ML20084L023
| ML20084L023 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/04/1984 |
| From: | Donlon W NIAGARA MOHAWK POWER CORP. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-83-137, NUDOCS 8405140307 | |
| Download: ML20084L023 (74) | |
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DC. S hO NIAGARA MOHAWK POWER CORPORATION NIAGARA MOHAWK 300 ERIE SOULEVARD WEST SYRACUSE. N.Y.13202 PRESIDENT May 4, 1984 Mr. Richard C. DeYoung, Director Office of Inspection and Enforcement .
U. S. Nuclear Regulatory Commission Washington, DC 20555 Re: Nine Mile Point Nuclear Station Unit #1 NRC Civil Penalty - $80,000 Docket No. 50-220 EA 83-137 Nine Mile Point Nuclear Station Unit #2 NRC Civil Penalty - $100,000 Docket No. 50-410 EA 83-137
Dear Mr. DeYoung:
Your letter of March 20, 1984, contained four enclosures concerning our Nine Mile Point Units 1 and 2, which required response from Niagara Mohawk.
This letter provides responses to Enclosures 1 and 2 (Notices of Violation and Proposed Imposition of Civil Penalties). Attachment I to this letter provides the infonnation required in connection with Unit 1, and Attachment 2 contains the corresponding information for Unit 2. This information is being provided pursuant to the provision of 10 CFR 2.201. We do not intend to protest the proposed civil penalties pursuant to the provisions of 10 CFR 2.205. Our responses to Enclosures 3 and 4 of your Marcn 20, 1984 letter will be forwarded within the specified time periods.
Your letter also requested that the Chainnan of the Board and I meet with you and the Regional Administrator for NRC's Region I to discuss the cited violations and corrective actions being taken. As you know, this meeting was held in your offices in Bethesda on March 27, 1984. From our viewpoint, it was a most productive meeting. During these discussions, we acknowledged our awareness of the need for certain corrective actions and our resolve to deal with these both promptly and effectively.
With respect to Unit 2, we described how, even prior to the NRC j Construction Appraisal Team (CAT) Inspection, a review of management l capabilities had already been initiated by us. This was to identify the Dest i means to successfully complete the project in full compliance with all quality and safety requirements. This review was conducted by Management Analysis l Company (MAC) and resulted in a number of changes to the project. These were detailed in Mr. G. K. Rhode's January 27, 1984 letter to Dr. Thomas E.
Murley. Briefly, these changes can be summarized as follows:
8405140307 840504 PDR ADOCK 05000220 PDR s G /g
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~ Mr. Richard C. DeYoung Page 2 Establishing the position of Project Director with overall responsibility for project design, construction, and preliminary and pre-operational testing. This position has been filled by a highly qualified and experienced individual who is physically located at the construction site.
Enhancing the management interface between Niagara Monawk and Stone and Webster by establishing a Stone and Webster Project Director reporting directly to the Niagara Mohawk Project Director. Tnis position has been filled by relocating the Stone and Webster Manager of Projects to tne site. In addition, certain functional groups which were heretofore situated in Syracuse, were physically relocated to the construction site.
Strengthening tne Project organization by adding several highly qualified and experienced individuals from MAC into the project to fill key management positions.
Strengthening the construction QA organization with the addition of a highly qualified and experienced QA Manager and several additional QA specialists. As part of this effort, strengtnening of formal quality engineering and site audit functions has been instituted. Their primary purposes include quality planning, resolution of quality problems and site quality audits.
Obviously, a strong experienced project management organization is a key factor in assuring full compliance witn quality and safety standards.
Additionally, we stated to you our intention to establish and maintain quality goals which strive for high standards of excellence. We also stated our intent to upgrade our auditing role, as licensee, over all quality activities being performed, including those of key contractors. Tnese enhancements are well underway through tne combined efforts of tne newly-strengthened
. construction QA organization and the new project management team.
With respect to Unit 1, we provided you with similar assurances that all safety related activities at this station will be properly managed and controlled. We too have been concerned by certain performance indicators immediately following the lengthy and very demanding piping replacement outage, most of which involved first-of-a-kind type work. This experience is in sharp contrast with the excellent operating records this station has achieved over the years. A number of steps were taken to reverse this recent trend which were described to Region I representatives at a November 15, 1983 Enforcement Conference. Subsequently, tne Senior Vice President - Nuclear has directed management and supervisory personnel to arrange to devote more time inplant with greater direct oversight of the various operations being performed. We are also continuing to review the merits of incentive / penalty programs as a possible means to avoid, or at least reduce, the occurrence of violations and nonconformances. We will keep you advised of any decisions which may be made in this regard.
4 r Mr. Richard C. DeYoung Page 3 We would like to assure you again that Niagara Monawk welcomes tne independent appraisal of site and corporate management and tneir functions because we share your desire that this station acnieve a hign level of pcrformance excellence.
Niagara Mohawk representatives of all levels, including tne Chairman of the Board and myself, welcome continuing discussions of our nuclear activities, including progress being made to resolve your concerns. We believe it would be useful to encourage these types of interfaces so that all parties are informed and assured of the effectiveness of our programs. To this end, I intend to personally interface with Dr. Thomas Murley of your Region I King of Prussia office.
Despite the above-described corrective and preventive actions taken by this Corporation botn before and after its receipt of the Notices of Violation, as previously stated, Niagara Monawk Power Corporation does not intend to protest the civil penalties imposed. Accordingly, please find enclosed this Corporation's check in tne amount of $180,000, representing paymat in full of the above-captioned civil penalties.
Very ly yours, 1
William J Donlon Presid xc: Dr. Thomas Murley Region I, US NRC 1
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e 1- o STATE OF NEW YORK )
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COUNTY OF ONONDAGA)
On this 4th day of May, 1984, before me personally came WILLIAM J. DONLON, to me known, who being duly sworn did depose and say that he resides at 8336 Craine Drive, Manlius, New York 13104, that he is the President of Niagara Mohawk Power Corporation, that he has read Attachment 1 and Attachment 2 (A-H thereof), and that the statements made therein are true to the best of his knowledge, information and belief, s
William J onlon, President NIAGARA M0 HAWK POWER CORPORATION Subscribed, acknowledged and sworn to before me this 4th day of May, 1984 ,
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Notary Public CHNSTWE AUSTW Publicin the 31sts of lips Vert
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ATTACfNENT 1 f
JThis attachment provides a response to tne Notice of Violation for Unit 1. j i
A. The alleged violation was stated as follows: l Technical - Specification Limiting Condition for Operation 3.3.0 requires - !'
primary containment integrity be maintained whenever the reactor is critical. Section 1.11 of the Technical Specifications defines containment integrity and specifies as one of its conditions that all
. nonautomatic primary containment isolation valves be closed, if not !
required to be open for plant operation.
Contrary to the above, from June 29, 1983, until October 17, 1983, while the Unit ' l reactor was critical and at 100% power, primary containment integrity was not maintained in that a nonautomatic primary containment i isolation valve on a test connection for torus water level transmitter
.LT-58-04.was open, and tnis valve is not required to be open during plant operations.
Niagara Mohawk's response to the alleged violation is as follows: ;
i Niagara Monawk concurs that a Tecnnical Specification limiting condition for l operation was violated by failing to maintain closed a non-automatic primary g containment test connection isolation valve whicn is not reonired to be open i for operation. We believe that tne test connection isolation valve was left .
open as a result of a lack of description of specific steps necessary to carry l out the return to service section of tne surveillance procedure.
Corrective and preventive actions being taken are as follows:
- 1. Tne surveillance procedure has been revised to require tnat the valve De I wire sealed closed and a pipe cap installed as part of the return to ,
t service section. t
- 2. Separate verification requirements tnat all valves for botn torus water f
level transmitters are in the in-service condition nave been added to the ,
" Pre-Startup Valve Line-up Check." f
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- 3. A special training program has been developed and is being implemented to stress the adherence to Technical Specifications. This training is being provided to operators, instrument and control technicians, chemistry technicians, maintenance personnel, radwaste operators and fire brigade personnel. This training program is approximately 80 percent complete.
- 4. Niagara Mohawk has initiated an overall analysis of our corporate and station organization which will be discussed in detail in our response to your order.
In particular reference to this notice of violation, Niagara Mohawk has retained an independent consultant (Pickard, Lowe and Garrick, Inc.) witn experience in the field of reviewing operating procedures and technical specifications, to conduct a specific review of the Unit 1 Technical Specifications and Surveillance Procedures. Following tne completion of the review, a final report will be issued which will address the following tasks and issues:
- a. An index of the Nine Mile Point 1 surveillance requirements and associated test procedures.
- b. A cross-reference index of the surveillance test procedures and the associated components in the frontline and support systems whicn must be demonstrated as operable.
- c. A listing of specific areas in the surveillance test procedures where additions and/or changes need to be made.
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- d. A listing of deficiencies in the current surveillance requirements as determined by review of tne associated LCOs.
- e. A listing of omissions or errors in tne current test procedures, including:
- 1. Inadequacies in the procedures used to demonstrate component /systen operability.
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- 2. . Inadequacies in the removal / return-to-service instructions. ;
- f. Recommended actions to correct the deficiencies identified in Items c ,
t through e. j
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i Niagara Mohawk will carefully review all recommendations of the report and f I- take appropriate action in connection with its recommendations.
L The alleged violation was stated as follows:
- 8. j Technical Specification Surveillance Requirement 4.2.7(a) requires that at ;
least once per operating cycle, the reactor coolant system isolation ,
valves shall be tested for closure times.
Contrary to the above, .
- a. From June 1973 until July 1983, a period of time covering five j operating cycles - over ten years, valve 39-05, a reactor coolant !
system isolation valve on the condensate return line of the No.11 i Emergency Condenser, had not been tested for closure time. :
- b. From June.1973 until November 1983, a . period of time covering five
. operating cycles over ten years, valve 39-06, a reactor coolant i system isolation valve on the condensate return line of tne No.12 :
Emergency Condenser, had not been tested for closure time. ;
Niagara Mohawk's response to the alleged violation is as follows: !
Niagara Mohawk concurs with the conclusion that a Technical Specification Surveillance Requirement was violated by failing to document that closure time j is within 60 seconds for valves 39-05 and 39-06. This violation is a result !
t of misinterpretation of Technical Specifications for automatic initiation of these particular normally closed isolation valves witn automatic isolation.
Normally open power operated isolation valves have been tested in the closed i direction and, therefore, the emergency condenser return valves whicn are '
normally closed have been tested in the open direction wnich is one of their automatic functions. In otner words, the primary function of this valve is to }
open during an emergency, not to serve as an isolation valve. Initial i procedures written by the plant staff emphasized the importance of opening ;
times for the following reasons: !
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- 1. During -100% power operation, the Emergency Condenser condensate return
- valve [39-05 (06)] and associated redundant isolation check valves are in s the closed position, which meets Technical Specification 3.2.7.b for j isolation valves. If any Emergency Condenser line break were to occur during normal operations, the valves are already in tneir isolation !
position. ,
- 2. Loss of control or motive power . will cause tne Emergency Condenser condensate return valves [39-05 (06)] to open, regardless of any Emergency j Condenser isolation signal providing a fail safe condition for initiation. The redundant isolation check valves provide a fail safe {
, condition for isolation. ,
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. Corrective and preventive actions being taken are as follows:
i i The surveillance procedure has been revised to require testing of the valve i stroke time in botn the open and closed directions. This revision encompasses !
the existing Technical Specifications Surveillance Test requirements. I i
In order to prevent recurrence of this or a similar violation, Niagara Monawk
- has initiated the action identified in Items 3 and 4 for Response A above. In !
addition, Administrative - Procedure APN-3, " Site Operations Review Committee :
t Procedures," was revised on December 7, 1983 to include an additional l
- requirement ' that procedure revisions are reviewed to ensure compliance with f Technical Specifications. The requirement - of ' the reviewers initials and the i review date on the document review form assures this requirement is met. The .
f Pickard, Lowe and Ga'rrick review will produce a cross referenced list of l
Technical Specification surveillance requirements and surveillance procedures !
to aid the Site Operations Review Committee in this review. ~
_ SCHEDULE FOR ACHIEVING FULL COMPLIANCE Pickard, Lowe and Garrick estimates that tne review is apprcximately 90%
complete and is expected to be completed by-the end of May 1984. Should any ,
further procedural inconsistencies be discovered, tne NRC will be notified via
, the requirements of 10CFR50.73. Recommended procedure revisions identified by i !
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a.. 'J Pickard, Lowe and Garrick to imtrove clarity and to specify instructions for precise ~ return to " normal" conditions where required, will be completed by November 30, 1984. This date is considered reasonable because of the need for thorough. review by the Tecnnical staff and the Site Operations Review Committee.
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ATTACFf4ENT 2
- This' attachment provides responses to the alleged violations identified in the Notice of Violation for Unit 2. ,
i The - following' in. formation responds to the specific allegations of violations
' of 'e'ight criter ia i of 10CFR50, Appendix B.
In order to better understand the f responses, the actions taken immediately after the CAT Inspections, and the !
f process presently ~ underway, the following background is furnished:
il Subsequent to the exit interview held witn the CAT Inspection Team on f December 9,1983, Niagara Mohawk established - several task groups composed !
- of senior management and supervisory personnel to review the deficiencies ,
{ and concerns identified during tne course of the CAT Inspection. Tnese !
ll teams evaluated tnese deficiencies and concerns to- identify causes and [
es tabli sh action plans for corrective and preventive actions. In [
[ addition, . these teams evaluated tne indicated deficiencies for generic 4
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[ implications and, wnere appropriate, established action plans to prevent l
[ reoccurrence. Immediate corrective actions wera instituted where f appropriate. When the CAT Inspection Report was received on February 2, !
1984, the findings cited tnerein were compared to tne actions already }
initiated subsequent to the exit interview. This review resulted in the i establishment of additional action plans. Tnese action plans are being .l updated to reflect planned activities.
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t For clarification, the format used in responding to each alleged violation ;
is as follows- I
- 1. The wording of the all'egation of violation, including examples,- has been repeated.
- 2. Niagara Mohawk's position regarding tne alleged violation nas been summarized following the statement " Niagara Mohawk's response to the alleged violation is as follows:"
-3. The. reasons for Niagara Monawk's position on the alleged violation is sununarized under the heading "The reasons for tne alleged violation were determined to be:"
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- 4. The corrective and preventive action related to each example including current status and results to date is provided.
- 5. Following the corrective and preventive actions for the last example, generic corrective and/or preventive actions are provided at the alleged violation level above and beyond tne specific examples, when required.
- 6. The date wnen full compliance will be achieved is given at the end of each section. The date(s) indicated relate to tne specific commitments indicated in tne responses. Wnen the response states direction will be provided Dy Niagara Monawk, this will occur prior I to the date indicated and tne resulting implementation of the direction will be ongoing.
Niagara Mohawk believes tnat these actions, along with tne successful l conclusion of the action plans, will provide effective corrective and preventive actions for the deficiencies identified in tne CAT Report and I the Notice of Violation.
The following sections address each alleged violation. I t
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A. The alleged violation was stated as follows:
10CFR Part 50, Appendix B, Criterion III requires, in part, "The design control measures shall provide for verifying or cnecking tne adequacy of i design...by the performance of a suitable testing program... Design ,
changes, including field changes, shall be subject to design control :
measures commensurate with those applied to the original design..."
Niagara Mohawk Power Corp.'s Quality Assurance Manual, Section 3 implements 10CFR Part 50, Appendix B, Criterion III.
Contrary to the above, tne licensee has failed to meet the requirements of Criterion III as exemplified by the following examples:
- 1. Failure to review design changes in a manner commensurate with the original design review. This is reflected by the hign percentage ,
(30%-40%) of design change documents issued to correct errors or to provide additional information that should have Deen provided on previously issued design changes.
- 2. Failure to perform prequalification tests for the installation of concrete ancnor bolts under tne most adverse design conditions. Tne concrete anchor bolts were tested in a 1000 psi concrete mix, rather than a minimum 3000 psi concrete mix wnich is the concrete mix most representative of field conditions.
Niagara Mohawk's response to the alleged violation is as follows:
Niagara Mohawk has reviewed the examples identified to determine the reasons and the extent to whicn tnese examples are representative of overall program or implementation weaknesses. Niagara Monawk nad concluded that the Unit 2 design control measures were consistent witn our interpretation of tne requirements of Criterion III. However, since it is clear that Niagara Monawk's interpretation is different from the NRC's as expressed in the CAT Report, and since tne NRC has identified specific concerns regarding design control measures, Niagara Mohawk has taken action to address tnese concerns. The following paragrapns explain our position and describe the actions taken to address the concerns identified in the CAT Report.
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The reasons in support of Niagara Monawk's position are as follows:
Design Changes - Related to Example 1 The Unit 2 Project does have programs in effect that provide for verifying or checking the adequacy of the design. Design changes, including field design changes, are subject to control measures commensurate with those applied to the original design. The changes generally do not involve design errors. Rather, they are issued to provide additional information not availaDie when the change was issued and/or to resolve holds on previously issued design change documents. '
However, past practices and timing of drawing issues did not always result in issuance of design drawings sufficiently in advance of the work commencing to allow time to issue a revised drawing to reflect needed changes.
Prequalification Testing - Related to Example 2 ;
With regard to the pre-qualification tests for the installation of the concrete anchor bolts, - we did not consider tnis to be an inadequate testing program under Criterion III.
i Pre-qualification tests for concrete anchor bolts were performed in a 1,000 psi design mix for installation of bolts in 3,000 psi concrete *. An engineering evaluation by Stone and Webster concluded tnat installation torques developed from testing with the 1,000 psi concrete would ensure that the anchors are properly set and will meet tne intended design function.
t The purpose of the pre-qualification test was to ensure that the installation procedure results in acceptable displacement characteristics and pull-out capacities of the ancnors. These pre-qualification tests were performed in 1,000 psi concrete whicn was determined to be representative of concrete used at Unit 2 for tne factors tnat are significant in determining the ancnor capabilities. The difference between tne two mixes is in the amount of cement and fine aggregate used.
The coarse aggregate content is essentially the same (within 6%).
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NOTE: *The designation 1,000 psi or 3,000 psi design mix denotes the value used by engineering in the design of concrete structures. The actual values of compressive strength tests was an average of 2,800 psi for the 1,000 psi mix and an approximate average of 4,400 psi for the 3,000 psi mix.
Additional tests were performed on 3/4 incn diameter anchors since a number of anchors were turning during installation using the pre-qualification torque value. Six anchors were installed in 3,000 psi concrete using a lower installation torque. Ancnors were tensioned to 150% of the design load and no slippage was observed.
Corrective and preventive actions are as follows:
Example 1: Failure to review design cnanges in a manner commensurate with tne original design review. This is reflected by the high percentage (30%-40%) of design change documents issued to correct errors or to provide additional information that should have been provided on previously issued design changes.
While Niagara Mohawk does not agree that the problem of design errors is extensive, it is important that the number of erroneous changes be kept to a minimum. An evaluation is being performed to determine where actions can be taken to more accurately identify the cause of changes as well as methods which can be -established to assure that actions are taken wnere required.
In the future additional detailed reviews are planned at the construction site sufficiently in advance of work being performed to allow identification of cnanges wnicn were previously identified on ACNs or E&DCRs and incorporate tnese changes into revised drawings before the work starts, where practical. Additionally, studies are currently being conducted regarding the transfer of certain design activities such as small bore piping design and seismic conduit design to the construction site. Transfer of these design activities will allow for even more rapid updating of drawings as well as improved identification of problem areas.
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The Project Engineer has issued a memorandum to appropriate Stone and Webster Engineering personnel to discontinue the practice of issuing E&DCRs that revise only parts of previously issued E&DCR's . Should changes to previous E&DCRs be required, they will be implemented by cancelling or replacing the previous E&DCR in its entirety by another E&DCR. The information in the memorandum will be reflected in a revised Project Procedure.
Example 2: Failure to perform prequalification tests for the installation of concrete ancnor bolts under the most adverse design conditions. The concrete ancnor bolts were tested in a 1000 psi concrete mix, ratner than a minimum 3000 psi concrete mix wW,n is tne concrete mix most representative of field conditions.
Subsequent to the CAT Inspection, verification tests were performed on bolts which had been installed in 3,000 psi concrete using installation torques developed from the pre-qualification tests. Twelve bolts, whicn were randomly selected based on installation dates and contractors, were tension tested to the allowable design load. All tests were witnessed by an NRC Inspector. Under the test load, there were no measurable displacements of the bolts. Therefore, all 12 bolts tested were acceptable.
Based on tests performed for installation of concrete anchor bolts in both 3,000 psi and 1,000 psi concrete, we believe that the bolts are properly set. Loss of preload observed by tne NRC Inspectors is characteristic of expansion type ancnors and is accounted for by design.
Tne date when full compliance will be acnieved:
June 15, 1984 A-4
B. The alleged violation was stated as follows:
10CFR Part 50, Appendix B, Criterion V requires, in part, " Activities affecting quality snall be prescrioed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall De accomplished in accordance witn tnese instructions, procedures, or drawings. Instructions...shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Niagara Mohawk Power Corporation Quality Assurance Manual, Section 5, implements 10 CFR Part 50, Appendix B, Criterion V.
Contrary to tne above, tne licensee has failed to meet the requirements of Criterion V as exemplified by the following examples:
- 1. The review of radiographs indicates tnat ITT Grinnell radiographic interpreters are not adequately evaluating radiographs of piping welds. Twelve piping welds requiring radiograpnic inspection failed to satisfy tne requirements for film and weld quality of the applicable ITT Grinnell procedures and ASME Section III and V.
- 2. Procedures used to accomplisn electrical raceway installations, installations of seismically mounted equipment, and Power Generation and Control Complex (PGCC) installations and modifications, were deficient with respect to quantitative and/or qualitative acceptance criteria.
- 3. Supports and restraints installed by Reactor Controls Incorporated and ITT Grinnell have not been constructed in accordance with design requirements.
- 4. Adequate procedural controls were not establisned to assure that Power Generation Control Complex (PGCC) cable and wiring installations would conform to design requirements.
- 5. ITT Grinnell piping weld liquid penetrant inspections for the. Reactor Venting System were not being performed in accordance with the requirements of ASME Section V.
Niagara Mohawk's response to the alleged violation is as follows:
Niagara Mohawk has reviewed the examples identified to determine the reasons and the extent to which these examples are representative of overall program or implementation weaknesses. As a result of this review, B-1
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Niagara Mohawk has determined that instructions, procedures, and/or H
' drawings do exist that contain quantitative and/or qualitative acceptance
. criteria. However, Niagara Mohawk concurs that certain instructions,
-procedures and/or drawings - require revision to assure that the above
' identified examples do not reoccur.-
The reasons for the alleged violation were determined to be:
Certain instructions, procedures, and/or drawings lacked accept / reject criteria for some attributes. Specific attributes to be verified were not identified on some documents (e.g. checklists, inspection plans, and planner packages) . Certain training programs did not adequately address all elements (e.g. accept / reject . criteria, procedures, instructions and drawings) necessary to perform and accept the work. Instances have been identified where personnel failed to implement approved instructions / procedures.
Additional information on the reasons for the examples cited (where they amplify the reasons for the violation stated above) is provided in the paragraphs below, which address corrective and preventive actions for each example.
Corrective and preventive actions taken are as follows:
Example 1: The review of radiograpns indicates that ITT Grinnell radiographic interpreters are not adequately evaluating radiographs of piping welds. Twelve piping welds requiring radiographic inspection failed to satisfy the requirements for film and weld quality of the applicable ITT Grinnell procedures and ASME Section III and V.
The corractive actions taken on the 12 welds identified on Pages IV-5 and IV-6 in the CAT Report are as follows:
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Shop Weld 01-21-MSS-150-1-129 SWB The ~ radiographic data on the reader sheet was correct in that the wall. thickness was listed as nominal wall tnickness, plus
' reinforcement of 1/16". However, wh'en using the actual thickness of the weld, the previously accepted porosity was rejected. ITT Grinnell issued N&D IG 1140 to correct the deficiency. N&D IG 1140 was subsequently canceled due to rework required on N&D IG 1627. The results are that the section of pipe that contained the deficient wcld will be cut out and replaced.
I Shop Weld 57-1-1C5-142-2-2 SWA R/l A suspected minimum wall deficiency was verified by ultrasonic
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examination and the density deficiency verified by film review during the CAT Inspection. ITT Grinnell issued N&D IG 1137 to correct these ;
deficiencies. The results are that the weld will De repaired to an acceptable condition and re-radiographed.
Field Weld CSH-25-21-006 R/l This weld was identified by the CAT Inspector as rejectable for a -
linear indication associated witn a single pore. On review of the )
film by Niagara Mohawk, it was determined that a linear indication !
vas present. Niagara Mohawk directed that the weld be repaired and
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re-examined. ITT Grinnell issued OR 5588 to correct this [
deficiency. The results are that this weld will be repaired to an !
- . acceptable condition and re-radiographed. !
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Field Weld CHS-25-21-007 R/l This weld was identified by the CAT Inspector as rejectable for an unconsumed insert. ASME Section III, Division I requirements contain no specific accept / reject criteria relating to unconsumed inserts.
Due to the lack of specific criteria for this condition, Niagara Mohawk developed criteria based on ASME Section III, Division I, para. NX-4424(e) which deals with abrupt changes in density that produce linear indications. This weld #as reviewed by Niagara Mohawk in accordance with this criteria .ad rejected. Niagara Mohawk directed that the weld be repaired and reexamined. ITT Grinnell 4 issued DR 5587 to correct this deficiency. The results are that the weld will be repaired to an acceptable condition and re-radiographed.
Field Weld RHS-66-38-006 R/l The same condition (unconsumed insert) existed for this weld as for Field Weld CHS-25-21-007R/1. Niagara Mohawk directed that this weld be repaired and re-examined. ITT Grinnell issued DR 5586 to correct this deficiency. The results are that this weld will be repaired to an acceptable condition and re-radiographed. Subsequently, N&D IG 2130 was issued due to an interference with a duct support which prevents the repair. As documented on N&D IG 2130, the section of pipe which contains the weld will be cut out and replaced.
Field Weld RHS-66-38-004 R/l Due to missing film in the documentation package, the weld was re-radiographed to complete the package. Review of this film revealed that, because of a foreign substance in the pipe, the acceptability of the weld could not be confirmed. ITT Grinnell issued N&D IG 1336 to correct this deficiency. The results are that the section of pipe containing the weld will be cut out and scrapped. The foreign material will be removed from the pipe. The cut out section of the pipe will be replaced and the welds radiographed.
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Field Weld CHS-25-6-009 R/l Due to missing film, this weld was re-radiographed to complete the documentation package during the CAT Inspection. ITT Grinnell issued DR 5409 to enter this film into the documentation system. The final radiograph indicated the weld was acceptable.
Field Weld RHS-66-39-012 R/l Due to missing film, this weld was re-radiographed to complete the documentation package. ITT Grinnell issued DR 5408 to enter this film into the documentation system. The final radiograph indicate $
the weld was acceptable.
Field Weld RHS-66-38-003 R/2 The radiograph for this weld was reviewed by the CAT Inspector and was found acceptable. The CAT Inspector requested the complete documentation package for his review. During this review, it was noted that weld rod requisitions were missing from the package. ITT Grinnell issued DR 5081 to correct this deficiency. The results are that this weld has been removed, replaced, and radiographed. The replacement weld was acceptable.
Field Weld RHS-66-38-005 R/l The CAT Inspector addressed two areas of concern for this weld. They were incorrect acceptance disposition on one film view, and an incorrect number of radiographic films in the package. The radiographic report was corrected to indicate correct disposition of
" accept" on the report, and the weld was completely re-radiographed.
ITT Grinnell issued DR 5411 to enter film into the documentation system. The final radiograph indicated the weld was acceptable.
B-5
Field Weld CHS-25-13-006 The CAT Inspector requested a thickness measurement be taken to verify a. suspected minimum wall violation. The UT Examiner incorrectly recorded the pipe thickness as a 12" Sch. 100 (.844 wall), instead of 10" Sch.100 (.719" wall) and rejected the weld for a minimum wall violation. ITT Grinnell issued DR 5005 to correct this deficiency before the UT Examiner's error was discovered. The weld was re-examined, and the report was corrected indicating no minimum wall violation. DR 5005 was voided. When the correct minimum wall thickness of .630" was used the condition was acceptable, with the lowest reading being .655".
Shop Weld 47-10-2-FWS-117-4-7S SWE Attempts to re-radiograph the subject weld during the CAT Inspection resulted in radiographs of different welds due to a miscomunication while trying to expedite resolution of the CAT Inspector's concern.
The correct weld was subsequently re-radiographed and determined to be acceptable. This weld was also examined by ultrasonic testing and found acceptable.
Additional corrective actions taken are as follows:
ITT Grinnell performed a review of 1025 field weld radiographs in the vault as of January 19, 1984, utilizing a 14 point checklist. ITT Grinnell issued a report of this review on February 7, 1984, which indicated that 14 radiographic reports were corrected to list code acceptable discontinuities, and that an additional eight welds require re-radiography due to film quality problems. ITT Grinnell issued DRs 5621 through 5628 to correct these eight deficiencies.
B-6
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In addition to the review performed by ITT Grinnell, Niagara Mohawk performed a review of previously accepted ITT Grinnell field and shop weld radiographs in the vault as of January 19, 1984. The specific radiographs reviewed are identified in Niagara Mohawk's Surveillance Reports. This review identified two additional welds that require repair and twelve (12) additional welds that require re-radiography due to film quality and weld coverage. This review identified additional documentation deficiencies associated with the radiographs.
These reviews and the correction of the deficiencies identified will assure that past welds radiographed by ITT Grinnell are of an acceptable quality.
The problems associated with ITT Grinnell's management of radiographic activities were recognized by Niagara Mohawk prior to the CAT Inspection. In an effort to strengthen the ITT Grinnell QA Procram, ITT Grinnell hired a Site QA/QC Director and a NDE Supervisor.
Preventive actions taken are as follows:
ITT Grinnell revised Radiographic Procedure -RTP-3-1 to include detailed requirements for radiographic technique and docuwtation.
^
Training of ITT Grinnell radiographers was- also conducted covering the revised procedure requirements. ' ..
's -
ITT Grinnell NDE Supervisor or SNT-TC-1A Certified Level III will monitor radiographic personnel to verify thai the radiographer:,"are '
performing in accordance with procedural requirements. ~
In addition to the above, Niagara ibhawk has increased its Quality Assurance surveillance activitiis 'per estab1Nhed surveillance schedules by utilizing checklists tnat include: spec!fic attributes related to the matters discussed above.'- ~~
B-7
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(- i i I fl Example 2: Procedures used. to accomplish electrical raceway
- l. installations, installations of seismically mounted
( equipment, and Power Generation and Control Complex '(PGCC) installations and modifications, were deficient with L rsspect ,to quantitative and/or qualitative acceptance
[ criteria. l The corrective action taken on electrical raceway installations identified l l
on Pages 11-2, II-4 and II-5 in the CAT Report are as follows:
I Identification of Raceways - As recognized in the CAT Report, the reason for this condition was that documentation indicated that )
raceway installation was complete when, in fact, permanent identification markers had not been installed. As a result, L Specification E061A was revised to require that permanent identification be applied on raceways prior ti release for inspection by Field Quality Control (FQC). The placement of permanent t
identification on those raceways which have been previously accepted is in progress and the permanent identification will be inspected.
Cable Tray Separation: As recognized in the CAT Report, the reason for this condition was that FQC did not utilize the "L" (Later) attribute, as required by procedure, for documenting that the separation barrier was permitted to be installed at a later date, after cable pulling.
Inspection Plan Number N20E061AFA002 has been revised to add a .
specific attribute for separation barriers and to document an "L" when the separation barriers are not yet installed. Previously I
issued raceway tickets have been corrected to show the "L" status.
Cable Tray Protrusions: Engineering and Design Coordination Reports (E&DCRs) F01,164 as recognized in the CAT Report and F01,238 have been issued to revise the applicable specification to address the acceptance requirements for protrusions into cable trays. Inspection B-8
l
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t l
plans hay 1 been revised to include the requin nts for protrusions g
as inspection attributes. Those HVAC and Fire Protection System 7
l safety related mechanical supports which had been previously final i
( inspected, were re-inspected. The re-inspection identified one l hanger that did not meet the protrusion requirements. This hanger L was reworked to conform to the design requirements.
l i l Preventive actions to be taken are as follows: ;
l For those construction and inspection activities that are allowed to j be delayed from the initial installation, the appropriate inspection 7 plan will be developed to define the inspection attributes prior to [
the start of these activities, and/or the "L" status indicator will be used as required by procedure. l l
Personnel will be retrained to assure procedural requirements are ,
adhered to and that inspections are not signed off as being complete i l
until all requirements have been satisfied or that procedures are in l l
effect to provide for additional inspections. I l
l The corrective actions taken on installation of seismically mounted equipment identified in Pages !!-16 thru II-18 in the CAT Report are as ;
follows:
i i
Switchgear and Motor Control Centers: The shop drawing required SAE !
J429 Grade 2 bolts. This grade of bolt was not utilized on the units furnished to the Unit 2 Project. The reason for this deficiency was i failure of the vendor to supply bolting material meeting his drawing i requirement and failure of Procurement Quality Assurance (PQA) to l identify that the bolts supplied did not meet the requirement of the '
drawing. N&D 7334 was issued to identify this deficiency and is presently being dispositioned by Engineering. l r
t B-9 ;
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s T . s x Stetion Batteries'and Rack: The seismic qualification report identifies .the use of ASTM 307 bolts in the analytical qualification, for thit 2 racks. The vendor did n00 ensure consistency between the assembly - draw;ng J and tne' seismic oualification report in that the assemoly drawfng did not require .tce use of ASTM 307 ~ bolts. Tne review,' in process,.of tne , seismic qualification report indicates that the bolting matbr'lal fs nots critical for tne qualifi' cation of i the battery racks, since c'alculated stresses in' the bolts are low.
Therefore, the specificL.iaantification of the bolts would not have been required on thnssemoly drawing. However, the vendor will be rey'Jired to revice, the seismic' qualification report to identify the acc$ptabilityoftheusefofst'andardbaitsy 1.
.s Previously approvpd sei'smically mounted equipment qualification ,
I
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repofts 'will be
- reviewed for ' specific field assemoly bolting .
requirements. Ai1 ' such. ' drawings ~ wi11 be reviewed to ensure consis'tency with tne identified requirements 1 of the qualification report. FQC hill sample the field assembly bolting to verify that drawing requirNientd- havE Deen met; sere discrepancies to the qualification rooHe, are f dentified ' by Engineering, FQC will '
re-inspectN tNe 'f,lhlld essembly? bolting to the requirements of the qualificatiod repod. Any deficiencier, identified will be corrected. [
Preventive actions taken are as f5110ws-Based on tne deficie1cy- related to seismic qualifications, a new Project Procedure PP94,,." Review of Cnanges and Tneir Effect on Qualification fofstlass' 41E and? Seismic Category I and II Equipment",
has been issued Land' $ being implemented to prevent this type of s
deficiency 'f' rom re-Uccurring.
PQA inspe'cti, plans will be revised to address field assembly bolting maYerial fcr compliance wit'n drawing requirements.
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The corrective / preventive actions taken on the Power Generation and y Control Complex (PGCC) ~ identified on Pages II-9 and II-10 of the CAT I Report are as follows: ,
- A change to Specification E061A was issued to prescribe separation
, criteria including the use of duct covers and floor plates as '
qualified separation barriers in the PGCC, and to establish cable installation and acceptance as a separate and independent program from duct cover installation and acceptance. The applicable inspection requirements of barrier installation will be incorporated into a new inspection plan. Cables in ducts are being inspected in ,
accordance with the GE Wire List, which has been verified as meeting divisional separation.
Inspections of safety related multi-divisional panels and termination cabinets have been performed. Divisional separation nonconformances have been documented and are being evaluated by Engineering. Wiring [
inspections have been performed and divisional separation nonconformances documented and are being evaluated by Engineering. !
Engineering is developing detailed subdivisional separation l instructions for the safety related divisional panels and termination cabinets and is providing these instructions on the C43155 E&DCR series documents. Inspections for subdivisional separation will be performed. Any subdivisional separation nonconformances will be documented in accordance with established procedures, prior to l
releasing those bays having subdivisional separation requirements for F i
further construction activities. !
In addition, Engineering reviewed issued work packages for the panels and termination - cabinets having subdivisional separation requirements, to assure requirements have been adequately defined. j Wiring activities were stopped for work packages requiring additional ;
separation instructions. These packages are being corrected as 3 required and the work allowed to resume as released by Engineering [
with FQC concurrence. ,
i.
B-ll
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Example 3: Supports and restraints installed by Reactor Controls Incorporated and ITT Grinnell have not been constructed in accordance with design requirements.
The corrective actions taken on the support and restraints identified on Pages III-2 through III-.7 and Table III-3 of the CAT Report are as follows:
RCI - Although the CAT Report did not list specific examples for RCI as in the casa of ITT Grinnell, it did refer to Sections III and IV of the Report. The corrective actions taken by RCI concerning conformance with design requirements is represented by the action taken regarding the undersized welds as follows:
Nonconformance report (NQR) NMP-083 was generated to document the undersize shop welds found in the _ Enterprise Control Rod Drive (CRD) structural steel systems fabricated by RCI. The results are that approximately 33% of the welds are undersized.
These welds will be reworked to bring the welds into conformance with design Equirements. In addition, RCI performed a surveillance check of field welds on the Multi-Function supports and-found them to conform with the design requirements.
As a result of CRD support hardware nonconformance reports, one-
, Installation Supervisor has been terminated. Additional training has been provided to supervisory personnel to assure a thorough understanding of responsibilities. Quality Assurance Instructions (QAI) 2, 8-3, and 10-1 have been revised and implemented to. clarify and enhance the detailed instructions for installation activities and inspection requirements. In addition, training was given to seven QC personnel and installation supervisors to help assure work activities are performed consistent with these requirements.
ITT - For the ITT Grinnell supports identified in Table III-3 which had been inspected, the following actions have been taken:
B-12
L b
Support 66G015 - Nonconformance and Disposition Report (N&D)
IG-ll38 was issued to document the deficiency. The N&D has been dispositioned and the pipe to structure gap was determined to be acceptable based on the fact that at the operating temperature of 40 F, a cumulative gap of 0.020 inches will not impact the design function of the item.
Support 71TL - Deviation Report (DR) 5109 was issued to document this deficiency. The DR has been dispositioned to remove the incorrect clamp and install the correct clamp.
l Support 66G043 - E&DCR C02128 has been issued to clarify gap requirements. The existing condition of the dead weight support conforms to the clarified design requirements.
Support 71JG - DR 5007 was issued to document this deficiency.
The DR has been dispositioned to rework the welds to conform with design requirements.
Support 19GK - DR 5003 was issued to document this deficiency.
The DR has been dispositioned to remove the incorrect clevis and pin, and install the correct clevis and pin.
Support 72AV -
N&D IG-1210 was issued to document the deficiency. The N&D has been dispositioned and the support has been determined to be acceptable as is because the welds are proper fillet size and the weld length is longer than required.
The missing strut rod end spacers have been installed and inspected. It should be noted that this is a non-safety related support.
Support 72VL - N&D 5866 documents this deficiency. The N&D has been dispositioned to rework the pipe clamp and strut to conform with the design requirements. It should be noted that this is a non-safety related support.
B-13
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Support '66G032 -
DR- 5000 was issued to document this i deficiency. The DR has been dispositioned to rework the support {
to conform with design requirements. [
Support 72MQ -
N&D -IG-1246 was issued to document this !
deficiency. The 'N&D has been dispositioned and the support has been determined to be acceptable as is because under operating conditions, the total relai.ive movement of the pipe is only 1/8".
- i Supports 19RR, 19RX, 19QX - DR 5829 was issued to correct the ,
. gap deficiency with Support 19RX. This support will be shimmed- i
~ to meet the design requirements. Inspection. Reports FU 271 and 1409 were issued to identify the gap deficiencies on Supports !
t 19QX and 19RR. These supports will be reworked to comply with i
. the design requirements.
t Preventive actions taken are as follows: ,
-Reactor Controls Incorporated Quality Assurance Instructions ;
(QAI) 8-2, 8-3, and 10-1 have been revised .to provide detailed instructions 'for- installation activities and inspection !
r requirements. Seven QC personnel and installation supervisors j f
have been trained to these revised procedures to help assure [
inspections are adequately performed. l 2
I As a result of CRD support hardware nonconformance reports, training has been provided to supervisory personnel to help :
assure a thorough understanding of acceptance requirements. .
i ITT Grinnell issued Corrective Action Request, Numbers 611, 617 ;
and 618 which provide for: Verification by Engineering of l,
{ previously installed items not released for QC inspection; ;
additional training of craft personnel on construction and l quality requirements; supplying appropriate measuring !
l l
B-14 l
- i
- - - , . - . _ , . . . _ , ~ _ _ . _ , - , , , . ._ ..-,. - ._ _._,_ ........ _ .,.- , ....,- - .. - .,,...-.-._,..,.._.
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equipment for craft use, evaluation of welders who exhibit above 10% weld reject rate; hiring of additional welding engineers; '
providing a mock-up depicting various types of welds related to !
supports.
ITT Grinnell will monitor the reject rates tnrough the quality l accountability program (trend) to determine tne ongoing I effectiveness of corrective actions. :
Example 4: Adequate procedural controls were not establishd to assure that Power Generation Control Compex (PGCC) cable and ,
wiring installations would, conform to design requirements. :
The corrective and preventive action for this example are as follows:
See' Example 2 of this alleged violation for Niagara Mohawk's ,
response for corrective and preventive action. !
Example 5: ITT Grinnell piping weld liquid penetrant inspections . for !
the Reactor Venting System were not being performed in i accordance with the requirements of ASME Section V.
The corrective actions taken on liquid penetrant examination deficiencies g identified on Page IV-4 in the CAT Report are as follows: ;
The certifications of the liquid penetrant examiners that performed these past examinations were revoked. These individuals will not ;
perform any future liquid penetrant examinations for acceptance of welds at the Unit 2 Site.
Accessible safety related welds previously examined are being re-examined by individuals trained and certified in accordance with training sessions tnat empnasize tnat surface preparation is to be in an ' acceptable condition prior to performing a liquid penetrant I examination. As of the ITT Grinnell Report dated April 20, 1984, a l total of 1636 welds were re-inspected and 86 of these welds had ;
rejectable indications. The majority of tnese rejectable indications !
i t
8-15
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r-were surface imperfections which will not require any repair. It should be noted that magnetic particle examinations may be substituted for the previously performed liquid penetrant examination when allowed by ASME Section III, Division I.
Safety related welds tnat are not accessible will De identified and
, receive an engineering evaluation. The engineering evaluation will include consideration of the design function of tne welds.
Preventive actions taken are as follows:
ITT Grinnell's liquid penetrant training and certification program will be revised to empnasize that surface preparation is to be in an acceptable condition prior to performing a liquid penetrant examination.
ITT Grinnell's training and certification procedures will oe revised to require the NDE Supervisor or designee to perform a surveillance over the initial liquid penetrant examination for each new employee.
This surveillance will be sufficient t'o establish confidence in the employee's ability to perform a proper liquid penetrant examination.
The results of this surveillance will be documented in a memo and included as part of the employee's qualification record.
ITT Grinnell procedures will be revised to require the NDE supervisors or a SNT-TC-1 A Certified Level III Examiner to perform an ongoing monitoring program that includes re-examination of previously accepted work.
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l B-16
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ITT Grinnell Field QA has a certified Liquid Penetrant Level II Examiner who will perform QA surveillance of the liquid penetrant examinatien activities.
GENERIC . CORRECTIVE ACTIONS TAKEN FOR THE ALLEGED VIOLATION B ARE AS FOLLOWS:
' Niagara Mohawk is performing surveillances . of site contractors' Non Destructive Examination activities for compliance to ASME Section III and V requirements including the deficiencies identified in the CAT Report. Corrective ac.tions are being taken as appropriate. Niagara Mohawk has streamlined procedures for stop work activities and has exercised these procedures on two occasions recently.
GENERIC PREVENTIVE ACTIONS TAKEN FOR ALLEGED VIOLATION B ARE AS FOLLOWS:
Niagara ' Mohawk is reviewing new and/or revised quality assurance procedures developed for use on Unit 2 to assure that they contain adequate quantitative and qualitative acceptance criteria, prior to these procedure's being i
'ssued for implementation by all site organizations. This was outlined in a letter issued by Niagara Mohawk, dated February 29, 1984.
Niagara Mohawk has i.ssued a directive requiring organizations performing radiography at Unit 2 to revise their procedures to incorporate the Niagara Mohawk criteria developed based on ASME Section III, Division I, paragraph NX-4424(e) pertaining to abrupt changes in film density which produce linear indications.
Niagara Mohawk will. provide direction to site personnel responsible for safety related work. The directive will re-emphasize the requirement that no work is to be performed that does~not comply with appropriate procedures, instructions, and drawings and that if adequate procedures, instructions and/or drawings are not available the work will not proceed until they are available.
B-17
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Niagara Mohawk has evaluated and re-oriented its approach to site surveillance programs to place additional emphasis on checking that the work is being performed in accordance with approved instructions, procedures, and drawings.
Niagara Mohawk will review Stone and Webster's site surveillance
~
program to determine _if adequate emphasis has been placed on checking that the. work is being performed in accordance with approved instructions, procedures and drawings.
The date when full compliance will be achieved:
June 15, 1984, except for the engineering evaluation of inaccessible welds discussed in Example 5 above.
B-18
C. The alleged violation was stated as follows:
10CFR Part 50, Appendix B, Criterion VI requires, in part, " Measures shall be established to control the issuance of documents... including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes...are distributed to and used at a location where the prescribed activity is performed."
Niagara Monawk Power Corp. Quality Assurance Manual Section 6 implements 10CFR Part 50, Appendix B, Critericn VI.
Contrary to tne above, the licensee has failed to meet the requirements of Criterion VI as exemplified by the following examples:
- 1. Raceway tickets used to perform inspection of Class IE cable tray and conduit installations, and ITT Grinnell and Reactor Controls Incorporated Hanger Inspection Checklists did not indicate the latest revision or design change document that was used to accomplisn construction and inspection activities. "
- 2. Design cnanges were not being incorporated into the construction drawings. It was found that a large number of design changes were posted against the BE-series drawings without revisions to the drawing being performed.
- 3. Design changes on construction drawings were not being identified at the location of the work activity. It was found that Engineering and Design Coordination Reports (E&DCRs) and Advance Change Notices (ACNs) were not being posted on drawings being used by the subcontractors and inspectors as required by site procedures.
Niagara Mohawk's response to the alleged violation is as follows:
Niagara Mohawk has reviewed the examples identified to determine the reasons and the extent to which tnese examples are representative of overall program or implementation weaknesses. As a result of this review, Niagara Mohawk has determined that implementation of tne methods used for controlling the distribution of changes to design documents to locations where prescribed activities are performed is deficient.
C-1 L
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The' reasons for the alleged violation were determined to be:
The Project Procedures did not require the recording of the latest revision or design change document that were used to accomplish construction and inspection activities on inspection records.
The system of posting design changes used at the time of the CAT Inspection was not timely considering the number of controlled document stations, as well as the volume of design documents and associated changes which needed to be processed.
Proce' dural requirements for E&DCR incorporation were not fully implemented. At the time of the CAT Inspection, an intensive effort was underway to increase the rate of incorporation of ACN's into drawings. Consequently incorporation of other documents such as E&DCRs lagged. Given the fact that there is more initial reviews on E&DCRs versus ACNs, it is believed that the proper priorities were applied.
Additional information on the reasons for the examples cited (where they amplify the reasons for the violation stated above) is provided in the paragraphs below, which address corrective and preventive action for each example.
Corrective and preventive action taken are as follows:
Example 1: Raceway tickets used to perform inspection of Class lE cable tray and conduit installations, and ITT Grinnell and Reactor Controls Incorporated Hanger Inspection Checklists did not indicate the latest revision or design change document that was used to accomplish construction and inspection activities.
The corrective actions taken on the above example are as follows:
Niagara Mohawk will direct contractors to develop and implement sampling plans for the inspection of previously accepted items where C-2
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' l
. -t. i i
' inspection records do not reflect the latest revision or design ,
change document, to verify that the installed work is in compliance with the latest revision of.the design document and/or design change documents.- These plans will be approved by Niagara Mohawk prior to implementation. Niagara Mohawk will also perform surveillance of the implementation of these sampling plans. -
Preventive actions taken are as follows:
Niagara Mohawk will direct site contractors to review the appropriate quality assurance procedures to verify that they contain requirements ,
that the latest revision of the design documents and change thereto are used to accomplish construction and inspection activities are documented on appropriate records. Procedures that currently do not state these requirements will be revised.
Examples 2 and 3: Design changes were not being incorporated into the construction drawings. It ' was found that a large ,
number of design changes were posted against the !
BE-series drawings without revision to the drawing being performed, and '
Design changes on construction drawings were not being l identified at the location of the work activity. It ,
was found that Engineering and Design Coordination Reports (E&DCRs) and Advance Change Notices (ACNs) were not being posted on drawings being used by the subcontractors and inspectors as required by site procedures.
The corrective actions taken based on concerns identified on Pages VIII-9 thru VIII-12 and Table VIII-1 in the CAT Report are as follows:
During the CAT Inspection, a computer search of drawings was performed. The final results identified 145 drawings that had 5 or more change documents posted against them. All 145 drawings have been revised to incorporate the posted changes.
C-3
The sample inspection to be performed as part of the corrective action stated under Example 1 above, will confirm that construction activities performed on Unit 2 were performed to the applicable design change documents. Niagara Mohawk will direct site organiza-tions to review drawings used at the work locations for compliance to posting requirements for any design changes. Any drawings found to be deficient will be corrected.
Preventive actions taken are as follows:
A computerized document control status information system will be implemented to assure that design changes are incorporated in a timely manner and that personnel are informed of changes to design documents.
The practice of posting changes on the cover of multi-sheet drawings has been discontinued. Each sheet of a multi-sheet drawing will be posted with the change document that affects it. When a sheet has five changes (E&DCR's and/or closed N&D's) posted against it, that sheet will be revised to incorporate the changes.
Project schedules called for completion of most Stone and Webster drawings by approximately the end of March 1984. Niagara Mohawk will assure that sufficient design personnel remain to maintain the updating of drawings at the required rate. Niagara Mohawk's assessment of the amount of manpower required to maintain this effort is complete.
The problem of the large backlog of ACNs was recognized and acted on prior to the CAT Inspection. On October 6, 1983, a decision was made to accelerate the rate of incorporation of ACNs into affected documents to approximately 1500 a month, 500 greater than the average C-4
number of ACNs generated. Since then tne targets have been set at either 500 more thm written the previous month or 1500. At this rate, it is expected that the backlog of QA Category I ACNs will be eli1tinated by May 15, 1984. Also, the 60 day requirement has been reinstated for ACNs initiated af ter March 31, 1984.
The data when full compliance will be achieved:
- June 15, 1984 W
es C-5
- D. The alleged violation was stated as follows:
10CFR Part ' 50, Appendix B, Criterion VII requires, in part, " Measures shall be established to. assure that purchased material, equipment and services... conform to the procurement documents... Documentary evidence that material and equipment conform to the procurement documents shall be available..."
Niagara Mohawk Power Corp. Quality Assurance Manual Section 7 implements 10 CFR Part 50, Appendix B, Criterion VII.
Contrary to the above, the licensee has failed to meet the requirements of Criterion VII as exemplified by the following examples:
- 1. General Electric Product Quality Control released a pump and motor
~
i from Union Pump Company (PQC No. AQ586), incorrectly verifying that
- the equipment conformed to the purchase specification when in fact the motor was the wrong size.
- 2. Stone and Web' ster Engineering Corporation PQA released material from Cives Steel Corporation, Power Conversion Products, and ITE Gould Corporation that did not meet specification requirements as follows:
- a. Stone and Webster Shop Inspection Report 0056 stated that Beams B-3203-2 and B-3203-4 were satisfactory based on a random inspection of. the shipment. 15% of the welds' on the beams inspected, supplied by Cives Steel, were undersized.
- b. Stone and Webster Shop Inspection Report N25204A057 of Cives Steel concerned steel beams for the Diesel Generator Building and stated that' " welding inspection performed and found to be satisf actory in accordance with inspection plan and AWS D.1.1."
The inspection plan instructions required "100 percent visual inspection in accordance with AWS D.1.1." However, beam i' E 4236-1 and others were found to have insufficient weld material.
- c. Stone and Webster Shop Inspection Report of the Static Battery a' Chargers supplied by Power Conversion Products stated that routine tests including- dielectric, regulation, ripple, and surge tests were performed. However, when tests were performed on-site, it was found that the battery chargers would not generate a DC output voltage when energized and internal circuit boards and breakers were found to be defective . These problems resulted in the identification of these problems as a potential 10CFR Part 50.55(e) item to NRC Region I; however, no actions were taken regarding ineffective source inspection.
f
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D-1
- d. Stone and Webster PQA released equipment and material for battery racks from ITE Gould Corporation that included bolting material that was commercial grade instead of the SAE J429 grade 2 bolting material required by the equipment drawings.
Niagara Mohawk's response to the alleged violation is as follows:
Niagara Mohawk has reviewed the examples identified to determine reasons and the extent to which these examples are representative of overall program or implementation weaknesses. As a result of this review, Niagara e
Mohawk concurs that Procurement Quality Assurance (PQA) inspection of certain components was deficient.
The reasons for the alleged violation were determined to be:
Failure of the vendor to comply with procurement requirements; and failure of Stone and Webster and General Electric Procurement QA Programs to identify these discrepancies prior to release of material.
Additional information on the reasons for the examples cited (where they amplify the reasons for the violation stated above) is provided in the paragraphs below, which address corrective and preventive actions for each example.
Corrective and preventive actions taken are as follows:
Example 1: General Electric Company Product Quality Control released a pump and motor from Union Pump Company (PQC No. AQ586),
incorrectly verifying that the equipment conformed to the purchase specification when in fact the motor was the wrong size. '
The corrective action taken on the pump and motor concerns identified on Page VIII-8 in the CAT Report are as follows:
0-2
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.c, -, ,.
In June 1982, the applicant identified that the motors on the Reactor Water Clean-up Pump were 460_ volt in lieu of the required 575 volts.
The- General ' Electric representative at the site was notified, and Field Deviation Disposition Report (FDDR) KGI-092 was initiated on 6/25/82._ Investigation revealed that the correct pumps and motors for Unit 2 with 575 volt ratings were shipped from Union Pump Co. to another nuclear project. The other project motors with 460 volt ratings went to Unit #2. The motors at Unit #2 were disassembled
,. . from the pumps and replaced with the proper motors, as required by the FDDR.
Niagara Mohawk will direct Stone & Webster to sample inspect the GE supplied safety related motors previously received at the Unit 2 site for compliance with specified ratings.
Preventive actions taken are as follows:
Niagara Mohawk will direct Stone and Webster to revise their receiving inspection plans to include inspection attributes to verify that safety related motors comply with the specified ratings.
Example 2: Stone and Webster Engineering Corporation '(SWEC) PQA released material from Cives Steel Corporation, Power Conversion Products, and ITE Gould Corporation that did not meet specification requirements as follows:
a) SWEC Shop Incpection Report 0056 stated that Beams B-3203-2 and B-3203-4 were satisfactory based on a random inspection of the shipment. Fifteen percent of the welds on the beams inspected, supplied by Cives Steel, were undersized.
b) SWEC Shop Inspection Report N25204A057 of Cives Steel concerned steel beams for the Diesel Generator Building and stated that " welding inspection performed and found to be satisfactory in accordance with D-3 s
+
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inspection plan and AWS 0.1.1". The inspection plan
-instructions required "100 percent visual inspection
-in accordance with AWS D.1.1". However, beam E 4236-1 and- others were found to have insufficient weld
,. material.
-The corrective actions taken on the Cives shop / field weld deficiencies identified on Pages IV-13 and IV-14 of the CAT Report are as follows:
The field welds identified by the CAT Inspection indicate 1 of 170 welds to be undersize. N&D 5986 was issued to address this :
deficiency. The results are that the undersized weld on beam !
F4236-2 was determined to be acceptable as is, due to the fact I that the actual weld size is greater than the minimum required as determined by subsequent engineering evaluation of the design ,.
calculations. l The shop welds identified by the CAT Inspector that had the paint [
removed, were reinspected and the following results determined: i i
Beam A-3621 contained undersize welds. (For the record, the f
correct beam number is A6321.) N&D 6040 was issued to address this deficiency. The results are that the undersized weld on j beam A6321 was determined to be acceptable as is, due to the >
fact that the actual weld size is 'reater than the minimum [
required as determined by subsequent e gineering evaluation of {
the design calculations. ,.
l Beam A3203-6 contained unacceptable underrun.- N&D 6040 was j issued to address this deficiency. The results are that the t underrun weld on beam A3203-6 was determined to be acceptable as [
is, due to the fact that the. actual weld size is greater than f the minimum as determined by subsequent engineering evaluation [
of the design calculations. !
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Beam E4236-1 contained undersize welds. N&D 6040 was issued to address this deficiency. The results are that the undersized
-weld on beam E4236-1 was determined to be acceptable as is, due !
to the fact that the actual weld size is greater than the minimum as determined by subsequent engineering evaluation of the design calculation.
Beams 83203-2, 83203-4 and E3213-1 did not contain any deficient ,
welds.-
In addition, a sampling plan was developed in accordance with Military Standard 414 (Inspection Level 4) for Cives Steel structural '
steel welds. Of tne 75 welds selected from tne sampling plan, 12 were found not to be in compliance with MS D.1.1 visual inspection ;
requirements. These deficient welds were documented on !
Nonconformance and Disposition Report Number 6796. These deficient ,
welds were determined to be acceptable since the stress levels in each of the nonconfcrming welds were enecked based on existing [
conditions and all are within the allowable design stresses. '
Preventive actions taken are as follows:
Stone and Webster Procurement QA Inspectors will be retrained with regard to visual inspection requirements of MS D.1.1 and the I inspection plan.
Example 2c: SWEC Shop Inspection Report of the Static Battery Chargers supplied by Power Conversion Products stated tnat routine tests including dielectric, regulation, ripple, and surge l tests were perfomed. However, when tests were performed !
on site, it was found that the battery chargers would not l generate a DC output voltage when energized and internal i circuit boards and breakers were found to be defective. l These problens resulted in the identification of these l I
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problems as a potential 10CFR Part 50.55(e) item to NRC Region I; however no actions were taken regarding ineffective source inspection.
The corrective actions taken on the Static Battery Chargers concerns identified on Page VIII-9 in the CAT Report are as follows:
Ouring testing of the battery chargers on site, it was found that the chargers would not produce a DC output voltage when energized; and internal circuit boards and breakers were found to be defective.
These deficiencies had been identified on Nonconformance and Disposition Reports. The deficient condition of the Battery Chargers was also reported under 10CFR 50.55(e) to the NRC on July 12, 1983.
The Final 50.55(e) Report concerning problems associated with the Battery Chargers was submitted to the NRC on August 15, 1983. The results were that vendor wiring errors were corrected to conform with design requirements, and defective components were replaced with acceptable components.
Preventive actions taken are as foll6ws:
PQA Inspection Plans are being revised for Category I equipment to require PQA to verify that the seller has performed and documented a complete wiring check. In addition, PQA Inspection Plans are also being revised to requirc 4QA to perform a sample physical inspection of wiring to the seller's latest approved wiring diagram.
Example 2d: SWEC PQA released equipment and material for battery racks from ITE Gould Corporation that included bolting material that was commercial grade instead of the SAE J429 grade 2 bolting material required by the equipment drawings.
The corrective and preventive act, ions taken on this example are as follows:
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See alleged violation B, Example 2 for the Station Batteries and Racks, for Niagara Mohawk's response for corrective and preventive action.
GENERIC CORRECTIVE ACTION TAKEN FOR ALLEGED VIOLATION D IS AS FOLLOWS:
Niagara Mohawk will direct that a sampling plan be developed by Stone and Webster for approval by Niagara Mohawk to re-inspect previously accepted vendor equipment. !
GENERIC PREVENTIVE ACTIONS TAKEN FOR ALLEGED VIOLATION D ARE AS FOLLOWS:
Inspection plans will be developed or revised that require Stone and Webster Procurement QA to witness testing of selected mechanical and electrical components not yet shipped to the site.
Inspection plans for receiving inspection of selected mechanical and electrical components will be developed or revised by Stone and Webster to require inspections of components for compliance to specification and drawing requirements (i.e. correct material supplied, correct wiring, correct welds, correct configuration, etc.).
Niagara Mohawk will direct Stone and Webster to notify Niagara Mohawk of PQA source inspections. Niagara Mohawk will then selectively f participate in these source inspections to satisfy itself that SWEC is performing its inspection in accordance with procurement documents.
The date when full compliance will be achieved:
June 15, 1984 L
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E. The alleged violation was stated as follows:
10CFR Part 50, Appendix B, Criterion VIII requires, in part, " Measures shall be estaolished for the identification and control of materials, parts, and components.... Tnese measures shall assure that identification of tne item is maintained by heat number, part number, serial number, or other appropriate means...."
- Niagara Monawk Power Corp. Quality Assurance Manual Section 8 implements 10 CFR Part 50, Appendix B, Criterion VIII.
Contrary to the above, the licensee has failed to meet the requirements of Criterion VIII as exemplified by the following examples:
- 1. Welding lugs and otner parts of ASME III Class 1 Linear NF Hangers for the Reactor Coolant Recirculation System were not marked for specific traceability to applicable specification and grade of material or neat number. This does not satisfy ASME NCA-3866.6 requir enents as pt esented by Code Casa N-255, wnich is referenced in the Final Safety Analysis Report (FSAR) Table 5.2.1.
- 2. The material control, application and installation of fasteners for safety-related mechanical, electrical and structural equipment, and the disposition of unused weld rod in tne plant have not been adequately controlled to prevent the use of incorrect parts or ma terial .
Niagara Mohawk's response to the alleged violation is as follows:
Niagara Monawk has reviewed the examples identified to determine reasons and the extent to which these examples are representative of overall program or implementation weaknesses. As a result of tnis review, Niagara Mohawk has determined that cited Example 1, relative to welding lugs and other parts is not a deficiency. Niagara Monawk has also determined that measures exist in implementing procedures / instructions to assure identification and control of material, parts and components; nowever, Niagara Mohawk does concur that failure to implement the existing programs did result in inadequate controls to prevent the use of incorrect materials.
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c-The reasons for the alleged violation were determined to be:
Failure of personnel to follow existing procedures, inadequate management attention to control of materials, and inadequate coordination of these activities between contractors.
Additional information on the reasons for the examples cited (wnere they amplify the reasons for the violation stated above) is provided in the paragraphs below, which address corrective and preventive action for each example.
Corrective and preventive actions taken are as follows:
Example 1: Welding lugs and other part:: of ASME III Class 1 Linear NF hangers for tne Reactor Coolant Recirculaton System were not marked for specific traceability to applicable specification and grade of material or heat number. This does not satisfy ASME NCA-3866.6 requirements as presented by Code Case N-255, wnich is referenced in tne Final Safety Analysis Report (FSAR) Table 5.2.1.
The corrective action taken on the welding lugs and other parts identified on Pages VI-2 through VI-4 in the CAT Report are as follows:
The vendor component drawing classified the welding lugs as Linear, ,
which is a higher classification than the lugs actually are. The actual classification of the welding lugs is Component Standard Support. General Electic has issued FDDR Number KGI-0191 to show the correct classification of the lugs. Otner parts of the supports are t correctly classified as Component Standard Supports. Under ASME ,
Section III, Division I NCA-3866.6 and Code Case N-255 Component l Standard Supports are not required to be pnysically marked for traceability after fabrication.
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- Preventive actions taken are as follows:
General Electric has- reviewed a representative sample of documentation for component standard supports supplied by Specific Scientific (the only other supplier of NSSS supports) and has not found any conditions that would require a need for a further traceability investigation.
Example 2: The material control, application and installation of fasteners for safety-related mechanical, electrical and structural equipment, and the disposition of unused weld rod in the plant have not been adequately controlled to prevent the use of incorrect parts or material.
The corrective action taken on the installation of fastener concerns identified on Pages VI-2 through VI-4 in the CAT Report are as follows:
Service Water Pump, 2SWP*Plc
- a. Motor mounting bolts were not marked. This deficiency was identified because the connections appeared to be designated as ASME NF, which would require the mounting bolts to be marked. A review 'of the connections had been performed and it was determined that they were not ASME NF, per E&DCR C15655. This E&DCR was issued to clarify that these connections were not designed ASME, which also deleted the requirement for the bolts to be marked. Therefore, these bolts are acceptable,
- b. Lockwashers missing from motor mounting _ bolts. Three lockwashers, which were vendor installed, apparently were removed during installation and not replaced. Since the vendor equipment documentation did not identify the use of lockwashers, E-3
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the vendor was contacted and it was confirmed that the lockwashers were required. Therefore, the vendor equipment documentation will be revised to identify the lockwashers. The final installation of the lockwashers has also been designated as a quality hold point.
- c. Flatwashers missing from beneath nuts for anchor bolts. Although the flatwashers were missing, the installation and inspection of this pump was not complete. Final installation and inspection will assure that the washers are installed.
Service Water Pump, 2SWP* PIA
- a. Motor mounting bolts are not marked. The resolution to this deficiency is the same as for Pump 2SWP*Plc (paragraph a) above.
- b. Flat washers missing from beneath anchor bolt nuts. The resolution to this deficiency is the same as for Pump 2SWP*Plc (paragraph c) above.
Unit Cooler, 2HVR*UC413B
- a. .No marking on 1" anchor bolts. Marking of anchor bolts is verified by Quality Control as part of the preplacement inspection. Marking may or may not be accessible after the concrete placement.
In addition, as per specification, the excessive thread projection had been cut off and had the marking been on the end of the bolt, it would not now be available. The preplacement inspection reports for the placements that involved these anchor bolts were complete and satisfactory for this item,
- b. Washers were missing and nuts were not marked to indicate material as specified by the drawing. At the time of the CAT Inspection, temporary hardware was in place. Bolting installation E-4
had not been signed off as complete by Construction or FQC.
Since then the permanent hardware has been installed and QC accepted.
Residual Heat Removal Pump, 2RHS*PIC - Washers were not installed under nuts attaching pump base to mounting adapter plate. The drawing configuration showed washers under the nuts, but the material list did not include washers. The lack of washers was detected by a Quality Control in-process inspection. The requirement for washers was subsequently deleted by E&DCR F11277 making the existing condition acceptable.
High Pressure Core Spray Pump, 2CSH*PI - Washers were not installed under nuts of main anchor bolts. The lack of washers was detected by a Quality Control in-process inspection. The requirement for washers was subsequently deleted by E&DCR Fil277 making the existing condition acceptable.
High Pressure Core Spray Pump, 2CSH*P2 - Washers were not installed under nuts of main anchor bolts. At the time of the CAT Inspection, temporary hardware was in place. Bolting installation had not been signed off by Construction or Quality Control. These washers will be installed during the installation process and inspected.
Low Pressure Core Spray Pump, 2CSL*P1 - Washers were not installed under nuts of the main anchor bolts. The conditions and corrective action on this pump are exactly the same as 2CSH*PI above.
Low Pressure Core Spray Pump, 2CSL*P2 - Washers were not installed under nuts of main anchor bolts. The condition and corrective action on this pump are exactly the same as pump 2CSH*P2.
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Reactor Water Chan Up Pump 2WCS*PI A/PIB - Washers were not installed
.under nuts of main anchor bolts. Washers have been installed and the bolts retorqued. Tne connactions have been re-inspected and found
. occeptabit. (For the record, CAT Report indicated that two pumps were in.olved, but only one pump (PI A) had been installed to the point where this observation could be made. The other pump (P18) had nat been bolted or grouted.)
Hydrogen Recombiners, 2 HTS *RBNRI A/D - a recognized in the CAT Report, tnis installatten was temporary. Inir coarect hardware will be installed at a later date, Niagara Moh44k wlil 'Jlract Stone and Vebster to develop a sampling plan ter inspectlon of safety related installed equipment to verify that fastener.s as inculled ara in confonnance with design requirenents.
. Corrective action taker, on unustt;/;&rtially used weld rod identified on Page IV-3 in the CAT Report is as follows:
An indepth plant surveillance was perfonned by ITT Grinnell to id40tify unuseJ/wrtially used weld rad. Tne deficiencies were corrected.
/
Proventide e.ctions taken are as follows:
Material Control, applica'. ton, and installation for Fasteners - To minimi2c re-occurence of toene types of conditions, retraining of
( constivction personnel is being nerfonned, witn enphasis to not i proceed with work if conflicting drawing requirements exist until tn/neeringhisprovidedclarification.
Olsposition of unused welo mater tal . Site contractors will oe directed to include tne follawing in their welding material control l program:
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Electrode station attendants shall witness the return of unconsumed / scrapped electrodes in all rod stub cans. Exposed electrodes that were not consumed and were scrapped due to rnoisture are to be returned to the electrode stations, weighed and the amount documented as described on the welder's requisition slip. Welding Supervisors, assigned to each electrode station, are responsible to monitor and control these requirements. Supervisors, General Foremen and Foremen are required to monitor their work areas on a daily basis to assure compliance in the use of rod stub cans and assure their areas are clear of improperly discarded electrode stubs.
In addition, training on weld material control requirements for craft supervision is being conducted.
Niagara Mohawk will perform surveillances of the weld material control program to assure the above preventive actions are effective.
GENERIC PREVENTIVE ACTIONS TAKEN ARE AS FOLLOWS Training of applicable personnel is being performed in the areas of control of materials and the installation process of equipment fasteners.
The date when full compliance will be achieved:
June 15, 1984 E7
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F. .The alleged violation .4as sthted as follows: !
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10CFR- Part 50,'_ Appedix 8, ' Criterion X requires, in part, "A program for '
r inspection of- activities affecting quality shall be established and !
executed...to veri fy'- ; conformance with the documented instructions, I procedures,e and drawings for accomplishing the _ activity... Examinations, '
measurements, or tiests of material s or products processed shall be I performed for each work operation where necessary to assure quality."
.. , t , i Niagara Mohaw:C Power- Corp. Quality Assurance Manual, Section 10, implements 10 CFR Part 50, Appendix is, Criterion X.
Contrary to the abo /e,.the licensee has failed to meet the requirements of :
. Criterion-X as; exemplified by the following examples: L
- 1. Supports and sestraints installed by Reactor Controls Incorporated i and ITT Grinnell have not been inspected in accordance with the design documents. .
I
- 2. ITT Grinnell piping weld liquid penetrant inspections for the Reactor t
' Venting System were not being performed in accordance with the Requirements of ASME Section V. ,
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- 3. Separation requirements relative to some PGCC cable installations had not been properly inspected. In addition, inspection of some raceway [
installations relative to the requirements for physical separation i had not been accomplished in accordance with the criteria established i in the applicable procedures. t I
- 4. .In the civil area, some inspections have been performed without ,
- adequate . acceptance criteria and an inspection failed to identify !
deficient conditions.
Examples are: concrete unit weight tests since 1976 were performed without acceptance / rejection criteria; base plates and equipment mounted on concrete surfaces have been installed i before the conc' rete surface defect inspections were performed; the i inspection plan for concrete surface defect inspections does not .i specifically address structural defects such as voiding, honeycomb, l or exposed reinforcing steel; and QC inspection did not identify !
reinforcing steel spacing. violations. l Niagara Mohawk's response to the alleged violation is as follows: .(
2' y j Niagara Mohawk has reviewed the examples identified to determine reasons l and the extent to which these exaniples are representative of overall l
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program or implementation weaknesses. As a result of this review, Niagara Mohawk has determined that improvements in certain inspection programs are required.
Reasons for the alleged violation were determined to be:
Some inadequate procedures; failure of some personnel to follow existing procedures; inadequate training regarding some procedure requirements such as the correct use of inspection equipment.
Information on the reasons for the examples cited (where they amplify the reasons for the violation stated above) is provided in the paragraphs below, which address corrective and preventive action.
Corrective and preventive actions taken are as follows:
Example 1: Supports and restraints installed by Reactor Controls Incorporated and ITT Grinnell have not been inspected in accordance with the design documents.
The corrective and preventive actions taken on this example are as follows:
See ~ alleged . violation B, Example 3 for supports and restraints, for Niagara Mohawk's response for corrective and preventive action.
Example 2 & 3: ITT Grinnell piping weld liquid penetrant inspections for the Reactor Venting System were not being performed in accordance with the requirements of ASME Section V.
Separation requirements relative to some PGCC cable installations had not been properly inspected. In addition, inspection of some raceway installations relative to the requirements for physical separation had not been accomplished in accordance with the criteria established in the applicable procedures.
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The corrective and preventive actions taken on this example are as follows:
See alleged violation B, Example 5 for liquid penetrant inspection and Example 2 for PGCC, for Niagara Mohawk's response for corrective and preventive action.
Example 4: In the civil area, some inspections have been performed without adequate acceptance criteria and an inspection failed to identify deficient conditions. Examples are:
concrete unit weight tests since 1976 were performed without acceptance / rejection criteria; Dase plates and equipment mounted on concrete surfaces have been installed before the concrete surface defect inspections were performed; the inspection plan for concrete surface defect inspections does not specifically address structural defects sucn as voiding, honeycomb or exposed reinforcing ^
steel; and QC inspection did not identify reinforcing steel spacing violations.
Actions taken on the ' civil area identified deficiencies on Pages V-2
' through V-6 in the CAT Report are as follows:
Niagara Mohawk does not agree tnat a violation of Criterion X existed relative to concrete unit weight tests performed without acceptance /
rejection criteria. Unit weight tests were performed "for information only" and not for concrete acceptance.
Structural concrete mixes in shielding areas have been designed to meet dry unit weight requirements of 135 lo/cu f t., to satisfy radiation shielding requirements. Trial batch testing which included dry unit weight tests, used to select mix design and pre-qualification testing, used to verify mix design, ensure that mix designs specified -
meet engineering requirements. Conformance to mix design is assured through in-process controls during batching and placement. 3 P
The above, along with additional testing and engineering analysis performed subsequent to the CAT Inspection, has led to Niagara Mc, hawk's conclusion that structural concrete shielding requirements have been satisfied.
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The CAT Inspector expressed a concern that surface mounted plates may be installed covering defects prior to surface inspection being performed. Niagara Mohawk does not concur tnat a concern exists, for tne following reasons.
Quality Assurance Inspection Plan N205203CFA004 provides the instructions and inspection criteria for concrete surface defects. Tnese inspections have been performed on concrete surfaces wnicn will be buried underground and are currently done to support the application of protective coatings. In addition, Quality Assurance Inspection Plan N20S203GFA001 requires an inprocess surveill'ance of drilled-in anchors and mounting of surface mounted plates. One attribute of tnis inspection plan is the verification of repair of damaged concrete. As described below, there is evidence that provides reasonaDie assurance that no concrete defects are covered by surface mounted plates.
Evidence tnat surface defects such as voids, exposed reinforcing steel and noneycomo are not being covered by surface mounted plates is documented by the 132 surveillance inspection reports
- performed to Inspection Plan N20S203GFA001. Tnirty-nine of these reports included 66 surface mounted plates. No instances of plate installation over surface defects were found. Tne other 93 surveillance inspections covered approximately 125 supports, junction boxes and other items. No instances of surface mounted equipment covering void,s, exposed reinforcing steel or honeycomb were found.
l Specification S203C allows the civil contractor to correct most defects inprocess, in accordance with tne specification, without
- the generation of nonconformance documentation. However, significant surface defects, i .e., voids wnich expose the back side of the first layer of reinforcing steel, require F-4 i
r repair in accordance with engineering direction provided on an N&D. Up until the time of the CAT Inspection, approximately 60 N&Ds had been generated to cover this type of situation.
Since there is no evidence of extensive defects on the exposed surfaces, it is not reasonable to assume that they exist where surface mounted plates have been installed. In addition, areas most prone to defects during placement, i.e. around doorways and penetrations, areas such as those identified by the NRC Inspector, are rarely locations' chosen for surface mounted plates.
The CAT Inspector expressed a concern that the corrective action taken to assure that an identified isolated reinforcing steel spacing violation in the " Main Stack" concrete placement was not adequate.
The specific concern was that the Stone and Webster inspector that gave a training session to assure the - condition would not re-occur was the same inspector that did not identify the violation. Niagara Mohawk does not concur that a concern exists for the following reasons:
As stated in the CAT Report, the unsatisfactory condition was documented on Inspection Report No. S3033202 and corrected prior to _the concrete placement and training sessions for corrective action were performed.
The training session was conducted using the inspector who was involved with the concern, the reason being that no one was more faimiliar with the concern and resolution of the concern than
-the person who had just been through the process. However, to resolve the CAT Inspectors concern, another training session covering this topic was conducted by the Discipline Inspector Supervisor on 12/6/83.
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Based on the reasons provided and that no deficiencies have been identified, Niagara Mohawk does not concur with the CAT Inspector's concerns; therefore, no corrective or preventive
, action is required.
GENERIC PREVENTIVE ACTION TAKEN ARE AS FOLLOWS:
Stone' and Webster will review all specialty and normal training programs - to , assure that items such as accept / reject criteria tolerances, procedures, instructions, and evaluation of effectiveness are addressed as-necessary.
As a- result of -this review, training programs will ~ be revised where
. applicable. Training will be conducted in the revised programs.
Niagara Mohawk .w ill increase its surveillance and audits . of
- inspection activities to assure that. contractors quality. inspection
-programs are being implemented.
The date'when full compliance will be achieved:
June 15,1984 1 .
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i G. The alleged violation was stated as follows: ;
t
- 10CFR Part .50, Appendix B, Criterion XVI requires, in part, " Measures shall be established ' to assure .that conditions adverse to quality...are l promptly identified and corrected...the cause of the condition, and the l corrective action taken shall be documented and reported to -appropriate :
levels of management." t Niagara Mohawk Power Corporation Quality Assurance Manual, Section 16, I implements 10 CFR Part 50, Criterion XVI. ,
t Contrary to the above, the licensee has failed to meet the requirements of
- Criterion XVI as exemplified by the following examples
- 1. The Stone and Webster Engineering Corporation program for overview of :
the ITT Grinnell radiograpny program did not take adequate corrective t actions or provide effective resolution to problems associated with !
the radiographic inspection of piping welds.
- 2. . Specification PP 77 required Advance Changes Notices ( ACNs) to be ;
incorporated into drawings within 60 days of initiation, but because -
of the large backlog of ACNs, Stone and Webster Engi_neering ,
Corporation simply circumvented the procedure by temporarily revising it rather than finding a solution to the root cause of the high ACN l generation rate. Tnus, measures were not established to assure that conditions adverse to quality were being corrected.
3.- Engineering and Design Coordination Reports (E&DCRs) and " documents" f (surveillance reports,- data ' sheets) other than tne formal !
-nonconformance reporting system have Deen used to identify and ;
! correct problems. In addition, conditions adverse to quality that were identified in the electrical and piping / pipe support areas have j not been properly corrected. As the applicant's program. of quality j control inspections was not conducted as construction progressed, it ;
has also prevented the prompt identification and correction of l 1 deficiencies. '
- 4. The Reactor Controls Incorporated nonconformance and corrective ;
action programs have failed to identify, evaluate, and correct :
recurring deficiencies in support / restraint installations. !
- 5. Control panels in tne Power Generation Control Comolex (PGCC) contain ;
many cable and wiring installations which do not conform to requirements. With regard to these installations, the applicant's !
-program failed to promptly and properly identify and correct ;
deficiencies. '
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- 6. After some deficient conditions were identified in tne civil area, inadequate corrective actions were taken. Two examples are: a QC Inspector retraining session on reinforcing steel placement
-inspection was instructed by 'the QC Inspector who had failed initially to identify the deficient condition; and tnere is no evidence to show that a concrete truck mixer, which had failed mixer uniformity testing, had been repaired and retested for mixer uniformity.
- 7. The applicant's audit programs have not been effective in identifying or resolving major deficiencies in construction as evidenced by the following examples:
- a. There were more than 150 open auditor comments and observations regarding audits performed in areas of Niagara Mohawk Power Corporation acitivities, some dating back to 1979.
- b. Seven audits were performed in 1982 and 1983, of wnich just two involved areas involving hardware. These were field audits 29 and 32.
- c. Although the audit program appeared to concentrate on program and documentation reviews, audits were not performed on inspection procedures and criteria in the electrical, mechanical and civil areas.
Niagara Mohawk's response to the alleged violation is as follows:
Niagara Mohawk has reviewed the examples identified to determine reasons and the extent to which these examples are representative of overall program or implementation weaknesses. As a result of this review, Niagara Mohawk has concluded that there were certain weaknesses in some of the corrective action programs of Niagara Mohawk and site organizations.
l The reasons for the alleged violation were determined to be:
The following were exhibited in varying degrees: lack of program effectiveness in idsntifying, tracking, trending, and timely follow-up and close out of corrective action items in a formalized and systematic manner; misinterpretation of and/or lack of specific procedure direction when deficiency documents snould be used; and lack of management control over the corrective action program.
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- _a e Information on the reasons for the examples cited (where they amplify the reasons from the violation stated abcVe) is provided in the paragraphs below which address corrective and preventive actions for each example.
Corrective and preventive actions taken are as follows:
Example 1: The Stone and Webster Engineerin"g Corporation program for overview of the ITT Grinnell radiography program did not take adequate corrective actions or provide effective resolution to problems associated witn the radiographic inspection of.. piping welds.
The corrective actions taken on the Type "C" Inspection Report concerns identified on Pages IV-7 and VIII-8 in the CAT Report are as follows:
Weaknesses existed in the implementation of the SWEC program for Type C Inspection Reports in that there was- inadequate attention to timely closure and no trending performed.
Stone and Webster's program for identifying deficiencies during overview of contractor's activities was to document the deficiency on a Type C Inspection Report to obtain corrective action. Stone and Webster Type "C" Inspection Reports had been issued, which identified conditions adverse to quality, however, adequate and prompt corrective actions had not been taken.
The status of the Type "C" Inspection Reports identified in the CAT Report are as follows:
- 1. P3G00352: Tne corrective action was taken and tne report was closed by Stone and Webster on February 16, 1984.
- 2. P2G00157: Tne report has not been closed to date. This report will be closed by May 15, 1984.
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- 3. P3G00411: The corrective action was taken and the report was closed by Stone and Webster on February 13, 1984.
- 4. P3G00012: The corrective action was taken and the report was closed by Stone and Webster on March 29, 1984.
- 5. P3G00051: The corrective action was taken and the report was closed by Stone and Webster on May 31, 1983.
- 6. P3G00244: The ' corrective action was taken and tne report was closed by Stone and Webster on February 7,1984.
- 7. P3G00133: For the record, tnis report does not exist and IR X3500133 does not relate to radiography. ,
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- 8. P3G00105: The corrective action was taken and the report was closed by Stone and Webster on OctoDer 4, 1983.
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- 9. P3G00196: The corrective action was taken and the report was closed by. Stone and Webster on March 26, 1984.
- 10. P3G00096: The corrective action was taken and the report was closed by Stone and Webster on August 25, 1983.
- 11. P3G00345: Tne report has not been closed to date. This report will be closed by May 15, 1984.
- 12. P2G00135: The report has not been closed to date. This report will
-be closed by May 15, 1984.
- 13. PlG00045: The corrective action was taken and the report was closed by Stone and Webster on January 19, 1984.
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- 14. M2R00275: Tne corrective action was taken and the report was closed by Stone and Webster on April 10, 1984.
Preventive actions taker are as follows:
Stone and Webster will revise the procedure controlling Type "C" Inspection Reports to provide for greater enforcement of time re.straints for response due from the responsible organization, and for approval and verification of the corrective actions delineated in the response. The procedure will also be revised to require escalation to upper management for resolution when the above actions are not performed within the required time. In addition, procedures are also being developed to involve Stone and Webster Engineering Corporation Management in all phases of the corrective action system.
Example 2: Specification PP 77 required Advance Changes Notices (ACNs) to be incorporated into drawings within . 60 days of initiation, but because of the large backlog of ACNs, Stone and Webster Engineering Corporation (Stone and Webster) simply circumvented the procedure by temporarily revising it rather than finding a solution to the root cause of the high ACN generation rate. Thus, measures were not established to assure that conditions adverse to quality were being corrected. _
The corrective action taken on tne backlog of ACNs identified on Page VIII-ll in the CAT Report are as follows:
Project Procedarr. PP-77 was implemented in May 1982. At that time, the ACN incorporation requirements for ACN's contained in PP-77 were 60 days after site work tracking closure date. These incorporation requirements were based on the assumption that documentation of work completion would occur as soon as the changes authorized on a particular ACN were completed.
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F These incorporation requirements remained in effect until March 1983. At that time, the incorporation requirements were changed to 60 days after ACN. authorization except when "as-built" information was required. This procedural change was made because it was recognized that contractor inspectors were not documenting work completion for an autnorized ACN until inspection of the entire system was scheduled, thereby delaying submission.of the ACN for incorporation.
In July 1983, an assessment was initiated by management to evaluate the ACN system. This assessment found tnat the backlog of unincorporated ACN's was unacceptably high (approximately 3500) and increasing. The cause of this increasing backlog was found not to be due to the rate of ACN initiation, but an extremely low rate of ACN incorporation.
On September 20, 1983, it was determined that immediate and extensive corrective action was necessary to reduce the ACN backlog and correct the conditions that caused it to exist. At this time, it was decided that the incorporation requirements in PP-77 should be modified to require incorporation of the greater of 1500 ACN's per month or 500 more ACN's than initiated eacn month.
On November 11, 1983, supplement NMP2-PPS-PP77-38 to PP-77 was issued in accordance with Project Procedure PP-86 to institute the revised incorporation requirements which represented an essential part of the corrective action for the ACN system.
In view of the large ACN backlog that existed at that time, it was necessary to suspend the previous 60-day incorporation requirement to permit the project to concentrate its incorporation efforts on those ACN's that had already exceeded this limit or otnerwise warranted incorporation on a priority basis. The accelerated incorporation requirements were to remain in effect until the backlog of unincorporated ACN's was effectively reduced, at which time the 60-day incorporation requirement would be re-instituted.
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Action was also being taken at this time to increase the speed of ACN incorporation. On September 27, 1983, the SWEC Senior Construction Site Representative issued a memorandum (NM2M-2116) to SWEC Department Heads and Site Contractors instructing them to submit ACN as-built information as soon as the work is complete.
Niagara Mohawk has concluded that the original project procedure incorporated a faulty assumption, that is, the original program requirements should not have tied ACN closure to work tracking closure.
As previously explained, the procedure change was, in fact, a portion of the corrective action effort resulting from tne condition of excessive ACN backlog previously identified by management, not an attempt to merely circumvent procedures.
Preventive actions taken are as follows:
The requirement for incorporation of ACNs within 60 days after issuance, has been reinstated in Project Procedure PP-77 for ACNs initiated after March 31, 1984.
Example 3: Engineering and Design Coordination Reports and
" documents" (surveillance reports, data sheets)(E&DCRs) other than the formal nonconformance reporting system have been used to identify and correct problems. In addition, conditions adverse to quality that were identified in the electrical and piping / pipe support areas have not been promptly corrected. As the applicant's program of quality control inspections was not conducted as construction progressed, it has also prevented the prompt identification and correction of deficiencies.
The corrective actions taken on the use of E&DCRs and " documents" other than the formal nonconformance reporting systems identified on Pages II-20 in the CAT Report are as follows:
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T Niagara Monawk concurs that there were deficiencies in the implemen-tation of the nonconformance reporting systems. Certain personnel did not fully understand tne system. However, tnere is no need for previously issued E&DCR documents that identified nonconforming l conditions to be reissued as nonconformance documents (i.e., no j backfit required) since tnes'e documents nave been reviewed and [
approved in a manner commensurate with the N&D report. Al so, independent of tne procedural requirements for processing E&DCR's and N&D reports, any employee who has evidence of a potentially i reportaole deficiency is required, by procedure, to notify !
apriropriate supervisory personnel.
Based on our assessment of project status, Niagara Monawk does not agree with tne conclusion that there is a significant backlog of i completed work which nas not been inspected. At tne time of the CAT Inspection, there was a backlog of construction installations whicn were not completed to the stage where they were ready for final inspection.
Preventive actions taken are as follows:
Training will be provided to project personnel by site organizations I to ensure compliance with existing nonconformance procedures and to ,
obtain a uniform interpretation of those procedures regarding the ,
documentation of nonconforming conditions. !
, i Example 4: The Reactor Controls Incorporated nonconformance and '
l corrective action programs nave - failed to identify,
- evaluate and correct recurring deficiencies in support / -
restraint installations.
I The corrective actions taken on the failure to identify, evaluate and l
correct recurring deficiencies in support / restraint installations l l identified on pages III-5 and III-6 of the CAT Report, are as follows: '
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A review of previously issued Reactor Controls Incorporated (RCI) surveillance reports will De performed to verify that potential nonconformances have been correctly' documented. Tnose deficiencies that were not documented will be documented on a nonconformance report. Conditions found to be adverse to quality will be identified and corrective actions taken to preclude their recurrence.
Preventive actions taken are as follows:
RCI Quality Control Inspection Procedures are being revised to include the process in which surveillance inspections are performed, open - items are tracked, and nonconforming items are identified, trended and action taken on to preclude their recurrence.
- RCI QAI-15-1, Nonconformance Report Procedure, was revised to include more detailed instructions on when a Nonconformance Report is required and the action to be taken.
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Appropriate personnel will be provided training covering compliance to the revised procedure requirements.
Example 5: Control panels in the Power Generation Control Complex (PGCC)c ~ ontain many cable and wiring installations which do not conform to requirements. 'With regard to these installations, the applicant's program failed to promptly and properly identify and correct deficiencies.
The corrective / preventive actions taken on the failure to promptly ' and properly identify and correct deficiencies in tne PGCC, identified on pages II-9 thru II-11 of the CAT Report are as follows:
See l alleged violation B, Example 2, for tne Power Generation and Control Complex corrective and preventive actions.
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Example 6: After some deficient conditions were identified in the civil areas, inadequate corrective actions were taken. Two examples -are: a QC inspector retraining session on reinforcing steel placement inspection was instructed by the QC inspector who had failed initially to identify the deficient condition; and there is no evidence to show that a concrete truck mixer, which had failed mixer uniformity testing, had been repaired and retested for mixer uniformity.
The con rective actions taken on the inadequate corrective actions of deficiencies in the civil area identified on pages V-3 and V-5 of the CAT Report, are as follows:
Concrete mixer truck Niagara Mohawk has concluded that the incident involving the concrete truck mixer was an implementation deficiency in that Stone & Webster did not follow through for corrective action or have specif'ic instructions to do so.
A review of. inspection records from 4/9/81 through 5/30/81 indicated that truck no. 25 was used on 5/1/81 and 5/6/81 for a Category I and a Category II placement, respectively. Compressive Strength Tests were performed on concrete placed from truck no. 25 on both days.
Specified strengths of 4000 psi were required at 28 days for the
-concrete delivered by truck no. 25. Actual average strengths of 4980 psi and 5120 psi at 28 days for tnese two placements were acnieved, substantiating the acceptability of the concrete that was used.
QC Inspector retraining See alleged violation F, Example 4, for the corrective and preventive actions.
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Preventive actions taken are as follows:
Inspection Plan No. N20S203AF0001 now requires that a letter will be sent to the vendor, informing him that a suspect truck, which has been rejected for failing mixer uniformity testing, cannot be used at Unit #2 until the unsatisfactory condition is corrected.
Example 7: The applicant's audit programs have not been effective in identifying or resolving major deficiencies in construction as evidenced by the following examples:
There were more than 150 open auditor comments and observations regarding audits performed in areas of Niagara Mohawk Power Corporation activities, some dating back to 1979.
Seven audits were performed in 1982 and 1983, of which just two involved areas involving nardware. These were field audits 29 and 32. .
Although the audit program appeared to concentrate on program and documentation reviews, audits were not performed cn inspection procedures and criter_ia in the electrical, mechanical and civil areas.
The corrective action- taken on the audit program concerns _ identified on page VIII-2 and VIII-3 of the CAT Report is as follows:
Significant progress has been made to close out open audit items identified during the CAT Inspection. The remainder will be closed by June 15, 1984.
The seven quarterly audits performed by Niagara Mohawk have been a combination of. programmatic / documentation reviews and physical inspection of hardware. Since the audits appeared to the NRC Inspector to concentrate on non-hardware concerns, Niagara Mohawk believes there may be an implementation weakness in that a better balance of hardware and paperwork audits was not maintained.
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r Audits, by their very nature, rely on sampling techniques which must !
be somewhat random in order to be effective. The fact that three '
specific areas were not audited within a snort series of audits may ;
be attributed - to the randomness of the audit process. However, l Niagara Mohawk believes that this could be considered an ,
implementation weakness in that a better balance of areas of audit ,
had not been provided. ;
Preventive actions taken are as follows:
i Niagara Mohawk has evaluated, reoriented, and revised its audit programs to emphasize hardware and has modified procedures as !
required. A Niagara Mohawk QA on-site audit group has been organized [
and a new procedure developed for auditing the Unit 2 construction '
activities.
GENERIC PREVENTIVE ACTIONS TAKEN ARE AS -FOLLOWS:
i Niagara Mohawk will direct all site organizations to. review and revise as !
necessary their corrective action systems to assure that conditions >
adverse. to quality are promptly identified and corrected, and that the cause of the condition and the corrective action taken is documented. :
Al so, site organizations will review existing audit procedures for i adequacy for identifying and promptly resolving conditions adverse to [
quality with. emphasis on hardware items. !
Niagara Mohawk has reviewed and revised its corrective action system and l audit ' program for the Unit 2 Project. The revised procedures include provision for timely response and verification of corrective actions.
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The new corrective action system has been implemented since February 17, '
1984. The new audit program has just begun implementation with completion I of the first audit of an on-site contractor, ITT Grinnell, on April 23, !
1984. -
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The date when full compliance will be achieved:
June 15, 1984 G-13 m-
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H. The alleged violation was stated as follows:
10 CFR Part 50, Appendix, B, Criterion XVII requires, in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality... Records shall be identifiable and retrievable...".
Niagara Mohawk Power Corporation Quality Assurance Manual, Section 17, implements 10CFR Part 50, Appendix B, Criterion XVII.
Contrary to the above, the licensee has failed to meet the requirements of
. Criterion XVII as exemplified by the following examples:
- 1. Electrical inspection records indicated separation criteria to be acceptable, when in fact, a number of installations examined did not conform to requirements.
- 2. Documentation deficiencies with regard to five Reactor Controls Incorporated welder qualifications, i.e., coupon thickness and bend test result documentation,'were identifed.
- 3. ITT Grinnell quality control inspection records for radiographs of twelve piping welds did not properly document the radiographic inspection results.
Niagara Mohawk's response to the alleged violation is as follows:
Niagara Mohawk has reviewed the examples identified to determine reasons and the extent to which these examples are representative of overall program or implementation weaknesses. As a result of this review, Niagara Mohawk has concluded that there were deficiencies in certain records related to electrical inspections, welder qualification, and radiographs.
The reasons for the alleged violation were determined to be:
Certain instructions, procedures, and/or drawings lacked accept / reject criteria for some attributes. Some attributes to be verified were not identified on some documents (e.g. checklists, inspection plans, and planner packages). Certain training programs did not adequately address all elements (e.g. accept / reject criteria, procedures, instructions and drawings) necessary to perform and H-1
F accept the work. Personnel failed to implement approved instructions / procedures.
Mditional 'information on the reasons for tne examples cited (wnere they amplify the reasons for the violation stated above) is provided in the paragraphs below, which address corrective and preventive
. actions for each example.
Corrective and preventive action taken are as follows:
Example 1: Electrical inspection records indicated separation criteria to be acceptable, when in fact, a number of installations examined did not conform to requirements.
The corrective and preventive actions taken on inspection records for separation criteria identified on Pages II-9 tnru II-11 in the CAT Report are as follows:
See Example 2 of alleged violation B for Niagara Mohawk's response for corrective and preventive actions.
' Mditionally, the following information is provided for the concern regarding cable pulling inspection records:
Cables 2EHSBYL003 and -2EHSAGL003 were installed in accordance with existing specification and QA Program requirements. During the CAT Inspection, these cables were in a partial pull status. The documentation shows these to be in-process. During the in-process work, the FQC inspector accepted tne cable installation knowing that in order to complete the cable installation, the cable would have to be moved and inspected. Inspection Plan No. N20E061AFA025 now requires the FQC inspector to inspect the caole back through the last raceway section or to the extent necessary to assure that the cable is still in compliance witn the applicable specification require-ments. Inspection Report No. E3007624 was for an in-process inspection which accurately reflected the condition of the cables at the time of the inspection.
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Example 2: Documentation deficiencies with regard for five Reactor Controls Incorporated welder qualifications, i.e., coupon thickness and bend test result documentation, were identified.
The corrective actions taken on documentation deficiencies for welder qualifications identified on pages IV-10 and IV-ll in the CAT Report are as follows:
A review has been performed of active pipefitter and iron worker welder qualification records as of 12/1/83. Where a discrepancy was identified on the welder qualification record, the record was corrected. Corrections of discrepancies on the qualification record were possible since the test parameters and test results were available for re-review. In no case was it found that a welder did not meet the qualification requirements for the welds that he has perfonned.
Preventive actions taken are as follows:
Appropriate personnel will be retrained to assure proper completion of tne welder qualification records.
Example 3: ITT Grinnell quality control inspection records for radiographs of twelve piping welds did not properly document tne radiographic inspection results.
The corrective and preventive actions on documentation of radiographic inspection results identified on pages IV-5 and IV-6 in the CAT Report are as follows:
See Example 1 of alleged violation B for Niagara Mohawk's response for corrective and preventive action.
The date when full compliance will be acnieved:
June 15, 1984 H-3