C (wela process). However, Form 19C does not provice a sequence of work to ce performed but, insteau, relies upon a the worker's experience and judgement to properly ano efficiently sequence the work. The need for a work m
sequencea process sheet oecame apparent curing an l '. ooservation of installation work for pipe support 797-SG-05/5A ( ASE Class 3) in tne PAB. This particular s
support required over 500 field welas, yet tne associated wela process sheet did not sequence the work. Insteau, the process sneets listed the fiela welos in a numerical
~t sequence that nad no relationship to the assembly sequence. Proc. JS-IX-6, Section 6.4.1, allows for this
, witnout regara to work sequence. Observed eviaence of tnis situation was noted oy ranoom completion or partial completion of the work package wela process sheets (Form a
19C). Tne aoove approach (work sequencea process sheet) requires careful planning by the workers prior to job initiation, to avolo fit-up problems later on. Since the 1
leaa hanger engineer initiates all process sheets, it woula
,.; appear prucent to apply tne Joo planning (ie., work sequence) at tnis stage, via the wela process sheet ratner 3
I than ourcen the worker curing tne installation pnase. As an acaea note, tne installation effort for pipe support 797-SG-05/5A cegan approximately two months ago and current completion is estimated at 50-60%.
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M d' PERFORMMCE EVALUATION DETAILS Construction Project Y
,_, Seabrook Station
'J' Performance Area: CONTROL OF CONSTHUCTION PROCESSES Objective No. CC.4 n
y CC.4-1 o Sub-process sheets (e.g., expansion anchors, snuboers, sway struts) generally provice a sequence of work but s'ometimes lack sufficient cetail to effect a quality installation.
p' Tnis situation was coservec ouring expansion ancnor L installations for pipe support 879-SG-201R (WS-1) in the Pfe. In tnis instance, tne process sheet sequences the n work but dio not detail the technique that should be useo
_ for ancnor installation. Instead, the workers refer to a nandwritten, uncontrollec instruction for Hilti q installation.
L o As noted in OA.3-1, Item A, the workers stated that they
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rely on tne in-process Q.C. Inspector for work cirection.
This is further evicence that proper guicance is not proviced to tne craftsperson.
, CC.4-2 A. The Piping Installation Contractor's procedures governing Q.C.
i inspections ano engineering verification of pipe supports results in an excessive cup 11 cation of work. These prtcedures are not reviewea by UEaC to ceteImine acceptability, r!
L o Procedures JS-IX-6, VI-4, and X-4 all contain information regarcing tne requirements for inspections / verification of p pipe support work. However, a recent "oraft proceoure", in
.j response to UE&C Proceoure AP-39 for as-built drawings, entitled " Acceptance, Preparation, and Issuance cf Certified Pipe Support As-Built Drawings" summarizes, in U cetail, tne inspection / verification responsiollities of d botn contractor Q.C. and engineering. This " craft" identifies cuplication of inspection / verification work that f- is excessive. The " craft" has not been reviewed by UEaC b] for appropriateness of the inspection / verification auplication. Because of a moalfication in Revision 3 to
,; UEaC Procedure AP-39, Section 4.2.2 now requires the
!' contractor to cevelop a mentoo rather than a proceoure.
LJ UE&C coes not review ano approve contractor metnoos.
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l PERFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station Perfomarce Area: CONTROL OF CONSTRUCTION PROCESSES Objective to. CC.4 r-
- , CC.4-2 o The duplicative inspection / verification effort detailec in the draft metnoc is intencea to recuce the nign rate of rejection of pipe supports experienced curing the final G contractor Q.C. inspection pnase. However, the Q.C.
- records indicate tnat tne root cause of tne proolem is aue to poor in-process contractor Q.C. inspections. The duplicative final inspection and engineering verification effort will not improve upon tne root cause problem wnien
'J occurs during tne work process.
"l o The Piping Contractor recognizes tne root cause problem anc
. _ . is taking corrective action by retraining in-process inspectors ano attempting to nire accitional qualifiec in-process inspectors. However, Q.A. cocumentation i indicates tnat poor in-process ontrol has been an .
icentified proulem since January,1981.
CC.4-3 A. Observation performec 10/27/82 on the installation of four (4) 1" alameter Hilti Dolts, by the Piping Installation Contractor, incicated tnat tne top of tne bolt is generally below the top of tne nut, prior to torquing tne colt. This was a violation of the j work process sneet in tne work package that requireo that the top of tne colt and the top of tne nut De flush prior to torquing.
, The process sneet was incluceo in procecure OX-IX-6, entitlec
, " Installation and Inspection of ASME Section III Component d
Support ana NNS Critial Plus NNS-1 Seismic Supports". The process sneet was entitled " Expansion Anchor Process Sneet".
~1 Training sessions were attenoeo in which the workers were instructea to maintain the nut flusn with the neaa of tne colt prior to torquing. UEaC Specification 18-17 requires tne top of
, oolt ce flush witn tne top of the nut prior to torquing.
- b. An observation perfomea 11/4/82 on the torquing of two (2) 3/4" diameter Hilti colts, by the Instrumentation Contractor, indicatea tnat the Q.C. inspector aid not check to cetermine if
, the top of tne nut was flusn with tne top of tne colt prior to torquing. The wrencn was removed anc it was found that the bolt extendeo beyond tne nut. The bolt was ariven flush prior to
. torquing. For the first colt, wnich had already been torqueo, it was not possiole to determine if the same problem was encounterea. Tne contractor procecure and training, as well as the UEaC specification 18-17 requires the top of the ooit to De flush witn the top of tne nut.
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'j PEHFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station Performance Area: CONTROL OF CONSTRUCTION PROCESSES Objective No. CC.4
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CC.4-4 UE5C nas instituted a program to locate recar prior to drilling into reit:fGrcea concrete. Tnis is a "Gooo Practice".
- p o The pro; ram consists of a procecure wnicn covers use of L radar recar cetectors oy UE&C tecnnicians wnose sole function is to locate reinforcing steel for all contractors p prior to orilling into tne reinforceo concrete surface.
O The racar rebar cetector is a " State-of-tne-Art" piece of
-, equipment wnien locates recar more accurately tnan any
- otner commonly usea piece of equipment, a
o Records kept on success rates snow a 75% success rate inside containment ano an 88.5% success rate in otner areas.
-,' CC.4-5 4. Tool availaoility was inacequate for Pipe Support Installation Work in the pac.
o Several pipe support installation workers statea tnat tne store-room frequently "ran out of tools". Because tools are enecKt:c out/in on a cally casis, the workers try to get
- to the store-room "early", Defore " tools are gone".
o once tne store-room supply is gone, tne job is celayeo U while a worker cnecks tne area to locate and corrow a
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neeced tool from another work team. This practice was observea on several occasions wnile making observations of R pipe support installation work during wnien other craftsmen a woula stop by to corrow tools, n 6. Concrete pumps were inoperable ana unavailaole, for several lj scneaulea concrete placements. A caaweld crew nad to borrow a pouring basin.
f, C. Apparent misuse of tools was observec when a worker was using a
!J grincer to cut a web section from a structural beam to provice clearance for a pipe support to be installea. He usea a 1' mini-grincer for tne effort wnich took excessive time. This
. coula also be symptomatic of lack of proper tral,ning or supervision (see TN.3-1). .
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.3 c, PERFORMANCE EVALUATION DETAILS Construction Project Seabrook Station J
Perfomance Area: CONTROL OF CONSTHtrTION PROCESSES Objective No. CC.4 b CC.4-6 A YAEC Q.A. surveillance of the Piping Installation Contractor's e, activities curing a pipe nanger installation was observea. The YAEC Q.A. engineer reviewea tne procedure with the observer, and proceecea LJ to perform tne surveillance utilizing nis enecklist and the document package for tne Joo. All items were checkea off satisfactorily on tne cnecklist. Altnougn the surveillance was accomplisnea per the Lj prescribec cnecklist, tne Contractor's Q.C. and YAEC's Q. A. personnel involvea were not effective in implementing the Q. A. program r, requirements, as evicenced below.
J o The YAEC Q. A. Engineer was not overly concernea that tne working arawing incluceo a nanawritten note, wnen tne F" evaluator asked several questions about tnis practice, the
- Q.A. Engineer indicated we coulo check with the Piping Contractor's engineering aepartment.
The non-conforming condition dealt with a plate on the restraint which was 5/8" off location.
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[' Subsequent investigation witn tne Piping Contractor's engineering cepartment indicatea that neither an RFI (Request For Information), ECA, nor NCR had Deen written, r' The YAEC Q.A. Surveillance Report on this activity is
,; Q.2.6.14.3206 catea 11/2/82.
4 o An NCR was subsequently generated to stop the work.
4 However, it is not known whetner tnis problem existea for Ls previous work witnout Deing identified by QA/QC personnel.
B. The Piping Contractor's engineering cepartment was asked wnether
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j', the above practice was allowea by proceoure. They indicated tnat a formal enange notice shoula nave been processeo prior to performance of work. In any case, engineers are not permitteo to i make fiela enanges on items similar to tnose loentified above.
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PEHFORMAtCE EVALUATION DETAILS Construction Pro)ect
' , ,i Seacrook Station LJ Perfomance Area: CONTROL OF CONSTRlETION PROCESSES Ocjective No. CC.4 l
J Other Infomation That Supports Tne Summary
- 1. HVAC Contractor -
o A field inspection of various Unit 1 ouilding areas was
'l conoucted by tne UE&C HVAC construction supervisor. The i!
areas covered includea the Containment, Primary Auxiliary Builoing, Control Builaing, anc waste Disposal Builcing. ;
The HVAC installation is approximately 40% conGlete '
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) according to tne supervisor. He also indicatea tnat significant delays are occurring due to major design cnanges ano delays in processing ECA's. The time requirec j' to obtain resolution to field problems averaged j approximately 4 weeks. The general quality of the work ooserved was gooa.
o Discussion witn the UE&C Construction Manager indicatea tnat tne previous HVAC contractor was replaced due to inaaequate performance anc inacequate controls ano quality programs for nuclear work.
O Tne HVAC Contractor's revisea quality assurance manual ana relatec construction, aaministrative, cesign, anc quality i assurance procedures were reviewed. Tney were revisea to be consistent witn the new contractor's operations. The new proceoures were found to be satisfactory ano shoulo provice tne means to implement g000 quality HVAC work.
._ Discussions with the QA managers on site confirmea tnis observation.
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o Several randomly sampled Non-Conformance Reports (tCR's),
Material Receipt Inspection Reports, hanger and ductwork
, installation packages, and YAEC survelliance reports were reviewed with tne HVAC contractor Quality Control Supervisor. Material receipt inspection reports and installation packages were thorough and complete. This
") conclusion war confirmed oy the surveillance reports.
J Control and disposition of NCR's may be a proolen area, as ciscussed in Finding QP.1-). ..
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4RF0ktWCE EVALUATION DETAILS Construction Project y Seabrook Station i ..
LJ ! Performance Area: CONTROL OF CONSTRUCTION PHUCESbES 00jective No. CC.4 b' Otner Informai.icn That Supports The Summary
- 2. Electrical Contractor -
" o The Construction Manager (Electrical discipline) was interviewea. It was evident that ne was familiar witn the
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applicaole procecures and processes governing his work. He aisplayea an awareness of ongoing costs ano scheoules. His relationsnips with Site Engineering contractors anc nis own rq personnel seemec efficient and procuctive.
d o Tne Site Engineering Leaa Discipline Engineer (Electrical) was well qualified for nis position. He was conversant
]. witn tne proceoures, incluaing tne latest revisions, that j affect nis work. Both ne anc his people attend training courses regularly ano seem to De performing acequately.
o It was observed that instrumentation caule crums are being stored insice tne control Duiloing, out the storage area is neitner marked nor roped off.
. o Tne Electrical contractor nas an acequate system for controliing and calibrating tools and test equipment.
o The contractor's program incluces ongoing training programs for QC inspectors, with good attendance at meetings.
o The Turnover Supervisor nas oeveloped a system for tracking
- progress ana inspection of cable trays casea on the CASP system. The system uses sepias to mark up the status of
] caole tray noces (hangers, bracings, grounding, etc.). The j sepia is kept up to cate ano can eventually be used as tne "as-ouilt" sepia. Interim ana final prints can De cotainea reaolly. Information is then usea to check off the status
. of suo-groups in BIP's. Double entries on computer read-out sneets provice aoaitional information or reasons for current status. Tnis metnod was effective for tracking cable tray status.
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.o PERFORMAtCE EVALUATION DETAILS Construction Project
-, SeaDrook Staticn I
Performance Area: CONTROL OF CUNSTHUCTION PROCESSES Uojective No. CC.4 il
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,. Otner Information That Supports Tne Summary rr. 3. Civil / Structural Contractor -
b o Tne UEaC Civil / Structural superintendent and concrete supervisor were interviewed and founa knowleogeaole of
' requirements. The concrete supervisor has tne
!- responsibility to select tne concIete mix aesign caseo on conaitions, i.e., recar and embed congestion, type of r# equipment used, pump, oucket, etc. The engineers specify y cesign strengtn. The use of superplasticizer ana mixture is a good way to minimize concrete voids and is usea 40% of q tne time.
d o The backfill program was reviewed and the backfill supervisor was interviewec. Procedures are ceing followea n and storage requirements are being met. The testing agency L cnecks in place censity on the 2nd lift and takes samples from the first lift to run a one point proctor test for use on the next in place censity test. This method minimizes
- p ,l in place censity measurement problems due to slignt non-uniformity of material as placed. Tney are successful in acnieving tne 954 compaction requirement. The equipment
[lLj used was acequate to efficiently place and compact tne structural backfill.
, o The testing laboratory was toured. The personnel were
~] qualified and tne facilities acequate to perform tne requirea testing of concrete, reinforcirg steel, and cackfiil.
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PERFORMAtCE EVALUATION DETAILS Construction Project
] Seacrook Station ,
Performance Area: CONTROL OF CONSTRLETION PROCESSES Objective No. CC.4
~1 U Other Information Tnat Supports The Summary 4 Installation of Component Supports -
o Construction activities in the pipe support area are identified in aavance. The Piping Installation Contractors
, process for installing pipe supports in the PAB was
' reviewec. The field engineer explained that by using the 12 montn and 12 week look aneaa seneaules issued by UE&C,
[] and Dy closely coorcinating with UE&C's Construction y Management, he issues crawings and material for pipe support work. The field engineer, after walking cown the system intencea to De workeo on, oevelops job instruction
.U packages for eacn pipe support. Joo instruction packages
() were ooservec to contain insufficient cetail to ensure timely ano quality construction. Tnese job instructions
"! are useo oy work teams (typically one welaer and one J pipefitter) to ootain necessary joo materials and guice tne installation activity. The concern regarding insufficient r, detail is sumarized in Finding CC.4-1.
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o The current drawings ana latest specification revisions are r, being used for construction, except as noted in Finding
_, PS.6-1. In one instance, it was noted that the process L; sheet for Hilti bolt installation was not being followea (see Fincing CC.4-3).
," o The contractor has a system establisnea to control rework activities. No specific coservation was maoe in tnis
., area. However, a review of the QA records iruicates that
- the rework is oeing contro11ea. .
o Tne pipe support work in the PAB is being performed witn
- minimal supervision. Tne pnilosopny is to issue the work
_j ptickage ano let tne craftsman work at their own pace.
However, some work teams have limited experience with nuclear work and turn to the QC inspector for job guicance
{ (see Finaing 0A.3-1). ,
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- J PERFORMAtCE EVALUATION DETAILS Construction Project Seaorook Statica t
Performance Area: CONTROL OF CONSTHLCTION PROCESSES Uojective No. CC.4
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[1 0 Tools were coservec to De in limitea supply. Frequent ana, 1 in some cases, extensive joo celays result. Many of tne workers complainea about tnis situation (see Finaing
. c. CC.4-5).
L 5. Installation of Major Equipment -
1 o Construction activities relatea to installation of major
_j equipment are identified well in aavance to allow for adequate preparation ana staffing for tne joo.
r ll" } o The contractor's effort in erecting the refueling water storage tank was reviewea. The Construction Superintencent snowed evidence that tne tank erection schedules nad oeen
[] forwaroea to UE&C well in acvance of tne joo initiation.
J Tne seneaule was then factorea into UE&C's 12 montn integratec construction scneaule wnicn gets wide
.n distrioution. As the jou neared the schedulea start cate, I 'i a 12 week look aneaa scneaule issuea Dy UE&C provideo furtner advance notice to all concerned that final r, preparation for this job must be completed. The 12 week
, look anead seneaule also signals the UE&C Constructicn
- J Management Group to begin close job coordination with tne contractor. The Contractor Construction Superintencent snowed eviaence tnat tne tank joo had been addea to tne 12
-"'! week look ahead sCheaule. All site Contractors ana UEaC Construction Management groups receivea tne 12 month ano 12
.. )
week scneaules that iaentify all site work activities.
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a o Contractor work procedures and drawings aisplayea acequate aetail to meet UE&C's engineering requirements for the
.;} refueling water storage tank (1-CBS-TK-8). The proceaure I!
" cetailed ana sequenced tne tank erection work. This worx sequence cannot ce osviated from without QA approval. All
., tne procedures ano crawings reviewed for the tank erection haa Deen reviewea ano approved by UE&C.
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PEHFORMAtCE EVALUATION DETAILS Construction Project
.q Seabrook Station
) Performance Area: CUNTROL OF CONSTRLETION PROCESSES ODjective No. CC.4 Other Information That Supports The Summary o In oroer to assure that tne tank erection was performea to
- } work proceoures and drawings, the contractor provided
-a direct ano continuous supervision of the Joo, work proceoures ano drawings were found to be current with UE&C Specification 9763-006-246-1, Revision 5. The contractor l~ and YAEC'c QA recoros for the tank erection 010 not contain l any references to problems with deviation from specifiec work or the use of outoated drawings. The Fabrication
.l Check List (FCL) used to outline the work process ano J ioent.tfy the QA nolo points was approvec by 0A and the ANI.
p o The contractor performed rework activities using a I}
' .Faorication Cneck List Accition (FCLA) that cetails the rework in steps for QA nold anc approval. However, not
.-) mucn rework is performec, wnicn cemonstrates gooo control i of work activities. The YAEC QA recora from July to d October,1982 snowec that only one weld repair was performeo on the tank erection joo.
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- o Tne training recorcs snowed that all supervision and labor involved in the tank erection joo were provided training in o all tne applicaole joo requirements. It was notea tnat
, supervision anc QA worked well together. All the QC inspectors were qualifiea to ANSI Level II. The joo supervisors hao consicerable experience. Botn the joo
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supervision anc QA stated a philosopny to ao the joo right
, the first time.
q- o During a walk-thru inspection of the job, no deficiencies were noted regarding correct usage of tools.
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- 6. Piping Installation -
a o work status meetings are held daily between UE6C anc tne contractor. The UE&C Piping Superintencent has a g000
] grasp of tne cay-to-cay work of the Piping Contractor.
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PERFORMANCE EVALUATION DETAILS Construction Project 1 Seaurook Station Performance Area: CONTROL OF CONSTRUCTION PROCESSES Objective No. CC.4 R
'l Other Information That Supports The Summary o Contractor's QA force is approximately 150 personnel.
o The average welo rejection rate is approximately 24%.
[ o UEAC's Piping superintencent oelieves that many of a the current cifficulties are oue to the iner,:perience (interpreting results) of the contractor's QA personnel.
o The organization of tne UE&C Piping group was
, reviewed ano it appears adequate, t
U o The UE&C Piping superintencent is familiar with, and nas an acequate working knowledge of, the procecures
"] in effect at the site for the accomplisnment of the a work, s o Tnere is no Contractor Design group on-site.
o Approximately 200 Engineering Change Authorizations
, (ECA's) are processed per week.
[j o The Contractor's organization enart was reviewea. Staffing appears to be acequate. QA reorganization and expansion is currently uncerway.
o Tne contractor's Assistant QA Manager is well qualifiea for the 6
position and very knowlecgeaole of tne proceaures establisnea for tne site. He explained the current QA reorganization to better id separate recoras functions from proauction functions.
, o Welaing work at two (2) different locations was coservea. In
- ! each case, tne work naa just been completed and tne craftsmen were getting ready to call for the QC inspector. Botn welaers nac tne required and correct accuments in their possession for the welas being made ano the process data sneets were correctly u annotated to the current progression of work. ,.
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.,, PERFORM 4tCE EVALUATION DETAILS Construction Project Seabrook Station 2
Performance Area: CONTHOL OF CONSTRU.: TION PROCE5SES Objective No. CC.4 Otner Information That Supports Tne Summary r
o Craftsmen were familiar with proceoures controlling tne working l )}
00cuments that tney were using (i.e., Wela Rod Requisition, Process Data Sheet, Construction Alce, & Isometrics).
o All four (4) Component Cooling Pumps in the PA8 pumps were coverec, however extreme amounts of cecris were thrown unoer tne covers between the pumps and tne motors and pipe spools were laying on the top of pumps llc & 110.
o The contractor's QA staffing is currently 159 people wnich is tne same as it was in FeDruary,1982.
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o A review of the NCR log indicates tnat the contractor is r; generating approximately 1,700 non-conformance reports per year.
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'> o A significant numoer of these NCR's are caused primarily by questionacie craft personnel work nacits (approximately
[]j 33%); i.e., missea nold point, used wrong weld roc, exceedeo minimum wall tnickness.
<; o A review of closed NCR's, from January thru Maren of 1982,
,j inoicatec a number of NCR's were originated as a result of colo sprirging of piping. At the present time, tnere is no trend analysis of NCR's by the Pipirg Contractor, at tne t ; site.
.)
o Tne NCR coordinator could not provide the reference in
- contractor procecure XV-2, which permittec NCR's to be
" voiced". This practice is being followea as discussec in Finoing QP.1-1.
j o A review of NCH #1892 snowed tnat after QA sign-off of the Li NCR, a memo was issued which changeo the reportability status of tne NCR from "not applicable" to a "potentially
"] reportaole" 10CFR21. The original copy of NCR #1892 was
,j not enanged to "potentially reporta0le". This practce is in accorcance with present project procedures.
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PERFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station J Performance Area: CONTROL OF CONSTHLCTION PROCESSES Oojective No. CC.4 C
'j
, Otner Information That Supports The Summary
, o As a follow-up, this situation was discussed with the UE&C Site Engineering QA supervisor. He produced the
~] cocumentation (letters) verifying a timely review ano investigation of tne "potentially reportaole" situation.
Il Handling of "potentially reportaole" concerns appears to De LJ well contro11eo.
4 o Tne contractor's metnoo for filing completed production occuments (i.e. Process Data Sneets) was reviewea. They are filed oy systems. Several were randomly reviewed anc then tne RHR system faloer was reviewea. All occumentation in the folcer was '
completed correctly.
o The folder for the Component Cooling System was revieweo e,
and all occument.ation was completec correctly.
o Documentation for rework is kept in tne same folder but is not attacnea to the cocumentation for the original work.
- a. O Large bore ASE-III pipe spools are being modifiec on site. However, separate files for tracking of ASME-III
,l spool modifications are not being maintainea. The u occumentation relative to ASE-III spool modifications are being kept (randomly) in tne appropriate System foloers.
.3 Current status of modifications to large bore ASME-III pipe
!' spools is not availacle anc woulo De very difficult to compile in a reasonaole time frame.
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- J 125l PERFORMAtC EVALUATION DETAILS Construction Project Seaurook Station
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Performance Area: CONTROL OF CONSTRtfTION PROCESSES 00jective No. CC.4 q, Other Information That Supports The Summary
,., o Copies of the montnly summary of NCR's for tne months l! January tnru Septemoer 1982 were obtained. A treno s analysis was performed and it was cetermined that a total of 975 NCR's were written (wnien incluces 107 "voiceo"
_l PCR 's) . 438 NCR's were attributed to contractor cause ij coces, 24 to venoor supply proolems, and 34 inoeterminate/ unknown. Of the "valia" NCR's (975 - 107 =
,, 868), the Contractor's cause coces account for 50% of all i NCR's written. Of tnis 50% of all NCR's written, J approximately 75% (326 NCR's) were assigned to vendor supply problems; nowever, the only corrective action ever J'
ij inoicatea on tne NCR's was " Construction Manager to Contact Vendor". A stronger effort snould oe made to assign the 112 NCR's in Cause Coce 34 (inceterminate/ unknown) to a t
definitive cause coce.
t o A aiscussion witn the contractor's Engineering Change Autnorization (ECA) cooroinator took place. Approximately 200
- ol ). ECA's are processeo per week.
o 20% to 40% of the ECA's are initiatea by p Pullman-Higgins I
P o 60% of tne approximately 200 ECA's pertain to nangers/ supports ano 40% pertain to piping 1
- o Tne processing of ECA's was oiscussed with the Drafting e'
Supervisor for piping. ECA's are logged in and scheduleo on a
" systems" priority casis for incorporation into tne construction
] aioe (ISO's) drawings (see Finoing CC.1-1 for'further discussion).
_ o. The processing of ECA's was discussea with the Drafting Supervisor for nangers/ supports. ECA's are logged in but not Hl t
scneculed for incorporation at that time. The ECA's are incorporated into tne nanger/ support orawings when tne i 7 Pullman-Higgins fielo engineer notifies them that ne will be O working on specific nangers/ supports in tne near. future (see Finoing CC.1-1 for details).
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.-[ PERFORMAtCE EVALUATION DETAILS Construction Project
- Seaorook Station J
Perfomance Area: CONTROL OF CONSTRtITION PROCESSES Objective No. CC.4 I
Otner Information That Supports The Summary
) o The Pullman-Higgins QC supervisor was accompaniea on the 2nc snift. No QC inspections occurrea while with the 2nd snift, since no ASME-III pipe welcing was performed. Second snift work i is somewnat limited to pipe nangers/ support installation anc u- , B31.1 pipe work. Availaallity of QC inspectors on the 2no snift appears acequate.
o Pipe storage in tne Soutn 40 & West 40 storage yarcs was reviewec. Storage of pipe spools in cotn yard areas is gooc.
All piping is on dunnage and completely off of the grouna, ana all piping haa eno caps securely in place to protect the pipe.
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'PERFORMAtCE EVALUATION StJNARY Construction Project Seaorook Station
-)
Performance Area: CONSTRLETION QUALITY INSPECTIONS Objective No. CC 5 Evaluator (s) A. Cooper, W. Rotherforth, A. Colello
! I. Performance ODjective Construction inspections snould verify and document that tne final
.] product meets the design and quality requirements.
6 J j! II. Scope of Evaluation iJ!
The evaluation included a review of several contractors' QC Inspection Programs. The purpose was to verify that WC Inspections are: conducteo
,! in accordance with approved procedures; performed by qualifiec
- 2 inspectors; supportea by upper management; anc identify substantiative problem areas.
'l This included interviews with construction site managers, supervisors, lj and both QC ano non QC personnel. Various inspection related documents were reviewed to determine the cepth and adequacy of the inspections.
1i In aadition, observations were conducted of inspectors performing U inspection activities. Approximately 90 mannours were expended.-
III. Conclusion n In general, Construction QC Inspections meet the requirements of this ii Performance ODjective. The inspection packages contain adequate detail and inspection personnel qualifications to meet ANSI standard requirements. An area of weakness was identified relating to the inspection process.
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PERFORMAtCE EVALUATION
SUMMARY
Construction Project
.) Seabrook Station
) Performance Area: CONSTRUCTION QUALITY INSPECTIONS Objective No. CC.5 IV. Areas of Weakness & Corrective Action; Good Practices Finoing The inspection process does not always assure tnat proce-I,! (CC.5-1) dural requirements of the project are satisfieo. This was
^J noted in several cases; one where work was performed to an annotatec crawing, and other cases where Hilti bolts were
, not installed in accordance with approved procedures.
L r, Correctiv'e The casic function of the inspection process is to
, Action assure full compliance that the procedural requirements of the project are being invoked and are totally satisfied.
Each contractor has this primary responsibility. In cases jl where full compliance is not achievea, Contractors generate
- eitner an inspection report or a non-conformance report cepicting the non-conformance conaition.
j "! Each Contractor will be required to upgrade nis process control during installation, to assure compliance witn procedures. Surveillance activities will be performed to l assure implementation of the upgraded program.
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jg PERFORMANCE EVALUATION DETAILS Seabrook Station Objective No. CC.5 I l Perfomance Area: CONTROL OF CONSTRUCTION PROCESSES p.
id CC.5-1 A. The Piping Installation Contractor was observed installing a pipe
., hanger using a drawing which was marked based on verbal input I from UE&C Site Engineering. The contractor Q.C. personnel
' allowea work to proceed without correcting the unacceptable conoition. For details of this finding, see Finding CC.4-6.
y Several Hilti bolt installations by the Piping Installation and U B.
Instrumentation Contractors were observed. Bolts were not 7
installed in accordance with approvec proceoures. In all cases.
"!;I tne Q.C. inspector allowed work to be performed in a manner wnien was not prescribed by the proceoure. For details of this finding, see Fincing CC.4-3.
<l l} C. For additional evaluations of the Construction Quality Inspection Program, see OA.3-1 (QA/QC functioning in a proouction capacity),
.7 and CC.4-2 (cuplication of inspection efforts).
!j Otner Information That Supports The Summary J 1. Contractor's QC managers, inspectors, procedures, and records 3
were assessea in the performance of this evaluation.
c' j' 2. The managers and the inspectors had a good understancing of their QC program and their responsibilities in the overall project structure.
> 3. The procedures that were reviewed defined the inspection process in detail, and appeared to include those requirements necessary
] to meet the project requirements.
U
- 4. The QC inspectors observeo did not appear to be influenced by the construction management or crafts in the performance of their l 1 inspections. The inspections observed were performec in t>
- accoroance with written procedures.
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PERFORMAtCE EVALUATION OETAILS Construction Project "l Seabrook Station
)
Performance Area: CONTROL OF CONSTRLETION PROCESSES Objective No. CC.5 r,
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'I Otner Information That Supports The Summary
~l 5. Recorcs of inspections that were reviewed were clearly ioentifiec j to type, scope, persons involveo, ano cefinitive oescription of results.
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- 6. The systems for reporting.cegraded quality are clearly in place
[' and understood. The system provides for tagging work in process
, with " Halo Tags", to inoicate tnat a proolem exists wnicn cannot
- ce resolved prior to proceecing with work.
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I, PERFORM 4CE EVALUATION
SUMMARY
Construction Project Seabrook Station I' Performance Area: CONSTRUCTION CORRECTIVE ACTIONS Objective CC.6 i
r" j Evaluator (s) G. Reardon (with input from several team members) j<!
[ I. Perfonnance Objective The construction organization shoula evaluate audits, inspections, and 1 surveillances; process replies ano follow-up; and take corrective ij action to prevent recurrence of similar problems.
r
!] II. Scope of Evaluation
..s The evaluation included a review of YAEC, UE&C, and various
[ contractor's construction corrective action systems. The purpose was i; to verify that construction corrective action systems, such as NCR, audit / inspection / surveillance oeficiencies, CAR, ano tracking and trend reports are effective in identifying problems and proviaing corrective
!j action to prevent reoccurrence.
This incluceo interviews with construction site managers, supervisors, ilj ana QA/QC personnel, as well as a review of selectea cocuments to ensure the system was functioning properly. Approximately 20 mannours were expended in this evaluation.
'1 l3 III. Conclusion f]; In general, tne construction corrective action program appears to be satisfactory. Tracking and reporting systems appear effective and personnel were knowledgeaole of the system.
l' No areas of weakness or strength were loentified for'tnis Performance Oojective.
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PERFORMAPCE EVALUATION DETAILS Construction Project F
Seabrook Station
.l}J Performance Area: CONSTRUCTION CORRECTIVE ACTIONS Objective No. CC.6 ri Ji Other Information That Supports The Summary j 1. The site contractors contacted in the assessment of correc *ive
- r[ ; action were very involved in adequate review, follow-up, E-ia analysis of deficiencies for corrective action to prevent
- c. recurrences. The actual tracking of the corrective action items was accomplisned oy tne QA/QC groups ano the follow up was by tne construction department.
- 2. The contractor's organizations have NCR tracking reports tnat can
_j be readily understood and tne personnel interviewed hao a gooo working knowleoge of the system.
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- 3. The contractor organization reports are used to develop ano track trends. All reports are identified on a montnly tracking report with the seneouled corrective action date. If tne cate for the
- l'l corrective action is long-term, it is carried on the report until 1i the action date and then trackeo. However, if a significant treno is discovered over a short period of time, a " Corrective
-( j Action Report" is generated, to effect prompt corrective action.
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PERFORMArCE EVALUATION
SUMMARY
Construction Project ii Seabrook Station Performance Area: TEST EQUIPE NT CONTROL Objective No. CC.7 ij -
Evaluator (s) A. Cooper (with selected team input) r'
- l. Performance Objective Measuring and test equipment should be controlled to support i construction testing effectively.
ij
,, II. Scope of Evaluation The evaluation included a review of the UE&C construction gauge facility and program. The purpose was to verify that UE&C and contractors' measuring and test equipment is: calibrated in accorcance
!I with approved procecures; calibrated by qualified personnel; acequately documentea; ano issued properly.
y
', This inclucea interviews with the UE&C gauge facility supervision ana lao personnel. Several measuring and test equipment calloration
, recoros were reviewec for frequency ana acequacy. Approximately 5 t
- mannours were expenceo in this evaluation.
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- III. Conclusion
!]~
In general, tne UE&C measuring and test equipment program meets tne requirements of tnis Performance Oojective. Stancarcs usea to caliorate equipment were acequately contro11ea and personnel performing id calibrations were suitaole qualified.
~] One area of weakness was icentified regarding control of calloration to
,j contractor's requirements.
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PERFORMAPCE EVALUATION
SUMMARY
Construction Project Seabrook Station Performance Area: TEST EQUIPMENT CONTROL Objective No. CC.7
] IV. Areas of Weakness & Corrective Action; Good Practices Finoing Measuring and test equipment is not always uniquely ioen-r, (CC.7-1) tified. There is no program to control or limit tne use of 1 '
equipment calibrated to specific contractor requirements 2
from being useo in applications requiring calibration to more stringent manufacturer specifieo tolerances.
I t_
Corrective Tnis proolem will be investigated and appropriate action
.7: Action will ce taken to assure that equipment calloration
'!( limitations are clearly unoerstood by the user. This will be completed by tne eno of January,1983.
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.tj i 73 PERFORMAPCE EVALUATION DETAILS Construction Project ii t SeaDrook Station Performance Area: TEST EQUIP >ENT CONTROL Objective No. CC.7 r,'
'{ j CC.7-1 The existing program for calloration of measurement and test equipment
' permits contractors to specify accuracy requirements that may differ
- ri from tne manufacturer's accuracy requirements, with no method of.
!j limiting the use of the oevice, o
'l Contractor's submittal forms for M & TE have a block entitled " Contractor's Accuracy Requirements". Two (2) of ii tne contractor's procedures and UE&C procedures were c
revieweo, and there was no requirement to identify, on the aevice, tnat the accuracy requirements were different than
~ those of the manufacturer, when tnis is the case. Wnen accuracy requirements less stringent than those of the hI manufacturer's are specified for a cevice, then the usage II should be limited to areas of work where the modified accuracy requirements are acceptable. There is no evioence tnat tnis is iaentified on the contractors submittal form
)) or the calloration sticker on tne instrumentation.
')
Otner Information That Supports The Summary "I
J 1.
Measurement and Test Equipment Control procedures and " gauge 3- facility" activities were assessed in the performance of tnis evaluation. The gauge facility operation is presently uncergoing a'" a enange in organization, whereoy certain instruments ana stancaros will be separatea from construction equipment anc will d.,! ce controlleo Oy a stancaros 1a0. For purposes of this LJ evaluation, there was more concentration on the lac section that calibrates equipment.
and controls construction measurement and test 1j 2. Test equipment was checked in the field for valid caliDration information and compared witn the gauge facility calluration r records. The examples selecteo had up-to-cate recorcs of i
calloration in tne gauge facility files. If equipment is founa to be out of tolerance when it is recalleo to the facility for calloration, the information is furnished to the contractor for evaluation of work activities associated with the equipment and required corrective action. ..
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'Il 1 PERFORMAPCE EVALUATION DETAILS Construction Project Seabrook Station
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[] Performance Area: TEST EQUIPENT CONTROL Objective 70. CC.7 Other Information That Supports The c mry
}
- 3. The test equipment examined in the field was in excellent
- {l conoition and properly protected when not in use.
- 4. The calibration of M.&T.E. is being accomplished by written
, procedures generally cased on manufacturer's recommencea
't i calibration instructions. The site procedures require the use of iJ certified standarcs or methods in the performance of tne caliorations.
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- 5. The qualification recoros of the incivicuals involved in calibration were reviewea ana appearea to De acequate.
' i 6. A question arose regarding calibration of dynamometers used II ouring cable pulling operations. It was establisnea that the cynamometer vendor is not qualified to calibrate dynamometers at F)
I his local outlet. Consequently, dynamometers have to be sent j away for calibration to a qualified laboratory. Dynamometers are calibrated monthly. Further inquiries regarding other equipment r
usea for cable pulling revealed that the proper type and range of
'" straight blocks, sheaves, anc rollers were used depending on the size and type of cable being pulled. ..
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PERFORMAtCE EVALUATION SLM%RY Construction Project Seabrook Station r;
j Performance Area: PROJECT PLANNING Objective 70. PS.2
.3
, Evaluator (s) W. Ramsden, W. Willougnuy, C. Fonseca
, (with contributions from entire team memoers) j I. Performance Objective Project plans should ensure completion of the project to the highest industry stanoards by identifying, interrelating, and sequencing the tasks of tne project.
_, II. Scope of Evaluation Discussions were belo with UE&C Project Management and site Planning ij '! and Scheduling (P&S) supervisors, the YAEC P&S Engineer, ano the Piping Contractor's P&S supervisor. P&S documents providing policies and
., procedures and various project scheoules were revieweo. Approximately
. 20 manhours were devoted to this evaluation.
J
'! III. Conclusion In general, the Project Planning appears to be satisfactory. However, 3 one (1) weakness was identified in that it is not apparent tnat cesign j verification programs have been integrated into the overall project scheoule.
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- j PEHFOR'WCE EVALUATION SLNMARY Construction Project Seabrook Station Perfortnance Area
- PROJECT PLANNING Objective No. PS.2
] IV. Areas of weakness & Corrective Action; Cood Practices
!J' Finding While the various design verification programs (Ref.
(PS.2-1) DC.4-4) will upgrace tne confidence in the oesign and
" enhance the reliaollity of the plant, it was not apparent that the senedules ceveloped for these programs nad been integrated with the overall project scheoule and the i' potential impact on the plant design and construction l,
adequately assessed. Program procedures should be oeveloped or reviewed to ensure they clearly define interface responsiDilities. Present manpower allocations r}
! snould be appraised consistent with cost-effective schedule J
requirements, n
ll Corrective The project will reassess the potential impact of the Action various verification programs on the plant cesign, integrate to a greater extent their related schedules into
['j- the overall project CPM schedule, and institute appropriate action to assure effective seneauling and implementation of the programs.
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Il PERFORMAK E EVALUATION DETAILS Construction Project 7 Seabrook Station Performance Area: PROICT PLANNING Objective No. PS.2 c,
- g PS.2-1 Several scheduling concerns became evicent relating to the
! implementation of tha oesign verification programs, recognizing their scope ano that some work has not yet started (see OC.4-4).
o Reactions of caole tray, conduit, and pipe supports, whether
' attacnea to supplementary steel, building steel, or emoecment plates, are not cons %ently being generated and/or transmittec
- to tne structural discipline for review.
- o Lack of timely approval and a program for implementation of the
'l oesign criteria for anchor Dolts (Appendix F to the Structural Design Criteria (craft issue), dated 3/82). Chief Engineer's comments have not been reviewed and incorporated, altnough the craft is being usec in oesign.
o Concern for the lack of timely evaluation of ARS revisions as they relate to structural ano equipment qualification reviews,
-t o A concern for the manpower applied to the Failure Modes and
' Effects Analyses cesign confirmation. The scope includes a review of postulated pipe break effects, pipe whip / target effects, jet impingement analyses, and Reg. Guide 1.29 considerations.
i): o UE&C's Project Manager stated that the engineering design confirmation and verification programs, except for piping related r,
programs, are scopeo out ana will get underway shortly. The
~;
piping programs are waiting input feedcack from the "As-Built" program, prior to initial scoping. However, according to the
' Project Manager, presently none of these programs are specifically incorporated into the project planning networks.
, Other Information That Supports The Summary
- 1. The following planning & scheduling documents were reviewed witn the Supervisor of P&S at UE&C's home office:
mt o CPM master scheoule - latest and one year o,1d
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PERFORMAtCE EVALUATION DETAILS Construction Project r; Seaurook Station l
Performance Area: PROJECT PLANNING Objective No. PS.2
!J , Other Information That Supports The Summary r; o Twelve (12) week scheoule o Twelve (12) month schedule o various schedule sorts available o General Aoministrative Procedures & Policies "I
[j o Seneaule analysis reports r- These schedules anc occuments appear to be consistent with
- ! incustry practices and provice an effective management control tool.
F1 2. Tne following subjects were discusseo with the UE&C Supervisor of
- P&S at the site
,3 o Planning organization and manpower I o Procedures ano policies o Interfaces anc inputs from other P&S grcups o Progressing
[l o Senedule analysis J
- 3. The project is presently re-estimating the master schedule which p; may impact the estimatec percent completion. Current percent ij completion is based on an estimate and senedule preparea in 4/81.
r'
- 4. The YAEC P&S engineer attenos the regular weekly Schedule update meetings with UE&C and provices the necessary input relative to J YAEC's scope of work. YAEC monitors all of UE&C's scheduling activity and provides direction when necessary.
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i~ 5. The following subjects were oiscussed with the Piping Contractor Planning & Seneduling Supervisor:
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PERFORMAtCE EVALUATION DETAILS Construction Project
. . , Seabrook Station Performance Area: PROJECT PLANNING Objective No. PS.2
, Other Information That Supports The Summary o Organization P
y o tuncer ano qualification of personnel r, o Proceoures ano guicelines i;
s o Methoos of oeveloping Level 4 plans
", o
,j Interfaces witn P.C.S. (UE&C), construction, ano construction turnover r,
o Material shortages The piping contractor's planning & scheouling group provices the
[ _, Level 4 planning activities to UE&C to be incorporateo into tne master CPM and work incentive programs. This is consioereo to De effective.
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PERFORMAPCE EVALUATION
SUMMARY
Construction Project Seacrook Station J -
Performance Area: PROJECT CONTROL Objective PS.3 0
- +
a Evaluator (s) W. Ramsden I. Perfomance Oojective
,a Project scheouling and work planning and coordination shoula ensure r
that the objectives of the project plan are met througn effective and
>j efficient use of project resources.
'l II. Scope of Evaluation
.J Project Control was evaluated by interviews with the UE&C Project
[' Controls Group and Contractor's Planning & Schecu]ing Group, reviews of
[ ~" the scheoules developeo by these groups, and assessment of the effectiveness of the interface between these groups to develop I
consistent project work scheduling.
'b Approximately 10 manhours were devoted to tnis evaluation.
T a III. Conclusion
- q The standaros of tnis Performance Oojective are being achieveo.
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j PERFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station Perfctmance Area: PROJECT CONTROL Objective No. PS.3 i Other Information That Supports the Summary
- l. Project seneduling for manageable work units is handled by the Project Controls group of the UE&C Planning & Seneduling 2
i section. This group develops, with the appropriate contractors, the Level 4 planning effort. The Project Controls group appears
,_ to be operating satisfactorily and is adequately staffec.
l3 The Project Controls group provices the interface between the contractors' Level 4 schedules and the irput to the UE&C
, construction scheoules. Basically, tnis group monitors, upcates, d
t evaluates, and oevelops preventive and corrective action; plans anc feecs information back to the contractors' ana UE&C area superintencents. In addition, this group estaolishes tne Dasis for the contractor incentive program.
- 2. The piping contractor's Planning & Seneduling supervisor indicated that the Level 4 planning (Project Controls) system is functioning acequately. A contractor, upon direction from the Project Controls group, initiates a cetailed (Level 4) plan for a specific area / system. This plan is reviewed by the Project i Controls group and adjusted, if necessary, to integrate with 4
other contractors. A review of a suomitted and later issued plan shows that any changes requirea to reduce impact on other traces 1 are minimal and tnus the contractor is essentially scheouling nis own work.
- 3. Much of the scheduling is initiated after the actual work has commenced. The reason appears to be that the seneduling system has been under development and is changing frequently. The
' system turnover is just now being integrated into the schedules.
Project Management is aware of this problem. .
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.j PERF0NE EVALUATION SLNHARY Construction Project Seaorook Station Performance Area: PROJECT PROCUREMENT PROCESS Objective PS.4
~
- Evaluator (s) G. Rearcon
) .
._, I. Perfomance 00,)ective
!I u
The project procurement process should ensure that equipment, materials, and services furnisnec by suppliers or contractors meet project requirements.
q II. Scope of Evaluation
!i The project procurement process was evaluated by interviewing personnel in both tne UE&C Home Office ano site Purenasing Groups, ano Quality
['
Assurance and Home Office Project Engineering groups; reviewing procecures to wnicn the work is performec, reviewing the sign-off of
' purenasing documents, and reviewing the process for developing list of Approvec Blooers.
Approximately 20 mannours were expenced for this effort and PS.5 in 4
7 whicn Cnange Orcers to the contracts were evaluatt.J in a similar manner.
III. Conclusion
!n j The standarcs of tnis Performance Oojective are being achieveo.
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PERFORMAtCE EVALUATION DETAILS Construction Project
,' Seaorook Station
$ Performance Area: PROJECT PROCUREENT PROCESS Objective No. PS.4 n
j; Other Information That Supports The Summary
._,' 1. There is an acequate documented program for the procurement process at the UE&C nome office. This program encompasses engineering, purchasing, and quality assurance proceaures wnien are being implementea for the preparation, review, and approval 1
of procurement cocuments.
o Tecnnical requirements are developea, preparea, reviewed, q ano approvea ano tecnnical portions of tne proposals are
- reviewed by the Project Digineering group. Procecures a proviae for resolution of connents on tecnnical requirements from other engineering cisciplines, Quality Assurance, ano YAEC.
o Quality requirements are identified, prepared, reviewea, and approved ana quality portions of the proposals are d
reviewec ey the Project Quality Assurance group.
o Commercial and soministrative requirements are developed, prepared, reviewea, ano approved and these portions of the
- proposals are reviewed oy the Project Purchasing group.
- o Recommendations and approval of purchase awards are i
documented on a signed-off 810 Evaluation Sheet. All comments and questions related to tne recommenced proposal
, are resolvec prior to formal purchase award.
_J 2. Tnere is an acequate documented program at the site for the centralized purcnasings by UE&C Field Purchasing of material, supplies, services, and rentals for UE&C and all contractors with
, field labor contracts. The centralized field purchasing proceoure wnich is being implemented provices for the preparation, review, ano approval of procurement documents.
o Technical requirements are developea, prepared, reviewed, and approved oy the requesting organization.
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., PERFORMAtCE EVALUATION DETAILS Construction Project Seaurook Station Performance Area: PROJECT PROCUREPENT PROCESS Objective No. PS.4
~l Otner Information That Supports The Summary
.j o Quality requirements are identified, preparea, revieweo, ano approveo and the proposals for safety-related items are i reviewed by the requestor's QA organization. UE&C site QA a provioes acoltional review.
7 o Commercial and administrative requirements are provideo by
_j the UE&C Field Purchasing group.
o Recommendations ano approval of purchase awarcs are occumented on a signed-off Bid Evaluation Sheet.
- 3. Approvec bicders lists are reviewed by UE&C home office QA group ano for field purchases by UE&C fiela QA and requestor's QA
- organizations. Procecures are provided to insure inquiries are issueo only to blocers on tne approvec list or those who are 1 capaole of being approved by a QA facility survey. This l j proceaure is satisfactory. !
l
, 4. Satisfactory verification of field purenase approval signatures is provicea Dy a signature and initials book maintained Dy UE&C Fielo Purchasing of all persons authorized to approve procurement occuments.
1 j 5. Historical venoor performance evaluations are based on experience of procurement personnel ano QA flies. This is a satisfactory metnoa.
J 6. Section IV in UE&C's Manual of Procecures, Revision 8/29/75, Purchasing Seaorook Project, ooes not specifically icentify the actual requirements for QA review of bidders lists and purcnase
, recommencations, altnough a general reference to procedures for "N" and "S" transactions is made. This is considereo minimally acequate for an overview procedure.
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,a PERFORMAtCE EVALUATION
SUMMARY
Construction Project Seabrook Station Performance Area: CONTRACT ADMINISTRATION Objective PS.5
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_j Evaluator (s) G. Rearoon i
I. Performance Oojective Methods for aoministering and controlling contractors and suppliers ano
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- J for managing changes to tneir contracts should ensure effective control of performance.
II. Scope of Evaluation g, Refer to PS.A.
III. Conclusion
'l
- The stanoaros of tnis Performance 00jective are Oeing achieveo.
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." PERFORMANCE EVALUATION DETAILS Construction Project Seabrook Station Performance Area: CONTRACT ADMINISTRATION Objective No. PS.5 9 Otner Information That Supports The Summary ai
- 1. In general, contracts involving field laoor are administerec Dy a Contract Aaministration group locateo at the site. Purchase
- q
. L, orcers involvim only materials are aoninistereo oy the Buyers in the UE&C nome office purchasing group. All written Change Oroers are issued by UEAC nome office purchasing.
L 2. Review of cnange orcer procecures and change orders for selecteo purenase orcers anc contracts showec that the following criteria q
are being met:
'd o Change preparation, review, and approval is in compliance with proceoures and consistent with the original
.; requirements.
o Justification is provided for the changes which consicer quality, safety, cost and scheoules as appropriate.
o Verbal changes are confirmed in writing.
o Change orders are supported by approved requisitions ana s
bid sneets, which provice approval oy appropriate levels of management and provide tne information above.
- 3. A program is in place, at the site, whien effectively monitors contractor performance.
3
- 4. Programs for initial contractor interviews and briefings, and for
- J tne close out of site contractors, are in place. These programs appear to be adequate for these site / contractor interfaces.
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PERFORMAtCE EVALUATION SLNMARY Construction Project Seabrook Station
.d Performance Area: 00CLENTATION MANAGEMENT Oojective No. PS.6 l
Evaluator (s) W. Willougnby, R. McHellon, & C. Ashton 7
_j I. Perfomance Oojective The management of project documentation should support the effective
~ control ano coordination of project activities ino provice a strong founaation for the cocumentation/information requirements of the plant's operational pnase.
J II. Scope of Evaluation
- Control of engineering documents relatec to preparation, document control center processing of oocuments, change control, oistrioution, anc recoros management botn at the site and the UE&C nome office were evaluateo. The UE&C project groups evaluated were Home Office Project Engineering, Site Support Engineering, Project Purchasing, and Document Control Center; Site Engineering, Site CharNe Coordinator, Field
] Purchasing, and Document Control Center. Contractors' site groups
_j evaluatea were the electrical and piping contractors' engineering, document control center ano document distribution, and the HVAC 3 contractor's Non-Conformance Report recoros. Discussions were held
" witn supervisory and working level personnel of these groups. Document records were examined and document nandling was witnesseo.
Approximately 75 manhours were devoted to this evaluation.
J III. Conclusion 7'
" In general, the docurrentation management is satisfactory. However, there were a number of weaknesses identifieo that indicated a need to strengtnen contractor programs and update UE&C document status logs.
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' PERFORMAtCE EVALUATION SLM%RY Construction Project Seabrook Station t
Performance Area: DOCLDENTATION MANAGEENT Objective No. PS.6 IV. Areas of Weakness & Corrective Action; Good Practices Finding The latest revision of project documents is not always
__l (PS.6-1) incorporated into the Piping Contractor's installation drawings available in the work area. For example, it was founc tnat pipe support drawings available for issue by tne o roa room are an earlier revision than the revision in the
'j DCC. Also, programs to assure the inclusion of the latest design requirements in installation arawings should be strengtneneo.
-,l
.J Corrective All ECA's are transmittea by the Contractor to the Action applicable Field Engineer witnin one to two cays from time of receipt and controlled according to Project Procedures.
The Field Engineer is, therefore, mace aware of pencing enanges. However, cue to the large numoer of backloggeo ECA's, a proolem coes exist in the timely incorporation of these changes to installation aid drawings. This situation was known and accressed prior to receipt of this Finaing.
A corrective action program has been implementea which incluces a reassessment of all work priorities and increasea engineering and drafting personnel to assure the incorporation of ECA's in accordance with those priorities. Work will be continued only after full assurance tnat applicable ECA's are included on construction aides usea in the Fielo.
J Fincing The recorcs management system oces not always identify (PS.6-2) the current status of project documents. Several cases
!"i were discovered where the Drawing Task System (DTS) and the Engineering Purchasing Schecule dia not identify the latest
, drawings ano specifications in the DCC.
..j Corrective Training sassions will be belo to reinforce the proper Action methoa ano importance of icentifying the current document revisions in the Engineering Purchasing Schedule and tne larawing Task System.
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o PERFOR W E EVALUATION
SUMMARY
Construction Project Seabrook Station Performance Area: DOCUMENTATION MANAGEMENT Objective No. PS.6 i,
j,i IV. Areas of Weakness & Corrective Action; Good Practices 3 Corrective The deptn of the training session will extena tnrougn
- Action all parties and organizations necessary to arrive at a tnorougn understanding of responsibilities. Project y Procecures will De revieweo and revised as necessary, d Scheduled internal audits will De conducted to assure tnat document revisions are incorporated into the Engineering
' Purtnasing Seneoule (status log for specifications) and
'; into the Drawing Task System (status log for specifications / drawings) in a timely manner. Management follow-up will be maintained to assure prompt corrective action is taken whenever necessary.
The training sessions will be initiatec in December,1982 and tne internal audits in January,1983.
J
, Finoing HVAC Contractor accountability of NCR's has a weakness.
(PS.6-3) A situation was discovered where the HVAC contractor transmitteo Non-Conformance Reports to YAEC for microfilming witnout maintaining a log to track document
_; status.
Corrective To avoia recurrence of non-documented NCR transmittal
- Action to YAEC's Document Control Center, tne Contractor's QA recoros clerk Will retain a Copy of package Contents in a working file, pending return receipt inoicating YAEC DCC verification. Contractor Procedure QP-10 will De revised accordingly.
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,q j PERFORMArCE EVALUATION DETAILS Construction Project Seabrook Station Performance Area: 00CUPENTATION MANAGEMENT Objective No. PS.6
- 9 PS.6-1 A. The program used by tnc piping contractor to control the transfer
.]'!
. of UE&C design drawing information and changes / revisions, to UE&C drawings, to tne contractor's installation orawings coes not q provide an acequate cross-cneck Detween contractor's installation 4
"j drawings (construction aides) and UE&C drawing revisions or ECA's. There is no convenient and timely method to determine
' which revisions or ECA's affect a contractor's drawing until the prioritizeo oesign enange is formally addresseo. It is not ij possible to cetermine what outstanding ECA's exist against a particular contractor drawing used for installation until the enange is incorporated.
<l B. Pipe nanger/ support installation drawings marked approved for construction (erection) at several Piping Contractor locations were checked against the appropriate UE&C design drawing
, . revisions. The following cases were noted where the contractor's drawings did not include the latest revision of the UE&C design drawing.
o Seawall Rod Room - 2 ciscrepancies for 2 drawing sheets
_. cneckea:
M-8000445, Sheet 13 M-8001585, Sheet 19
[ o Central Rod Room - 1 discrepancy for 5 drawing sneets checked:
M-801818S, Sheet 3 o PAB Tank Farm Rod Room - 2 discrepancies for 5 drawing f] sheets checked:
~~!
M-800838S, Sneet 8 M-8018065, Sheet 3 o Stick files with the piping nanger/ support installation
., drawing group - 3 oiscrepancies for 8 arawing sheets eneckea; a
- M-800202S, Sheet 9
- 4 M-8002175, Sheet 4
- j. M-600219S, Sheet 3
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PERFORMAtCE EVALUATION DETAILS Construction Project Seaurook Station
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Performance Area: DOCUMENTATION MANAGEMENT Objective te. PS.6 ji PS.6-2 The cocument status logs ao not acequately reflect the issued cocument status. There does not appear to be a formal system to assure that a
, document revision, when issued by UE&C home office, has that revision J
1 incorporated into the status logs. Documents in the files at tne UE&C site DCC were compared with their respective status logs.
o Specifications were compared with the E-P Schecule catec s 9/24/82. Twelve (12) specifications were checked and three (3) ciscrepancies (25%) were founa:
1 LJ i Specification Site DCC File E-P Schedule
._, (1) 5-11 Rev. 2, 06/30/82 Rev. 1, 03/21/79
._1 (2) 18- 2 Rev. 4, 09/24/82 &
Rev. 3, 02/21/82 Rev. 3, 04/07/82 (3) 33- 5 Rev. O, 01/05/82 Rev. 2, 08/28/81 i
o UE&C crawings were comparea with the DTS dated 10/08/82.
Thirty-seven (37) drawings were checked and four (4) 01screpancies (11%) were found:
i j Drawing Site DCC File OTS i (1) 104076 Rev. 14, 08/31/82 Rev. 12, 05/26/81 (2) 222443 Rev. 3, 06/29/82 Rev. 2, 02/08/82
[ (3) 301252 Rev. 11, 09/22/82 Rev. 10, 07/27/82 (4) 309721, Rev. 3, 01/18/82 Rev. 2, 05/16/79
,1 Sheet 1 1
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o Altnougn the DTS was dated 10/08/82, it reflected the drawing revision status of 09/24/82. The actual revision status cate was not shown on the DTS sheets.
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PERFORMAtCE EVALUATION DETAILS Construction Project
,, Seabrook Station U' Performance Area: 00COENTATION MANAGEMENT Objective No. PS.6 r
[~ PS.6-2 o Four (4) foreign prints were checked against the foreign print log ano no discrepancies were found.
U o The responsible discipline engineers are responsible for J provicing a montnly status upoate for the E-P scheaule anc DTS.
The engineer is required to provide a marked-up status p output / input sheet for DTS showing enanges curing the montn. Tne
-[j engineer is requested to provide a marked-up E-P schedule, montnly, snowing cnanges auring the month. There appears to De o no formal programmatic check of the engineer's status input to
{ '
assure the accuracy of the various status logs.
PS.6-3 Non-Conformance Reports are not always properly controlled and transmittea by tne HVAC contractor to YAEC.
, o Approximately fifty (50) completed Non-Conformance Reports (NCR's) were reviewed at tne HVAC Contractor's site office.
Approximately ten (10) out of fifty (50) NCR's listed in the index were not on file. According to the contractor's quality control supervisor, the completed NCP.'s had been delivered to
} YAEC for microfilming ana incorporation into permanent plant a recoras. There was no recora to document this transmittal in the contractor's office. The quality control supervisor indicatea tnat YAEC sends an acknowledgement of NCR transmittals back to
!q
~, the contractor, but it usually takes two (2) days for receipt by tne contractor. Additional copies of these NCR's were not
... available. The possibility exists that NCR's coulo be lost anc
!'a not be traceable. This item was suosequently reviewed ano confirme0 with the YAEC Quality Assurance Manager.
n j Otner Information That Supports The Summary
., 1. Tne UE&C Document Control Centers (DCC), both in the home office 4
and in the fielo, provice adequate controls for the receipt, logging, limiteo distribution, and storage of the following project occuments:
J' ,.
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PERFORMAtCE EVALUATION'UETAILS Construction Project Seabrook Station Performance Area: DOCUW.NTATION MANAGEMENT Objective No. P5.6 Other Information That Supports The Summary
.1 i i o corresponcence o oesign drawings i o specifications o system cescriptions o venoor drawings / manuals
'] J o project manuals and procecures
- 2. The responsioility for maintenance and storage of the UEAC
-3 official master copies of occuments is satisfactorily icentified ana unoerstood. The UE&C DCC satisfactorily provides for storage in lockaole containers and for limited access to these files.
- 3. UE&C has established procedures for changes to project cocuments
( AP-15 & AP-46) . Tnese proceaures provice for appropriate levels
' of review ano approval, to assure that changes are reviewea and approveo in a manner consistant with the original design. In general, cnange accuments are adequately prepared, reviewea, approveo, logged, and monitored. However, basec on review of project tracking logs, the following weaknesses were notec:
o Review of the disposition time for fifty-four (54) ECA's
~
snowea approximately 50% took longer to resolve than the indicated resolution neeoed cate. The average excess time was ten (10) days, as determinea by a sample of twenty (20) 9 which nac ceen resolveo.
o
- An SSE group status report snowed that approximately 50% of the ECA's wnich requirea SSE concurrence review nac been issueo " Approved for Construction" Dy the Site Engineering group, for greater than 30 aays. The SCC logs showea very few forecast dates, as required oy AP-15, for concurrence review ECA's oloer tnan 30 cays.
o There was no tracking system to flag concurrence review ECA's older than 30 aays, either in UE&C's home office or in the field. The need was recognized and systems were being developec.
(The above concerns are discussed in Finding DC.5-1).
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,[, PEkFURMANCE EVALUATION DETAILS Construction Project Seabrook Station Performance Area: 00CUENTATION MANAGEMENT Ubjective No. PS.6
^
Other Information Tnat Supports The Summary
- 4. There is a large backlog of UE&C documents wnich must be revisea I to incorporate approved changes from ECA's. Since July, 1982, 2 significant progress has been made by the UE&C in the reauction of tnis backlog.
rl
- 5. Proolems with the piping contractor's accument control are bd discussea in Finaings CC.4-1 & PS.6-1. However, tne electrical contractor has an acequate system for receipt, enange
- i incorporation, and aistribution to the work site of UE&C cesign
[; arawings and tne system is being satisfactorily implemented.
_, 6. UEaC cocument status logs for project corresponcence, controllea
!,4 manuals, and vencor drawings / manuals which were reviewed snowea satisfactory upaating of tnese logs to reflect the latest m information for these accuments.
!j
- 7. The recoros management plan ana seneaule, as delineatec in AP-2 ano Project QAP-17, appears to be a program whien is tne minimum
, to meet the regulatory requirements.
! ;I
- 8. Tne UE&C procedure for handling venoor prints / manuals from fielo
"', purcnases (AP-14) ooes not reflect present UE&C site organization proceoures or metnoa of nanaling these cocuments.
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t PEiFORWCE EVALUATION SLNKMY Construction Project Seabrook Station i Performance Area: TRAINING MANAGEMNT SlPPORT Objective TN.1
~' , Evaluator (s) G. Rearoon I. Perfonnance Cb,)ective Management should ensure that an effective program exists for
-, inooctrination, training, and qualification of personnel involved in
- the project.
.1 Scope of Evaluluation II.
The Training Program was evaluated by reviewing the programs at UE&C (Home Office and Site), PSNH/YAEC, ano the Contractors. Specific responsibility for aaministration of the program was assured and the adequate implementation of the program was substantiated.
Qualification of instructors was reviewed, along with the available facilities and training material. A walk-thru was mace of the site
, training facilities. -
Approximately 15 manhours were devoted to the effort for TN.1, TN.2, &
TN.4.
1 III. Conclusion a
The standards of this Performance Oojective are being acnieveo.
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df PERFORMAPCE EVALUATION DETAILS Construction Project Seabrook Station n
jj Performance Area: TRAINING MANAGEMENT SUPPORT Objective No. TN.1
}
.J 3 Other Information That Supports the Summarf
- 1. The following Training Programs were evaluated:
i -'1
'j o UE&C (Home Office) o UEAC (Site)
, o PSNH/YAEC (Site) i:d o YAEC (Home Office) o Piping Contractor (Site) o Union-Operated
[ Welding Senool (Off-Site) t All of the above programs had the support of Management.
- f,, 2. The UE&C nome office naa management support, although the program was somewnat fragmented. Eacn department kept their own training recoras ano, except for QA (see QP.1-4), had provided the minimum 1 training in basic QA witnin tne prescribed time frame.
- .J
- 3. Training programs at the site for non-nuclear safety aspects are
,, the responsiollity of PSNH/YAEC, in collaboration with UE&C. The i
. minimum required programs covered site indoctrination, industrial safety, and basic QA requirements. All personnel working on site were requireo to attena these training sessions prior to tne
. _] start of work. In addition, PS M/YAEC provided all the training
._J facilities and equipment. Management support is evidenced by the fact that 59,000 mannours were expendea on training.
i-'! 4. The off-site welcer training school is sponsorea by the Uniteo Associated National Contractors Association. PSm management supports this activity by providing the welding equipment, j consumaales, and testing personnel. -
- 5. .
Training of project and support engineers at the YAEC home office
'l is provioeo in accoroance with their procedures. It is the
_ responsibility of the Project Manager to assure that training is provided for project personnel and of the department manager to
,7 provide training for support personnel. Approximately one (1)
, , full week of training is initially provided to all the engineering personnel. .
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~I PERFORMAtCE EVALUATION DETAILS Construction Project
..q Seaurook Station
.j Performance Area: TRAINING MANAGEENT SlPPORT Objective No. TN.1 j Other Information That Supports the Summary
- 6. Training of contractor personnel at the site is the j
- responsioility of tne contractors. Subjects includeo in their training pro performance. grams Major are for the enhancement contractors of skilled have provioed full-time qualifiec q instructors.
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. 3 PERFORMAtCE EVALUATION
SUMMARY
Construction Project Seacrook Station i Performance Area: TRAINING ORGANIZATION Objective TN.2
& ADMINISTRATION
, Evaluator (s) G. Rearoon p]
! I. Performance Objective
, The training organization ano aoministration should ensure effective I control and implementation of training activities.
-) II. Scope of Evaluation f
~'
i The training Program was evaluated by reviewing the programs at UE&C
,, (Home Office & Site), PSt4H/YAEC, ano the Contractors. Specific
.j responsiollity for aoministration of the program was assured and the adequate implementation of the program was suustantiated.
Qualification of instructors was reviewed along with the available
, ; facilities ano training material. A walk-thru was maoe of the site t
, training facilities.
.j III. Conclusion The stanoaros of this Performance Objective are being acnievec.
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..q PERFORMMCE EVALUATION DETAILS Construction Project Seaurook Station 7
j Performance Area: TRAINING ORGANIZATION Objective No. TN.2
& ADMINISTRATION
- r3
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Other Information That Supports The Summary 1 1. The aaministration of training programs at the job site is the
.: responsibility of PSNH. The implementation of the training programs is carried out jointly by PSNH and the contractors
, organizations. Effective control of the training is maintained j by the PSNH Training Amninistrator, as follows:
o Tne training manual oefines the organization goals, Il oojectives, ano qualifications for instructors.
'.) Discussions with the Training Aoministrator suustantiateo the implementation of the manual requirements.
i '
i o PSNH ano contractor procedures require instructors to have a minimum of 1-1/2 years as a practicing teacher plus graouation from a qualified college of teaching. Working experience in the crafts is oesireo. All the instructor's a
recoros reviewed showed compliance witn the minimum qualifications.
il o The Training Aoministrator adequately provices for instruction ano testing of instructors. Instructors must pass the test in accoroance with the training manual
-} requirements.
o The Training Aoministrator has an acceptable formal program l "t to evaluate instructors and their effectiveness.
- 2. The UE&C nome office effectively controls the training program for project personnel through the cesignateo Training
" Administrator, who is also the Assistant Project Engineering Manager. The following items were reviewed witn nim:
o Management support of training J o Facilities o Training seneoules o Attendance o Course. content for mandatory training This is consistent with the requirements of QA.2-2 and ASME III.
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PERFORMAPCE EVALUATION DETAILS Construction Project q Seacrook Station
.!tLJ: Performance Area: TRAINING ORGANIZATION Objective No. TN.2
& ADMINISTRATION 1
"] '
Other Information That Supports The Summary
,rm
~d l 3. The YAEC training organization anc aaministration was reviewec and founo to De acequate. This is evicenced oy their implementation of the Corporate Training Manual.
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'b Altnough the project team at YAEC is small and does not have a full-time dedicated training organization, the program is effectively implemented. The Project Manager has clearly 1
celegated responsiollity for training to the Project Administrator ano maintains authority to assure implementation.
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i j PERFORMAtCE EVALUATION St.NMARY Construction Project Seabrook Station q
j Performance Area: GENERAL TRAINING & QUALIFICATION ODjective No. TN.3 l Evaluator (s) W. Ramsoen, G. Rearoon, & A. Cooper J
(with contributions from rest of tne team members)
- 1. Performance Oojective
,, The training program should ensure that all employees receive 1
indoctrination and training required to perform effectively, and that
.J employees are qualified as appropriate to their assignec responsioilities, e
II. Scope of Evaluation Discussions were held with UE&C, YAEC, and Contractor personnel responsible for training, ano their training recoros were revieweo. A
, site training session was coserved. Engineering, cesign, quality assurance, ano craft personnel were interviewed.
Approximately 15 j mannours were devoteo to this evaluation.
III. Conclusion In general, the training and qualifications of project personnel are l! satisfactory . However, there were three (3) areas of weakness related
..a to joo specific training and training of Calloration Lab personnel necessary to ensure tneir aoility to perform effectively.
II; J
om 1
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PERFORMAPCE EVALUATION SLNMARY Construction Project q Seabrook Station Perfonnance Area: GENERAL TRAINING & QUALIFICATION Objective No. TN.3 R
(d IV. Areas of Weakness & Corrective Action; Good Practices I
- , Finding The piping installation contractor supervisors are not
- ! . (TN.3-1) utilizing the available non-mandatory training programs to l '- ' maintain tne employee's ability to perform consistently and i effectively and, in some cases, were not aware of their jq responsibility to schedule sucn training. This is ju supported by tne small numbers of craft personnel who have attended tne non-mandatory sessions contrasted with the performance concerns oetailed unoer other Performance
!!.g Objectives.
'~
Corrective An investigation will be conducted of the training
- Action records to determine the extent to which available, non-mancatory training programs are being used to upgrace job skills and productivity. Weaknesses will be correctec
~'; witn increased training, where appropriate. Supervisors will be directed to participate and become actively i involvea in the selection of personnel wno require socitional training.
Finding In all cases, both on the job and formal training is not l!f
~
(TN.3-2) adequate to maintain the employee's ability to perform consistently ano effectively. An instance was found where
, , , calioration lab personnel old not receive adequate training l; in QA/QC requirements related to measurement anc test L equipment.
Corrective The Gauge Facility personnel attenced tra'ining sessions on Action QA proceoure for calioration and control of measurement and
., test equipment on November 16 & 17, 1982 and the training recoros will Decome part of their personnel file. The v
training sessions will be scheouled on an on-going basis for proper instruction of appropriate proceoures and manuals.
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PERFORMMCE EVALUATION
SUMMARY
. Construction Project Seabrook Station b.d Performance Area: GENERAL TRAINING & QUALIFICATION Objective No. TN.3 l
jj IV. Areas of weakness & Corrective Action; Good Practices i
Finding The General Training Program at UE&C's office is in
<! : (TN.3-3) compliance with corporate commitments and procedures.
,J However, the job specific training program, structured to provide the employees with indoctrination and training 1 appropriate to their cesignated responsibilities, could De j strengthened.
I Corrective The project training program for 1983 will be structured to
-- Action address the areas listed in this item. Attendance will be monitored and make-up sessions scheduled to assure
, attendance. The program for 1983 is scheouled to be issued by Decemoer 30, 1982.
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- PERFORMAKE EVALUATION DETAILS Construction Project n Seabrook Station tj Performance Area: GENERAL TRAINING & QUALIFICATION Oojective No. TN.3 l
. TN.3-1 The piping installation contractor's first line supervisors were not 1 always aware of their responsioility to seneoule appropriate non-mandatory training for assigneo craft persomel.
' Il b '
o Site Inooctrination, QA Program, ano Industrial Safety training is provicea to all craft persomel on their first day of q errployment, on a mancatory casis.
i i J o Craft training specific to "on the job" operations, is not
~' consistently applied by the area foreman. Tnis statement is substantiated oy a comment of the supervisor that he relies upon L the QC Inspector to identify the personnel wno need specific training.
o
- The Contractor QAM requires that every new nire attend a Quality Assurance Inooctrination (Course 001). A review of the training
- , record for eignt (8) pipe support installation persomel working t
in the PAB showed that they all have attended 001 and also 002 (welaer QA Indoctrination), 005 (Safety Inooctrination), and 101 (Basic Rigging). However, job specific training courses such as r
i 201 (Welo Symools) and 203 (Hanger Tolerance) were attendeo by
' only one (1) out of the eight (8) personnel training records reviewed. The majority of the eight (8) nad less than six (6)
' I,i months on the job.
'j o The job supervisor is responsible for providing training for craft personnel, as he deems necessary, beyond the QAM requirement. However, the supervisor ooes not maintain a plan,
-h seneoule, or recora for craft training. This situation leaos to corrective training rather than preventive training.
,, o The relatively new craft persomel interviewed hao previous work L-experience in their discipline area (i.e., welaers or fitters),
n out aamitted tnat nuclear work requirements were new to them.
Tne nuclear aspects of the job are learned on-the-job.
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PERFORMPCE EVALUATION DETAILS Construction Project 7, Seaorook Station I
Performance Area: GENERAL TRAINING & QUALIFICATION Objective No. TN.3 TN 3-2 The training records of the individuals assigned to the Gauge Facility (Calibration Lab), dic not show evidence of training in the UE&C q
corporate, project, anc ASME QA manuals. Sections of these manuals
, describe calibration and control of measurement and test equipment.
.a In the review of the records of the above individuals, it was noteo l1 that the QA manuals were on the required reacing list. Reading of uj manuals is satisfactory for general information, but does not assure tnat the individuals nave the proper understanding of the program
, requirements.
TN.3-3 Only two (2) Quality Assurance training sessions are mandatory for
, engineering anc cesign personnel. Other training sessions covering UE&C working procedures, such as Specification Development, Performance of Calculations, etc., are offered baseo on icentifiec need or proolem areas. Based upon the discussions hela witn various engineering ano design personnel, and tne finoings reported under DC.3, additional formal training, at UEAC's Headquarters Office, should be conductea in the following areas:
o Project specific Administrative Procedures o UE&C General Proceoures o UE&C Detailed Desiga Procedures 1
I Otner Information That Supports The Summary 1
- 1. The training programs, as implementeo at the job site, meet the mancatory requirements set forth by the PSNH Training Program. A review of training recoros indicates tnt all craft personnel have
] received tne minimum site inooctrination courses. Additional
' j contractor training of craft personnel varies somewhat with eacn contractor. Generally, the craft personnel are qualified in L their trade prior to being nirea.
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PERFORMAPCE EVALUATION DETAILS Construction Project SeaDrook Station Il' ! Performance Area: GENERAL TRAINING & QJALIFICATION Objective No. TN.3
- l. Other Information That Supports The Summary L.] ;
- 2. Tne following items were oiscussed with the Piping Contractor q training instructor:
o Qualification o Instructions provided Oy Contractor
' p) .
o Attendance The instructor was well qualified. He was a former teacner and F naa also worked in the traces at tne Seacrook site. The program
,L includes mancatory training in site / company inacctrination and the QA programs. Accitional training is provioed in Hilti bolt
, installation, rigging practices, weld symbols, plan reading, PCR's, material icentification, and other work-related operations. Tne non-mandatory training of workers is initiatea upon request of the craft supervisor. Accitional discussion i regaraing proolems with the implementation of the non-mancatory i program is incluoed in Finoing TN.3-1.
o
- 3. The field fabricated tank installer nas hired welders who have proven tnelr aoility on other projects. The welaers who are nirec locally are extensively tested on production welds prior to oeing issued qualification certifications. Work assignments are
-l1 tailored to Dest utilize the welaer's ability.
LJ
- 4. Implementation of the training program at the UE&C home office is j1 carried out Oy tne cesignated Training Administrator for
. engineering and purenasing, ano oy the QA Indoctrination and Training Cooroinator for tne QA Department (see Finding QP.1-4).
A review of the engineering training recoros inoicated that all
] project engineering personnel received tne minimum required training. No log / list of purcnasing personnel training is maintained, but ratner the attendance sign-in sheet at the 7 training session serves as tne training record.
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i PERFORMAPCE EVALUATION DETAILS Constrxtion Project Seacrook Station Performance Area: GENERAL TRAINING & QUALIFICATION Objective No. TN.3 m
t Other Information That Supports The Summary
- t
- 5. The UEAC nome office HVAC Supervising Engineer was interviewec
- i regarcing training. He inoicatea that there was a need for iJ formal training programs for administrative procedures (suen as the UE&C General Engineering and Design Procedures - GEDP's). It was nis opinion that adequate formal company programs ao not j exist for indoctrination training or continued training of employees to ensure familiarity with engineering and design practices (see Finding TN.3-3).
- 6. A review of the training records at the YAEC home office indicates that the training program is being adequately implementeo.
~
o A review of the project records, kept by the Project
- aninistrator, indicatea that all personnel had the required training and, in most cases, had received many adoitional courses to enhance tneir job skills.
4 o Review of tne off-project support personnel training files confirmed that all personnel hao received the requireo Seabrook Project Training, even when they were not assigneo work on the project.
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.q PERFORMAtCE EVALUATION SlM4ARY Construction Project
- Seabrook Station J
Perfomance Area: TRAINING FACILITIES, EQUIPW.NT, Oojective TN.4
& MATERIAL
.?
r Evaluator (s) G. Rearoon, W. Ramsden
~1
'i u I. Performance Objectlye The training facilities, equipment, ano material should support ana
,; enhance training activities.
II. Scope of Evaluation
~ The training Program was evaluated by reviewing the programs at UE&C
- l (Home Office & Site), PSNH/YAEC, and the Contractors. Specific responsiollity for administration of the program was assured and the acequate implementation of the program was substantiateo.
r,
' Qualification of instructors was reviewed along with the available facilities ano training material. A walk-thru was made of the site training facilities.
. III. Conclusion The stancards of this Performance Objective are being achieved.
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PEHFORMAtCE EVALUATION DETAILS Construction Project Seaorook Station Performance Area: TRAINING FACILITIES, EQUIPENT, Objective No. TN.4
& MATERIAL t
Other Infortnation That Supports The Summary
- 1. A tour of the site training facilities was conductea and found to 4
be acequately equipped and well suppliec with training materiais. The adequacy of the Site training facilities is evidenceo by tne following:
'~
o Six (6) dedicated class rooms were available and a review q of tne training senedule indicated that spare f acilities
- exist.
o The equipment available for use included overnead projectors, video cameras and screens, black /wnite boards, desks and chairs.
o An acequate supply of paper, manuals, and reference materials was available.
- 2. Dedicated facilities at UE&C and YAEC were not available, however, the use of existing conference rooms provided acequate classroom space. Overnead projectors, screens, and viceo equipment was made available, wnen necessary. Proper scheduling of conference rooms minimized any oisruption of scheoulac classes.
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tj PERFORMAtCE EVALUATION SLM4ARY Construction Project Seabrook Station p,
Performance Area: WALITY PROGRAMS Objective No. QP.1
];
a Evaluator (s) A. Colello, A. Cooper, C. Ashton, R. McHellon r I. Performance Objective The quality assurance program scope, content, and applicability should
_ be appropriate, cefinea clearly, ana understood.
ii L,}
II. Scope of Evaluation n
.]
The evaluation incluaed a review of the overall Owner's Agent, A/E, ana various Contractors' @ality Assurance Programs. The purpose was to O verify tne acequacy of tnese QA Programs through: compliance with ij Regulatory Guide / ANSI commitments; review of necessary program elements; coservation and verification of day-to-cay QA/QC activities; relationsnip between manuals and proceoures; review of auait anc
- p surveillance programs; effectiveness of stop work authority; and
~j, implementation of a QA indoctrination and training program.
This inclucea interviews with corporate and site managers, supervisors, and botn QA anc non QA personnel. Observations of QA/QC activities ana verification of quality relatea documents weza utilized to determine 7 the acequacy of the overall QA Program. Approximately 60 mannours were devotea to tne effort for QP-1 thru QP-4.
.J n III. Conclusion J
In general, the overall Quality Program meets the requirements of this
^ performance oo,)ective. Quality cocumentation reviewed contained acequate cetail, and audit / surveillance personnel were suitably
.j qualified to procedures ano stancards.
However, several weaknesses were identified that indicated a neeo to strengtnen certain aspects of tnis activity. These relate to contractors' hanoling of NCR's, incorporation of A/E QA cocuments in a 1
contract, the Owner's Agent QA Manual, Regulation Guice references, A/E QA training, and A/E QA review of ASME III drawings.
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PERFORMAtCE EVALUATION
SUMMARY
Construction Project Seabrook Station C
'j - Performance Area: QUALITY PROGRAMS Objective No. QP.1 7
!. IV. Areas of weakness & Corrective Action; Good Practices 4
Finoing The contractor's procedures relating to Non-Conformance j (QP.1-1) Reports (NCR's) 00 not oefine tne autnority of
_J organizations to void NCR's. In several instances, contractors were unilaterally voiding NCR's without 1
specifiec autnority.
4:
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, Corrective Engineering Cnange Autnorization #100105A has Oeen issueo I Action to enange the Site Contractors' QA Program for
. LJ non-conformances. The applicable paragraphs of UE&C Standard Documents QAS-1, QAS-3, and QAS-5 snall state, "Non-Conformance Procedures snall include provisions and j authority for voiding Non-Conformance Reports". However, the reason snall be clearly documented on the
.r7 Non-Conformance Report.
U
, Finding The changes to QA requirements are not always imposed on P' (QP.1-2) contractors in a timely manner. An example is that the
_a piping installation contractor is working to an outdated revision of UE&C Specification QAS-1.
Corrective The Site Contractors nave been issued the latest revision Action of the applicable stanoard occuments such as QAS-1.
T However, the Purcnase Orders have not been enanged to show
_j tnese latest revisions. Cnange Orcers to all Site Contractors are being developed to show the latest 1 revisions ano make tnem part of the contract. Cnange
- Orders will ce issued for each new revision of the stanoard occuments.
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PERFORMAtCE EVALUATION
SUMMARY
Construction Project Seabrook Station II j Performance Area: QUALITY PROGRAMS Objective No. QP.1 IV. Areas of Weakness & Corrective Action; Good Practices Finding The YAEC Seabrook QA Manual does not include all require-p (QP.1-3) ments in the SAR. For example, the Manual's reference to j applicaole Regulatory Guides coes not include all Regulatory Guides listed in the SAR.
~i.
d Corrective Table 1.1-3 of the YAEC Seabrook QA Manual lists quality Action related Regulatory Guides applicaole to tne Seabrook
[ Project. A Manual Procedure Change is being prepared to L upcate the table to the Regulatory Guide revisions ano dates, to conform to tnose listed in Section 1.8 of the q FSAR. This Procedure Change is to be implemented by the a
3 end of December, 1982.
[. Fincing There are weaknesses in the UE&C Corporate QA training pro-U. (QP.1-4) gram seneoule implementation. The training sessions are r- not being provideo in a timely manner, as evidenced by
! training sessions whien were scheduled but did not take u place,
$'L3 Corrective The R & QA Training Schedule is being revised. Necessary Action make-up sessions will be conducted ana attencance monitored. The next session is scheouled for November 23, I
1982.
w Fincing Procedures related to tne UE&C QA Engineer's review of (QP.1-5) ASME III Drawings are not in sufficient cetail to assure J
than an acequate review is performed. This is supportea by
=(1 the lack of instructions and/or checklists in the proceoures.
J y, Corrective The typical R & QA checklist for review of UE&C Drawings
, . . Action for ASME Section III will be incluoed in the Project QA i
'O' Procedure QA-3. Advanced Change Notice #83"has been issued.
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r-PERFORMANCE EVALUATION DETAILS Construction Project
- Seabrook Station Performance Area: QUALITY PROGRAMS Objective it. QP.i
- QP.1-1 Various contractor's quality programs should be improved to ensure proper identification, resolution, and aisposition of non-conforming 7
concitions. volaing of NCR's is not presently permittea by the a contractor's or UE&C's procedures, however instances were noted wnere this was being Gone.
~-
0 Fif ty (50) Non-Conformance Reports (hCR's) were reviewed at
_; the HVAC Contractor's quality control office.
Approximately four (4) out of fifty (50) NCR's were marked
, volo and notea as resolvea, referencing contractor Request i: For Information (RFI) or Engineering Cnange Authorization J (ECA). This process of voicing NCR's is not acoresseo in tne contractor's or UE&C's procecures. The 4 NCR's in
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question oealt with violation of a 1-1/2" clearance
,, requirement for seismic HVAC ductwork stated in UE&C's Specification #9763.006-45-15. The specification was r-subsequently revised to relax the clearance requirement.
1; The NCR was voiced. The proceoure requires that the NCR be dispositioneo. The procecure woulo have been satisfied if the NCR were cispositioned in accorcance with the revised
[, specification.
o The Piping Installation Contractor personnel are not 4- following the approved proceoure for hanoling of i i Non-Conformance Reports. NCR's are being " VOIDED" and procedures ao not address autnorization to " VOID" NCR's.
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o Reviewed NCR log from January 4,1982 thru October 27,1982 (NCR #1821 thru NCR #3714).
- , o 157 NCR's (8%) nave been " VOIDED".
t o The contractor's procecure has no authorization for
, , " VOIDING" of NCR's (XV-2, Rev.13) .
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.J PERFORMAtCE EVALUATION DETAIi.5 Construction Project Seabrook Station fl O Performance Area: QUALITY PRC@AMS Objective No. QP.1 t
QP.1-2 The system for ensuring all contractors will comply with the latest Jl Regulatory Guides and stancaros was found to be ineffective at times, as evidencec by the following example, fi_j o In trying to verify that the Piping Installation Contractor was committec to ANSI N45.2.6-1978, it became apparent, auring m, conversations with various QA/QC personnel, that the 1973 version i
.a was being used.
o Tne same coservation can be maoe for other recent stancarc
{ upoates (see enanges in S. A.R., Feoruary,1982).
L o No change in purchase oroer nas been issued by UE&C concerning this item. A revision was mace to UE&C's specification QAS-1,
]- nowever it was not incorporated into the contractor's contract.
o In general, the acequacy and timeliness of this system is weak.
,1
,a QP.1-3 Several quality-relateo Regulatory Guices/ ANSI Standards referencea in the Seacrook S.A.R. are not acequately reflected in the YAEC Seabrook
o Regulatory Guices 1.58, Rev.1,1.144, Rev.1, and 1.146, Rev. 0
, a.m not listea in tne Seabrook QA Manual (Table 1.1-3). In ac11 tion, the requirements of these Regulatory Guices are not i inclucea in the appropriate manual sections.
[' QP.1-4 The Corporate UE&C QA training seneoule for 1932 is behind by three (3) i sessions. The Indoctrination & Training Coorcinator may not have acequate time allocateo to perform tnis function, i o The 1982 QA trainirg scheoule listed three (3)
- sessions that nave not been performea.
{^ o No change in the schedule was issueo.
!J o The Coordinator could not produce a list of QA personnel who have
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attenced the mandatory QA Indoctrination Program. No such list or matrix exists at the present time. ,
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a PERFORMAPCE EVALUATION DETAILS Construction Project Seabrook Station
'r j Perfomance Area: QUALITY FROGRAMS Objective No. QP.1 QP.1-4 o A possible reason the Cooroinator nas not kept up to cate is that il.'
he is committed to other important project assignments.
QP.1-5 There were insufficient instructions / checklists in the procecures to
!j; perform reviews of ASME III crawings ana specifications by the UE&C Quality Assurance Engineer (QAE).
m o Proceoure QA-3, Revision 10, 12/17/77, Paragraph IV.E.3.a.
I celineates the instructions for the QAE crawing review. It coes not provice adeouate oetail to perform this review. The
_[" completeness of :ne crawing review is depencent on tne a indivioual's experience ano knowledge of the necessary review items. A prescrioed checklist woulo provice uniformity of
, reviews ana ioentity of problem areas generally found in tne
- j arawing reviews.
o Procedure QA-3, Revision 9, 8/16/76, Paragrapn E.2.e.4 celineates 1 the instructions for the QAE specification review. It does not j provice acequate detail to perform tnis review. The completeness of the specificat.on review is cepenoent on the incividual's
.) experienca and knowledge of the necessary review items. A i
prescrioed checx11st would provide uniformity of review ano icentity of proolem areas generally found in the specification
,_, reviews.
a Otner Information That Supports The Summary ri -
- 1. All QA/QC programs included the appropriate program elements.
Procecures are written for items such as aucits, inspections, surveillances, non-conformances, corrective action systems, management assessments, and training.
2.. Personnel throughout the system were asked about the procedures that govern tneir joo. In general, personnel were aole to
- j icentify tne procecures that apply to their work function. QA personnel were aole to cescribe the hierarchy of QA accuments.
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PEHFORMAFCE EVALUATION DETAILS Construction Project q Seaurook Station Performance Area: QUALITY PROGRAMS Objective No. QP.1
- Other Information Tnat Supports The Summary
,, 3. QA/QC persomel continually monitor contractor workmansnip.
- Surveillance programs oy YAEC & UE&C were observed and founo to lJ meet procedural requirements. Problems were identified and correctea through this system. Personnel performing
' [1 surveillances, for tne most part, are well qualifieo. The
- tj surveillance senecules are oeing met and are modified when work or problems indicate an increase in surveillance activity is p necessary (one finoing concerning surveillances was identified in QP.1-2).
- 4. Daily activities were discussed with QA/QC persomel. Items
[
- J discussed included proceoure reviews, specification reviews, drawing reviews, non-conformance processing, surveillances, audits, and inspections. Most persomel had a clear ir, unoerstanoing of what was required of them both from a management
- ] stanopoint as well as a proceoural standpoint.
- 5. The QA classification of systems, structures, and components was
.) oiscussed witn personnel from various oepartments. Even thougn
. _) the system for classification appears complex, persomel were able to unoerstand the metnoas of classification, m'
j 6. The audit system was reviewed for completeness and effectiveness. Audit reports contained gooo detail and
, ioentified problem areas. Audit schedules are being met and are
,s j; sufficient to cover the appropriate program elements. Leaa auditors are adequately trained and certified to conduct aucits.
r' 7. Inooctrination in the QA program was conoucted by all evaluated i organizations. The indoctrination program provides an understanoing of quality requirements.
t,
. 8. Stop work authority was examined with various QA persomel. All lu people interviewed unoerstood now a stop work order operates. -
Several stop work orders have been written. In most cases, YAEC hy and UE&C try to get the contractors to initiate the stop work order. No problems were loentified in this area g t._
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PERFORMAfCE EVALUATION SlfiMARY Construction Project Seadrook Station Performance Area: PROGAM IH'LEENTATION Objective No. QP.2 l
Evaluator (s) A. Colello, A. Cooper J
I. Performance Objective Quality assurance ana quality control functions snould be performec in
- , a manner to support and control tne quality of tne project activities.
J II. Scope of Evaluation
{I
!, This evaluation examined tne implementation of the overall Owner's Agent, A/E, and various Contractors' Quality Assurance Programs. The F, purpose was to verify the implementation of the QA Programs througn: a L, review of QA/QC interfaces with project personnel; an examination of QA/QC organizational " independence" anc freccom from harrassment anc intimidation; and a review of Contractors' QA Program for adequate implementation.
This included interviews with corporate and site managers, supervisors, ano octn QA ana non QA personnel. Numerous quality documents were reviewed in tne performance of this evaluation.
] III. Conclusion J
In general, tne implementation of the QA Programs is satisfactory. The j QA Programs acequately oefined the inoependence of QA/QC personnel.
" QA/QC personnel had sufficient interfaces estaolished and were free from harrassment anc intimidation. One Good Practice relatec to A/E Vendor Surveillance and a weakness related to Owner's Agent Surveillance was ioentified for this performance oojective.
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l;i a PERFORMAtCE EVALUATION
SUMMARY
Construction Project
, Seabrook Station
} }: > Performance Area: PROGRAM I>PLE>ENTATION Objective No. QP.2 IV. Areas of weakness & Corrective Action; Good Practices Fincing The following Good Practice was noteo. The UE&C Home
') (QP.2-1) Office Venoor Surveillance group supervisor effectively
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coorcinates witn the Vencor Surveillance Representatives.
This was evioenced by the use of " Vendor Surveillance y3 Directives" to the Representatives, b
Finding The Second ano Thiro Level surveillance process does 4 (QP.2-2) not always assure that requirements of the project are i
satisfied. Tnis is evicenced by numerous concerns with the Piping Contractor which were not corrected as a result of the Surveillance Program.
.J Corrective The second and third level surveillance program has been Action effective in loentifying the concerns relatec to the Piping aj Contractor. The finding may be inoicative that positive corrective actions nave not been implemented in a timely fasnion to correct identified or potential deficient
- conoitions. In tnis vain, management action has been taken to strengthen the project corrective action programs as evloenced by the response to 0A.3-1 and the following
,j management actions: '
J
- a. A program for escalation of corrective action reporting to executive levels of contractor
- management via an Immediate Action Request (similar to NRC Immeciate Action Letters).
- b. Management directives to construction management ij personnel reiterating the roles, outies, and j'
responsiollities of those parties responsible for the t
' cirection of construction activities.
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PEPEORMAtCE EVALUATION SLNMARY Construction Project
. , . Seaurook Station l). -
Performance Area: PROGRAM IWLEENTATION Objective No. QP.2 il
>J IV. Areas of Weakness & Corrective Action; Good Practices 1
- t Corrective c. Implementation of single project installation J Action and inspection proceoures to be utilized oy all contractors, i.e., Hilti Bolt installation, b a. Directives to surveillance and audit personnel to remain cognizant of untimely or ineffective remeolal actions and report same to nigner levels of
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j management for action.
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d3 PERFORMMCE EVALUATION DETAILS Construction Project Seabrook Station ,
i3o .,
Performance Area: PROGRAM I!PLEMENTATION Objective No. QP.2 QP.2-1 The UE&C QA Venoor Surveillance section nas dev31oped "Vencor Surveillance Directives".
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[j o The purpose of these directives is to inform venoor surveillance representatives of enanges in code requirements / interpretations, <
recent problem areas, or changes in the way surveillances are '
o conoucteo.
O Each venoor surveillance representative has a controlled directive copy for reference. These are utilized during f,l cepartment training sessions.
o This system snould be a benefit in the performance of venoor surveillances.
QP.2-2 Many concerns related to the Piping Contractor are discussed in other 1 sections of this report. While eacn isolated Finding cannot be attributea to Second and Third Level surveillance activity, and it is recognizec that the Contractor is responsible for First Level QA/QC, the large numoer of concerns may be symptomatic of a general concern i
with the effectiveness of the Surveillance Program. The following concerns are listed for background instruction to support the above Finding.
Il o QA.3-1 & (QA/QC providing direction)
CC.4-1 i' o CC.1-1 (Incorporation of ECA's onto Construction Aices)
'j o CC.4-2 (Redunaant pipe support inspections) o PS.6-1 (Availability of updated documents at Rod Room) o QP.1-1 (Voiding NCR's) o CC.4-6 (Pipe hanger installation to annotated drawings)
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o CC.4-3 (Hilti bolt installation iroolems)
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PERFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station
'u il Performance Area: PROGtAM IWLEMENTATION Objective No. QP.2 Other Information Tnat Supports The Summary
- 1. During tnis assessment, it was apparent that the overall QA/QC jl functions were performeo in a manner that was conducive tu
> controlling and improving the quality of the project,
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- 2. The organizational responsibilities were discussed with lj management personnel througnout the project. There is adequate freedom from cost and seneoule pressures. These responsibilities are written up in sufficient detail to ensure their incepenaence.
- 3. In all cases, it was observed that QA/QC personnel receiveo a cooperative attitude from project personnel. In several cases, f; it was notea tnat QA people have received project support wnen 1j proolems arose with contractors.
, 4. During discussions with QA/QC personnel throughout the project, it was evicent that harrassment and intimication does not exist.
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- 5. The QA/QC cepartments function in a manner that supports
'i1 management. Proolems are ioentified and corrective actions taken 1j to precluce reoccurrence ouring aucit, surveillance, and inspection activities (see concern in QP.2-2). Trena analysis
- c. reports have oeen written by corporate and site QA/QC
{ organizations anc forwarced to upper management for evaluation.
, 6. For the most part, manpower and budgets appeared adequate. Where
])
'a manpower requirements were less than acequate, contractors nave been instructed to increase their staff. It appears that the numoer of UE&C corporate QA personnel required to support the project may be marginal. This is supported by the findings
,j against QA training (QP.1-4) and the changes to QA requirements (QP.1-2).
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PERFORMAPCE EVALUATION StMMARY Construction Project l Seabrook Station
.)
Performance Area: INDEPENDENT ASSESSMENTS Objective No. QP.3 I
L Evaluator (s) A. Colello, A. Cooper
^1
[j I. Performance Oojective
.,, Management snoulo provide an effective, independent assessment of project activities affecting the quality of the project.
II. Scope of Evaluation The evaluation includeo a review of the Owner's Agent and A/E g indepenaent management assessments. The purpose was to verify tnat ll these assessments are: scheduled and planned on a periodic basis; performed by incividuals who are suitably qualifiec and are indepencent
, of areas assessed; ano utilizec to improve the overall quality program.
i) This included interviews with Owner's Agent and A/E corporate managers. Management assessment packages were reviewed to determine i
i the depth and acequacy of tne assessments.
U III. Conclusion Il U In general, the '~1ependent management assessments meet the requirements rr this Performance Objective. The assessments have been
[] seneouleo on a yearly basis anc personnel performing them nave U sufficient indepencence. However, the effectiveness of these assessments to improve the overall quality program was marginal.
i One (1) area of weakness was icentifiec in the area of Owner's Agent L] management assessments, that indicateo a need to strengthen this aspect of tne activity.
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s, ol il PERFORMAtCE EVALUATION
SUMMARY
Construction Project
_ Seabrook Station
,j Performance Area: INDEPENDENT ASSESSW.NTS Objective No. QP.3 I]
l;-,
IV. Areas of Weakness & Corrective Action; Good Practices
^
Finding The results of YAEC management assessments ao not
! ,l (QP.3-1) adequately address substantive issues, in all cases. An example was noted where the documented scope of the evaluation was too narrow to adequately determine the r3 effectiveness of the QA program.
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Corrective The scope of the management assessment of the Seabrook l ,' Action Construction Quality Assurance Program will be increased to L. provice an acequate overview of Program acequacy and implementation. This will be provicea:
7 l o througn participation by management staff personnel (as observers), on a quarterly basis, in internal
,_, and/or external audits, and I-o by expancing the areas anc broadening the scope of the annual management aucit.
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i-PERFORMMCE EVALUATION DETAILS Construction Project
~ Seacrook Station f Perfomance Area: INDEPENDENT ASSESSMENTS Objective No. QP.3
- r=
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j QP.3-1 The management assessment performed by the YAEC management team dio not contain sufficient oojective evioence to verify the depth and thorougnness of the assessment.
ly IO o Management Report 82-1, catec 5/26/82, indicates that a small percentage of procedures were reviewed. The checklist utilizea jP to perform tnis evaluation was only tnree (3) pages long.
1 o No oojective evidence was included in the assessment package to verify acceptacle or oeficient areas.
'-- o The scope of the assessment appeared to be too narrow. Only a
, . , portion of the oesign control program was evaluated.
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- U Other Information That Supports The Summary ijj
- 1. The results of indepenaent assessments conducted by YAEC and UE&C were evaluated for their effectiveness. The'YAEC assessment was
..., weak regaroing deptn and thorougnness (as indicated in Finoing
- )
- QP.3-1) . The UE&C assessment snowed that the programatic il J requirements as defined in their " Topical Report" were met.
I However, specific "now to" details on the conouct and reporting of management assessments were not well defined.
{b]
- 2. Both the YAEC & UE&C assessments for 1982 were performed by management inoividuals wno were independent of the areas to be jf)i j evaluatea. These indiviouals were suitably qualified to perform jJ indepenoent assessments.
ir' 3. The assessment reports were sent to senior management for their Q) review and approval. Corrective action letters were issued by senior management to the responsible supervisor for
- ,, aispositioning. All items were properly addressed ana closed out.
4i D.J 4. In general, the assessments identified weak areas, and corrective actions were taken. However, it was difficult to determine b: whetner or not the results are used to improve the effectiveness j of the quality program.
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- PDFORMAtCE EVALUATION
SUMMARY
Construction Project 7i Seabrook Station 1i' ~
Performance Area: CORRECTIVE ACTIONS Objective No. QP.4 E i
!j Evaluator (s) A. Colello, A. Cooper I. Performance Oojective
-., Conditions requiring corrections or improvements should be resolved in
- j an effective and timely manner.
l7 II. Scope of Evaluation e
The evaluation included a review of the Owner's Agent, A/E, and Contractors corrective action systems. The purpose was to verify that j,
corrective action systems: identify ano report conditions adverse to quality in a timely manner; involve management when corrective action is requirea; are effective in resolving reporteo items in a way that
!j ensures quality of future activities; and include trend analysis as a means of accressing generic proclems.
3 This included interviews with managers, supervisors, ana QA/QC personnel, as well as a review of selected documents to ensure the system was functioning properly.
.i
'j III. Conclusion
, In general, the corrective action program is satisfactory. Tracking
- anc Reporting systems appear effective and personnel were knowleogeable of tne system.
l One Good Practice regaroing Owner's Agent tracking of reportable items
- i. was identified for tnis performance oojective.
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PERFORMAtCE EVALUATION
SUMMARY
Construction Project
, Seabrook Station f,j Performance Area: CORRECTIVE ACTIONS Objective No. QP.4
{ IV. Areas of Weakness & Corrective Action; Good Practices Finding The following Good Practice was noted. YAEC tracking
- ([ (QP.4-1) of reportaDie oeficiencies (10CFR50.55e and 10CFR21) is
['l performed in a controlled and effective manner. Assurance is provided that all items will be addresseo in a timely r]
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PERFORMAPCE EVALUATION DETAILS Construction Project Seabrook Station
\I Performance Area: CORRECTIVE ACTION Objective No. QP.4 q
j "1 QP.4-1 YAEC tracks all reportable deficiencies (10CFH50.55e ano 10CFR21) oy utilizing a " Future verification List", tnat recoros all communications along with the status of eacn item. This list provices a enronological
!} nistory of the processing of each item, ano it is upcated quarterly.
i This action exceeds the program auditing requirements of tne YAEC Quality Assurance Organization.
R U
Otner Information That Supports The Summary
! 1. Various organizations were assessed in the performance of this L
evaluation. The organizations directly interviewed were UE&C Quality Assurance (Philadelphia), UE&C Quality Assurance I (Seabrook), YAEC Quality Assurance (Framingham), YAEC Quality
!j , Assurance (Seabrook), and various contractor's Quality Assurance organizations.
j 2. All the above organizations cemonstrated their knowledge and understanding of corrective action systems. All of the tracking and trending metnocologies were similar and appeared to be
] working.
I
- 3. Based on interviews and managment reports, it was determined that management is adviseo of items requiring corrective actions d
l anc is actively involveo in directing resolution of identified problems.
l} 4. The Civil / Structural contractor has a reporting system that
.J provices a status report to the project manager on a monthly basis regarding items requiring corrective action . The project manager replies to the QA department, aodressing the action j taken, or to be taken, on an item by item basis.
, 5. The YAEC QA oepartment maintains a tracking list on all l significant deficiency reports on the project, documenting all communications and corrective action on the part of all contractors, l
- 6. For the most part, trend analysis reports generated by the contractors and YAEC appear to be adequate in addressing generic problems and requiring corrective action.
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PERFORMAfCE EVALUATION Sl14 MARY Construction Project Seaorook Station l
Performance Area: TEST PROGRAM Objective No. TC.1
- P (j ,
Eva$uator(s) G. Reardon I. Performance Objective
{
' The test program should verify the plant's full capability to operate as intended oy testing tne plant's systems functionally.
.L II. Scope of Evaluation
.' The test program was evaluated oy performing a detailed review of the Preoperational Test Program manual, a select sample of test procedures and Test Program Instructions, ano interviews with key test and startup
)tJ engineering personnel. Approximately 20 manhours were expendeo evaluating tne Test Control Performance Objectives.
- O
.of III. Conclusion ll The standards of this Performance Objective are Oeing achieved.
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PERFORMAPCE EVALUATION DETAILS Construction Project Seabrook Station u Performance Area: TEST PROGRAM Objective No. TC.1 Other Information That Supports The Summary
- 1. A Preoperational Test Program Description manual has been I
j developed and approved by the appropriate construction ano station managers (i.e., UE&C, YAEC, & PSM1). The manual was c developeo per the requirements of FSAR Cnapter 14 and NRC Reg.
Guioe 1.68, Revision 2. The manual clearly identifies the test
{" organization's responsiollities and was given wide districution within tne construction management organization.
I
- 2. A sampling of test procedures were reviewed and indicated that u
the principal design organizations are involved in the development and review process. Test Program Instructions p!
t (TPI's) 61 & 62 provide the guidance in this area.
3.
, Section 4.0 of the test manual fully cescribes the scope of system testing. Detailed guidance for test conduct and evaluation of results are provided by TPI's 64 & 65.
4 1, A system and procedure for identifying, tracking, and resolving t any nonconforming and deficiency conditions is estaolished and oefined in TPI-31.
- 5. A sampling of test proceoures reviewed showed that station i
proceoures are referenced and used to the extent practicable to perform tests.
[ij 6. Section 7.0 of the test manual fully aescribes the interrelationsnips between the Test and Quality Assurance Programs.
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J PERFORM 4CE EVALUATION
SUMMARY
Construction Project j Seabrook Station l "1 '
Performance Area: TEST @0LP ORGANIZATION & STAFFING Objective No. TC.2 n
Evaluator (s) G. Rearoon l I. Performance Objective q The test group organization and staffing would ensure effective i implementation of the test program.
II. Scope of Evaluation The evaluation of tne test group organizational structure and staffing r,
adequacy consisteo of a review of organization charts, the
{, Preoperational Test Program Description Manual ano several Test Program Instructions, a review of personnel ano qualification recoros and key position oescriptions, interviews with leaa engineers, and a walk-thru i plant inspection.
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- III. Conclusion Tne stancards of tnis Performance 00jective are being achievec.
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I PERFORM 4tCE EVALUATION DETAILS Construction Project Seabrook Station J Performance Area: TEST GROUP CRGANIZATION & STAFFING Objective No. TC.2
,- Other Information That Supports The Summary
- 1. The Test Group organization ana interface with the Construction Organization is clearly oefined in the "Preoperational Test Program Description" manual. The manual was reviewed ano approved by the Construction and Station Management (i.e., YAEC, UE&C, & PSt+t) and was given wide distribution. Several Test
.- Program Instructions (TPI's) existea, to provide furtner oefinition of respons1Dility and jurisdictional areas. All TPI's
.) are reviewed and approvec by representatives from the YAEC, PSNH, j & UEAC organizations.
- 2. A sampling of the Test Department training and qualification records confirmed tnat personnel at all levels are qualifiec ano b trained to perform their assigned tasks. Qualification ano training requirements are oefinea in the " manual" ano TPI-81.
q j 3. At present, tne test activities were limited to primarily Phase 1 Construction verification. The organizational chart ana walk-tnru inspections confirmed that the test staff and
[3} construction support were adequate to support the existing and
)
near term activities. The Test Department is continuing to increase their staff to accommocate longer term work loaos as
~j more equipment / systems become available for Phase 1 and
,. j subsequent phase testing. No evicence was found in a record searen or curing walk-tnru inspection that testing haa or was
,. being celayea oue to inacequate staffing.
b 4. The test department organization includes operations and maintenance personnel from PSNH Seaorook Station staff. Also, the station staff is becoming more actively involved in the J)'
( testing process as evioenceo by PSNH memo #SS7202, catea j 9/20/82. In this memo, the Seaorook Station Management nas y3 agreed to get involved in the Startup Preventive / Corrective ll Maintenance effort prior to turnover of equipment / systems to them from the test group.
I 5. Test department key position cescriptior.:, exist and the personnel
- records confirm tnat personnel who fill these positions meet the experience and qualification requirements as written.
- 6. Test department personnel training and qualification recorcs are maintained and stored in the YAEC QA recoro vault.
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-) PERFORMAtCE EVALUATION SLNMARY i, Construction Project Seabrook Station Performance Area: TEST PLAN Objective No. TC.3
<J Evaluator (s) G. Reardon
'd I. Performance Objective
'].j The test organization snould prepare a plan ano a senedule that describe the sequence of system or component testing to support major scheoule milestones.
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II. Scope of Evaluation "1
J Tne test plan was evaluated by conducting interviews with appropriate scheouling engineers, an inspection of scheduling activities performeo n to cate inclucing evicence of proper interface with overall project j scheoules ano icentification of appropriate nold points, and a review of relateo cocumentation.
't g III. Conclusion i
The stancaros of tnis Performance Objective are being achieved.
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- PE.VORMAtCE EVALUATION DETAILS Construction Project
., Seabrook Station
.il Performance Area: TEST PLAN Objective No. TC.3
,j Other Information That Supports The Summary - TC.3 1.* The test department organization has a distinct group assigned to develop and maintain a test schedule. This group reports a
directly to the test department manager. This group was
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presently working on a reviseo test schedule which cetailed the sequencing and appropriate nolo points for all pnases of startup testing. The seneduling engineer interviewed oemonstratec knowleoge in scheoule preparation ano stated previous Joo-relatea
., experience from anotner jou site.
- 2. The test plan and senecule are identifieo in the UE&C 12 month and 12 week "Look Ahead" schecules. 91-weekly meetings are helo O witn UE&C's Construction Management and contractor
[+ representatives to review status of Bouncary Identification Packages (BIP's), well in advance of the scheduled turnover from construction to the test department.
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- 3. BIP's are prepared Dy the Test Department to define a testable
_' portion of a plant system. The BIP's are packaged Dy technical discip1 hts (i.e., Meenanical, Electrical, I&C, etc.) and forwarcea to the appropriate contractor and UE&C's Ct.nstruction Management well in advance of the scheduled turnover.
l 4. A review of the Test Schedule under revision inoicated that it contains detail identifying all phases of startup testing. The required test elements are further detailed in the system test j}
2; index, as cerined in TPI-51.
- 5. The status of testing is monitored by a test chronological log 11 that is cefined in TPI-64.
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l PERFORM 4CE EVALUATION
SUMMARY
Construction Project 1 Seabrook Station j
Performance Area: SYSTEM TURNOVER FOR TEST Objective No. TC.A Evaluator (s) G. Rearoon
] I. Performance Objective
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The construction testing and turnover process shoulo be controlleo
-) effectively to ensure tnat program objectives are met.
.j II. Scope of Evaluation The evaluation was performed by walk-thru inspections of the test activities, interviews with responsible personnel, and review of related manuals and procedures.
III. Conclusion i
Tne stanoaros of this Performance Objective are being achieved.
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x PERFORMAtCE EVALUATION DETAILS Construction Project q Seabrook Station Performance Area: SYSTEM TURNOVER FOR TEST Objective No. TC.4 Other Information That Supports The Summary 7 1. The test oepartment " manual" and various TPI's cetail
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I jurisdictional areas regarding construction turnover anc succeeding testing by the startup group. Responsibilities are
- p. clearly oefinec in the Bouncary Identification Package developed b by the startup group and given to UE&C's Construction Management and appropriate contractors.
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- 2. Tests are performeo and the results evaluatea for conformance to a design requirements, per the requirements of TPI's 61 (Preparation of Test Procedures), 64 (Test Performance), ano 65 (Test Completion Review & Approval).
- 3. TPI-12 identifies tne requirements for retesting ano the conditions that require a retest. No review of test recoros or fj ;
walk-thru inspection was performed to confirm that the new test instructions were being followeo. However, the YAEC QA recora did not reveal any proolems in the retest area.
- 4. Once a contractor has completed a BIP for turnover, UE&C's Construction Management and the startup engineer perform a
.l walk-thru of the system / equipment. This process is not lJ specifically stated in the test manual or TPI's, but reporteoly i
is performed as a general practice.
7; 5. The turnover process is clearly defined in various TPI's and the b BIP package, r ., 6. Turnover documents contained in the BIP and various TPI forms ji identify material ano equipment bouncaries and provide for h identifying exceptions / deficiencies existing at the time of i
s turnover.
b 7. Various TPI's define establisned methods for effectively tracking and correcting turnover exceptions /ceficiencies.
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d 8. The bi-weekly BIP status meetings, attendeo by UE&C Construction Management, contractor, and test department representatives serves to ensure timely turnover of equipment / systems as
!] seneduleo.
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PERFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station
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Performance Area: SYSTEM TURNOVER FOR TEST Objective No. TC.4 Other Information That Supports Tne Summary
-, 9. Walk-thru inspections of test activities indicated tht tagging i ano contro11eo access metnocs are effectively employeo to insure area cleanliness. Maintenance is being performed and a new TPI is being oeveloped to accelerate the involvement of station staff l personnel in equipment / system maintenance of the initial J construction turnover.
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Qjl PERFORMAtCE EVALUATION
SUMMARY
Construction Project Seabrook Station F1 y: Performance Area: TEST PROCEDURES & TEST DOCu{NTS Objective TC.5 Evaluator (s) G. Rearaon rq I. Performance Objective Test procecures and test accuments shoulo provide appropriate direction and snoula be used effectively to verify operational anc cesign features of respective systems.
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II. Scope of Evaluation
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The primary empnasis in evaluating this performance objective was on the review of occuments for acequacy ano a walk-tnru inspection to assess conformance to procedural requirements.
III. Conclusion FL The standaros of this Performance Objective are being achievea.
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d PERFORMAtCE EVALUATION DETAILS Construction Project Seacrook Station Performance Area: TEST PROCEDURES & TEST 00CLENTS 00jective No. TC.5 1 Other Infomation That Supports The Summary Jj
- 1. A sampling of test procedures reviewed inoicated that appropriate p technical cata is referenced anc factored into the proceaure, j The requirements that this be cone are cerined in TPI-61.
, 2. A review' of test prdcedures being used during walk-thru j
inspections ircicated that they had been preparea and approvea a well in acvance of the testing in progress. Further, review indicatec that test procedures are preparea in draft form ana I finalizea (reviewed /approvea) at time of turnover (i.e., Phase V
" testing). In support of this practice, it was notea that Pnase 2 procedure drafts are 47% complete and Phases 4-6 drafts are 35%
complete. All of these drafts are being prepared well in aavance of tneir testing seneoule neea.
- 3. A sampling of the test procedures was reviewed and indicatec that r the test ou,)ectives, pre-requisitions, test bouncaries,
[ acceptance criteria, etc. were clearly defined.
<, 4. Test proceoures oeing used in the fiela were observed to be d appropriately reviewed ano approved per TPI-62 (Review & Approval p- of Test Proceaures).
l 7 5. A review of tne testing in progress comparea well with the
'~ applicaole test procedure. Tne test log coincioed with the testing stop being performea.
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- 6. Retesting was not caservea in tne fielo. mwever, TPI-12 (Retest J
Requirt.ments) clearly aefines conditions anc requirements for retesting.
J 7. The " test incex and test results" oefinea in [PI-51 are given an r
indepenaent review anc approval by the Systems Leau Engineer and Test Group Supervisor. TPI-65 provides furtner guicance for test
[t completion review ano approval.
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!"l, l# 1 U' PERFORMAtCE EVALUATION
SUMMARY
Construction Project '
Seabrook Station
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[j l Performunce Area: SYSTEM STATUS CONTROLS 00jective TC.6
{ Evaluator (s) G. Rearcon I. Performance Ob)ective A metnod shouic exist to ioentify the status of eacn system or o component and tne organization noloing control or jurisdiction over
{" that system or component to prevent interference and ensure equipment and personnel safety.
V E II. Scope of Evaluation The primary enphasis in evaluating this performance objective was on q{ the review of occuments for acequacy and a walk-thru inspection to assess conformance to procecural requirements.
E O III. Conclusion Tne stancaros of this Performance Objective are being achieved.
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PERFORMAtCE EVALUATION DETAILS Construction Project Seabrook Station
., Performance Area: SYSTEM STATUS CONTROLS Objective No. TC.6 Otner Information That Supports Tne Summary J
- 1. For systems / equipment under Test Department jurisdiction, TPI-23
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(Safety Tagging) cefines a system for assuring personnel and
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equipment safety ano ioentifying system / equipment status.
Appropriate tagging was noted curing walk-thru inspections of testing work in progress.
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- 2. Tagging and test logs are being used to l'nJre up to cate status of a system test.
j 3. The test director is tne authorizing agent for test status changes wnich are occumentea in the test enronological log.
TPI-64 defines this process. A walk-thru inspection confirmea that the test status log was up to cate.
4 Two (2) tagging systems are used at Seaurook. A jurisdictional tagging system uses color-coded tags or stickers to " identify
._; what organization (test or station staff) nas responsibility for equipment / systems". Juriscictional tagging is cefinea in TPI-21 r- ano is being implementea as defined.
I A safety tagging syscem oefined by TPI-23 is being used by the Test Department wnile the equipment / system is under their jurisdiction. Once jurisaiction is transferred to the station staff, their procedure for safety tagging will be employed.
, 5. Control of temporary fiela modifications, control of construction
[- work after initial turnover, and the requirements for assemoling a complete anc occumentea system test package are all clearly cefinea in various TP1's. However, verification that these controls and requirements were ceing implemented was not pursueo, m because all testing to date has involvec only Phase I (Construction verification Testing), and only 10% of that program l has been completed or is in progress.
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