ML20126C907

SALP Rept 50-412/85-99 for Apr 1984 - Mar 1985

ML20126C907
Person / Time
Site:	Beaver Valley
Issue date:	06/07/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20126C895	List: ML20126C892 ML20126C907
References
50-412-85-99, NUDOCS 8506140565
Download: ML20126C907 (44)

See also: IR 05000412/1985099

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

REPORT 50-412/85-99

DUQUESNE LIGHT COMPANY

BEAVER VALLEY POWER STATION, UNIT 2

(Construction Phase)

ASSESSMENT PERIOD: APRIL 1, 1984 - MARCH 31, 1985

BOARD MEETING DATE: MAY 20, 1985

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TABLE OF CONTENTS

Page

I. INTRODUCTION ....................................................... 1

1. Purpose and Overview .......................................... 1

2. SALP Board and Attendees ...................................... 1

3. Background .................................................... 1

II. CRITERIA ........................................................... 4-

III. SUMMARY OF RESULTS ................................................. 5

1. Overall-Facility Evaluation ................................... 5

2. Facility Performance .......................................... 6

IV. P E R FO RMAN C E ANA LYS I S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

1. Containment and Other Safety Related Structures ............... 7

2. Piping Systems and Supports ................................... 9

3. Safety Related Components ..................................... 13

4. Support Systems ............................................... 15

5. Electrical Power Supply and Distribution ...................... 17

6. Instrumentation and Control Systems ........................... 21

7. Licensing Activities .......................................... 23

8. Storage of Safety Related Components .......................... 25

9. Engineering / Construction Interface . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

10. Preoperational/Startup Testing ................................ 30

11. Quality Assurance and Administrative Controls ................. 32

V. SUPPORTING DATA AND SUMMARIES ...................................... 34

1. Construction Deficiency Reports (CDRs) . . . . . . . . . . . . . . . . . . . . . . . . 34

2. Investigation Activities ...................................... 34

3. Escalated Enforcement Actions ................................. 34

4. Management Conferences ........................................ 34

TABLES

Table 1 - Construction Deficiency Reports ............................... 35

Table 2 - Violations (Summary) .......................................... 36

Table 3 - Inspection Hours Summary ...................................... 37

Table 4 - Inspection Activities ......................................... 38

ATTACHMENT

Attachment 1 - Enforcement Data ......................................... 41

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I. INTRODUCTION

1. Purpose and Overview

The Systematic Assessment of Licensee Performance (SALP) is an integrated '

NRC staff effort to collect the available observations on a periodic

-basis and evaluate licensee performance based on those observations with

the objectives of improving the NRC Regulatory Program and licensee per-

formance.

The assessment period is April 1, 1984 through March 31, 1985. The prior

assessment period was December 1, 1982 through March 31, 1984. Signifi-

cant findings from prior assessments are discussed in the applicable

Performance Analysis (Section IV) functional areas'. Evaluation criteria

used during this assessment are discussed in Section II below. Each

criterion was applied using the " Attributes for Assessment of Licensee

Performance," contained in the NRC Manual Chapter 0516.

2. SALP Board and Attendees

Review Board Members

W. Kane, Deputy Director, Division of Reactor Projects (DRP) and Acting

SALP Board Chairman

S. Ebneter, Director, Division of Reactor Safety (DRS) (Part Time)

E. Wenzinger, Chief, Projects Branch 3, DRP

L. Bettenhausen, Chief, Operations Branch, DRS (Part Time)

L. Tripp, Chief, Projects Section 3A, DRP

G. Walton, Senior Resident Inspector, Be:ver Valley, Unit 2

S. Varga, Chief, Operating Reactors Branch No. 1, DRP

B. Singh, Licensing Project Manager, NRR

Other Attendees

C. Anderson, Chief, Plant Systems Section, DRS (part time)

G. Meyer, Project Engineer, Projects Section 3A, DRP

F. Casella, Reactor Engineer, Projects Section 3A, DRP

H. Gray, Reactor Engineer, Materials and Processes Section DRS (part time)

3. Background

Duquesne Light Company was issued a Construction Permit (CPPR-105) to

build Beaver Valley, Unit 2 (Docket No. 50-412) on May 3, 1974. The

Nuclear Steam Supply System (NSSS) is a 2660 MWt Westinghouse PWR with

three loops; the Architect / Engineer (A/E) is Stone and Webster. At the

end of this assessment period, fuel load is scheduled for April, 1987,

and the planned commercial operation date is December, 1987. Stone and

Webster Engineering estimated the construction at 85.3 percent complete

as of March 31, 1985, as compared to 77.5 percent complete at the end

of the last assessment period (March 31,1984).

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a. Licensee Activities

The numbers of craft workers decreased slightly during the assess-

ment-period. On March 31,.1984, there were 2412 craft workers, ,

compared to 2338 craft workers on March 31, 1985; a decrease of:3

percent. -Second shift activity.was increased from 423 to 570 during

.this period. There is essentially no third shift activity. Weekend

-activity has decreased from an average 1746 manual and nonmanual

personnel to an average.of five manual personnel working on Satur-

days. The licensee's Quality Control Department staffing increased

from 281~to 361, an increase of 28 percent. Stone and Webster En-

gineering supervisory, engineering and administrative personnel on

site have increased 34 percent; from 485 to 650 people. The major-

ity of this increase was in the Engineering Department. Also not-

able was the assignment by Stone and Webster of a full-time Site

Project Manager and a Site Engineering Sponsor. Both of these

senior managers bring many years of nuclear. experience to the pro-

ject in key areas.

Reorganizational changes were made in the Duquesne Light Company .

Startup Group during the assessment period by combining the " Con-

struction Startup Group" (CSUG) and " Operations Startup Group" ,

(OS'JG) under one Startup Manager as the "Startup Group" (SVG). This

will eliminate the need for two independent turnovers as well as

combine all testing activities.

Additional safety-related equipment was completed and turned over

to Duquesne Light Department Startup Group. Thirty-eight (38) sub-

syster release packages that contain safety related items were

turned over. Included in these packages were major items such as

the 4160-volt-emergency buses, the 480-volt emergency buses and

substantial portions of the Service Water and Primary Component

Cooling Water Systems. See Functional Area 10 for additional de-

tails.

-During this assessment period, the major construction activities

included installation, welding,' examinations, hydrostatic testing

and flushing of the main steam, feedwater, large and small bore

piping and associated supports; heating, ventilation, and air con-

ditioning (HVAC) and fire protection systems were partially in-

stalled; pumps, motors, control panels, reactor coolant pumps and

motors, and safety-related storage tanks were installed and con-

nected. Electrical cable trays were installed, cable was pulled

and terminated; instrumentation lines and associated hardware were

partially installed. Painting / coating occurred throughout the site.

Insulation of tanks and pipes commenced during this assessment

period. The major-portion of safety related work on soils and

foundations was completed before this assessment period started.

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To complete the cable pulling, approximately two million additional

feet remain to be pulled of the approximately 5.8 million feet total.

The contractor plans to pull 90 percent of the remaining cable dur-

ing the 1985 calendar year. The reactor coolant system hydrostatic

test is planned for May, 1986. Steam generator hydrostatic test

-of the secondary side is scheduled for January,1986. The initial

startup of the diesel generators is planned during 1985. The tur-

bine was put on turning gear in October, 1984.

b. Inspection Activities

A second resident inspector was assigned onsite effective October

7, 1984. Resident inspector activities involved accomplishment of

assigned inspection requirements including observation of work in

progress, follow-up of licensee events, reactive inspection and

evaluation of licensee responses to NRC identified concerns. In

addition, the resident inspector participated in a Construction Team

Inspection (CTI) conducted by NRC Region I.

Twenty-two inspections were performed during the assessment period;

nine independently by resident inspectors, twelve by region-based

specialist inspectors and one Construction Team Inspection performed

jointly by a resident inspector and region-based specialist inspec-

tors. There were 3917 hours0.0453 days <br />1.088 hours <br />0.00648 weeks <br />0.00149 months <br /> of inspection of which 1593 were by

the resident inspectors, 1207 were by region-based specialists and

the remainder was the CTI plus the inspection hours involved in

examinations of components using the Nondestructive Testing Mobile

Lab. The specialist inspection activities were in the following

areas: instrumentation installation, piping and pipe support in-

sta11ation, electrical cable installation, electrical separation

and termination, welding and welder qualifications, preoperational

L test and operational preparedness, and independent verification of

piping, structural, and support weldments. The CTI included cover-

, age of project management, engineering / construction interface,

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quality assurance / quality control, piping and mechanical components,

and electrical / instrumentation work.

c. Licensing Activities

The Draft Safety Evaluation Report (SER) was issued March 1, 1984.

Final SER issuance is planned for April,1985. NRR and DLC Licens-

ing Division continued correspondence and meetings to resolve NRR

outstanding items. This included site visits made by NRR personnel

to observe the actual installed condition of the hardware. The

ACRS full committee hearing is scheduled for August, 1985.

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Four amendments (Amendment 9) to the FSAR were issued during this

assessment period.

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II. CRITERIA

The following criteria were used as applicable in evaluation of each func-

tional area:

1. Management involvement in assuring quality.

2. Approach to resolution of technical issues from a safety standpoint.

3. Responsiveness to NRC initiatives.

4. Enforcement history.

5. Reporting and analysis of 50.55(e) and Part 21 items.

6. Staffing (including management).

7. Training (effectiveness and qualification).

To provide consistent evaluation of licensee performance, attributes associ-

ated with each criterion and describing the characteristics applicable to

Category 1, 2, and 3 performance were applied as discussed in NRC Manual

Chapter 0516, Part II and Table 1.

Category 1: Reduced NRC attention may be appropriate. Licensee management

attention and involvement are aggressive and oriented toward nuclear safety;

licensee resources are ample and effectively used such that a high level of

performance'with respect to operational safety or construction is being

achieved.

Cateocry 2: NRC attention should be maintained at normal levels. Licensee

management attention and involvement are evident and are concerned with nuc-

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lear safety; licensee resources are adequate and are reasonably effective such

that satisfactory performance with respect to operational safety or construc-

tion is being achieved.

Category 3: Both NRC and licensee attention should be increased. Licensee

management attention or involvement is acceptable and considers nuclear

safety, but weaknesses are evident; licensee resources appeared strained or

not effectively used such that minimally satisfactory performance with respect

to operational safety or construction is being achieved.

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The SALP Board also assessed ea r functional area to compare the licensee's

performance during the last quarter of the assessment period to that during

the entire period in order to determine the recent trend for each functional

area. The trend categories used by the SALP Board are as follows:

Improving: Licensee performance has generally improved over the last quarter

of the current SALP assessment period. .

Consistent: Licensee performance has remained essentially constant over the

last quarter of the current SALP assessment period.

Declining: Licensee performance has generally declined over the last quarter

of the current SALP assessment period.

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III. SUMMARY OF RESULTS

1. Overall Facility Evaluation

it Improvement was shown in all three areas that received low ratings

(Category 3) in the last SALP report; the licensee and their primary

contractor were responsive in addressing the weaknesses noted in that

assessment. Several initiatives implemented ~during this assessment

period were effective in improving performance in those weak areas, how-

ever, some lingering engineering / construction interface problems still

exist in the electrical / instrumentation area. An overall program for

resolution of electrical cable separation. problems now exists; satisfac-

tory progress is now being made in this area. Additional attention to

separation problems involving instrumentation tubing and internal panel

wiring is needed.

Satisfactory performance was achieved in each functional area, but prob-

lems within several areas need further attention if higher performance

levels are to be achieved.- These include better control over items being

reworked, day-to-day attention to in place storage to preclude past cyc-

lic performance in this area, assuring that recent actions to preclude

or provide for prompt: identification of QC inspection errors are effec- i

tive, and tightening the system completion / turnover process to reduce

the high number of open items at turnover. Licenser. project management =

and startup programs are functional, but better defined organizational

responsibilities and control of system completion / turnover are needed.

Quality Assurance and Administrative Controls was evaluated as a separate

functional area in this SALP assessment period due to numerous organiza-

tion and senior management changes that occurred during this period.

Except for isolated cases of inspector error, the Quality Assurance /

Quality Control organization has been effective in assuring quality

through independent audits, daily inspection activities, and reinspec-

tion efforts. Licensee resolution and followup of deficiencies resulting

from inspector errors were thorough and are now complete.

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2. Facility Performance

Category Category Recent

Functional Area Last Period This Period Trend

1. Containment and Other Safety-

Related Structures 2 1 Consistent

2. Piping Systems and Supports 3 2 Improving

3. Safety-Related Components 1 1 Consistent

4. Support Systems 1 1 Consistent

5. Electrical Power Supply and

Distribution 3 2 Consistent

6. Instrumentation and Control

Systems 2 2 Declining

7. Licensing Activities 2 2 Improving

8. Storage of Safety-Related

Components 1 2 Improving

9. Engineering / Construction

Interface 3 2 Consistent

10. Preoperational/Startup Testing Not rated 2 No Basis

11. Quality Assurance and

Administrative Controls Not rated 2 Consistent

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I V.- PERFORMANCE ANALYSES

1. Centainment and Other Safety-Related Structures' (1%)

a. Analysis '

During the~ prior assessment period, performance in this-functional

area was generally good. Problems were identified which involved

a failure to identify requirements for bolted connections of struc-

tural steel joints with long slotted holes and the lack of progress  ;

in repairing containment electrical penetration welds.

All inspection coverage in this area was by the resident inspectors

during the current assessment period. It included the licensee's

activities to demonstrate that surface coatings in containment were

acceptable, verification that high strength bolts and nuts were used

in the construction of structural steel members, and the repairs

made on the containment electrical penetration welds. Although in-

spection coverage was limited, this Functional Area was rated during

this assessment in recognition of the licensee's thorough followup

on problems noted in the last SALP as well as in-response to an

allegation.

The bulk of all concrete was placed during previous assessment

periods, and during the previous assessment period, the batch plant

was disassembled and removed from the site. The miscellaneous con-

crete poured during this period was'obtained from offsite. The

major work remaining to be done in this functional area is the  ;

closing of the cor.tainment construction opening: which is planned

for the fall of '985. ,

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. No problems were identified by the NRC during this assessment period.

The concerns expressed in the last SALP report regarding the slow '

progress being made on the required repairs to containment electri- ,

cal penetration welds have been satisfactorily resolved. During

this assessment period, all repairs were completed and reinspected

with minimal impact on construction.

To resolve an allegation that the NRC received from an outside

l . source, DLC performed extensive destructive tests on paint coatings i

inside containment to demonstrate acceptable coating adhesion and  ;

, thickness. The licensee took the initiative and contracted a coat-

j. ing expert to destructively sample 187 areas where coatings were

l applied to assess installed conditions. All areas investigated were

l acceptable. This demonstrates a commitment to quality and a desire

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to work with the NRC to resolve safety concerns.

No 50.55(e) reports were issued in this functional area.

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b. Conclusion

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Category '1, Consistent. Licensee actions to resolve concerns re-

sulting from allegations concerning coating quality are particularly

noteworthy.

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c. Board Recommendation

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Licensee

None

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None

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2. Piping Systems and Supports (27%)

a. -Analysis

- During the prio'r assessment period, there was a marked increase in

the number of deficiencies and errors noted in this functional area.

Many of:the protAems were attributed to deficiencies in basic docu--

p ments'such as drawings and specifications, and involved lack of

clarity, insufficient details, ambiguity, conflicting requirements,

_ etc. . Problems ~fn this area were closely related to weaknesses in

the engineering / construction interface; a Category 3 rating was

assigned.

This area received frequent coverage by the resident inspectors,

during four inspections by region-based specialists, and was in-

cluded in the Construction Team Inspection (CTI) coverage. One of

the specialist inspections included the NDE van and actual tests

were performed on.several components. A high level of piping in-

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stallation has continued throughout the assessment period. The

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majority of the large bore piping is installed; however, many of

[ .the associated supports are not. Small bore piping installation

is progressing satisfactorily.

_The licensee and constructor have been aggressively pursuing-and

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correcting the root causes of problems identified in this area in

the last SALP. An action taken in the Engineering Department was

L the formation of an " Integrated Construction Support Group" (ICSG)

in November, 1984. The personnel are located in the Auxiliary

Building which allows construction direct access to the engineers. '

The group's function is to' perform " hands on resolution of con-

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struction problems ~ associated _with the drawings or specifications."

This group has high visibility and accessibility to the construction

forces. It has strong licensee and constructor support and-although

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it has been operational for only a short time, it appears to be

functioning very well~and eliminating many construction / engineering

l. problems where confusion previously existed.

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l Stone and Webster Engineer.ng also established a "Constructability

l Review Team (CRT) to review pipe support drawings and assure they

were precise and clear. The objective was to eliminate the issuance

of confusing information to. Quality Control'and Construction which

would then be.used during installation and inspection. This di-

rectly addresses a problem. area discussed in the last SALP report.

This team consisted of representatives from Schneider. Power Con-

struction and Engineering,' Stone and Webster Construction and Engi-

neering, and Duquesne Light Company Site-Quality Control. Since

this team's inception in June, 1984, it has been very effective in

eliminating confusion on drawings. The team decided shortly after

its formation to completely redraw all pipe rack support drawings.

Also,1 numerous changes were required on-individual pipe support

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drawings. Many drawings were expanded from one sheet to two sheets

to provide clarity. The effectiveness of the CRT efforts, including

feedback ~to and training of design engineers, has been demonstrated

by the marked decrease in the percentage of drawings that are being

sent back for revision following CRT raview (from an initial rate

of approximately 50% to a 3-5% rate by the end of the assessment

period).

The " Engineering Confirmation Program" was implemented during this

period,_ partially because of past concerns identified by NRC. The

licensee's portion of this program was completed during this as-

sessment period. Stone and Webster plans to complete their part

of the program during 1985. Licensee management has shown strong

support for this program. The licensee is demonstrating through

implementation of this program, the acceptability and implementation

of specification and design criteria.

The licensee has placed greater emphasis on reducing the number of

first time rejects (i.e., construction presenting unacceptable

material to Quality Control), by emphasizing to the workers and

construction foremen the need for quality improvements during the

initial construction and installation of the hardware. This has

strong management support and resulted in a reduction of the amount

of rejected material. In parallel with these corrective actions,

the piping contractor replaced the Project Manager and Assistant

Project Manager effective January 1,1985. These actions are de-

signed to reduce the problems the contractor had been experiencing.

The above actions demonstrate considerable attention to past weak-

nesses in this area. To date, these efforts appear to have been

effective.

The licensee has implemented major reinspection programs to correct

discrepancies in the area of pipe supports and baseplates. (This

was also identified as a concern in the last SALP report.) Imple-

mentation also included numerous reinspections of supports due to

inspector error. (This item was reported to the NRC as a 50.55(e)

. item.) The reinspections and rework have, for the most part, been

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completed.

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i NRC has identified conc. erns in this area involving reworked items.

The contractor needs to' implement stricter controls when existing

QC inspection reports are nullified and when additional inspections

! are necessary when existing pipe supports are reworked or dismantled.

L Although the licensee has issued procedures to control this area,

implementation results have only been marginally effective. This

item was also the subject of a 10 CFR 50.55(e) report.

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The number of croblems identified by NRC and other independent

audits involving pipe supports indicates some weaknesses in the

quality program in this area. However, when problems were identi-

fled, the licensee took-excellent corrective actions through in-

spections and rework to assure the product was constructed ade-

quately. For the inspector errors, the licensee has taken strong

punitive actions and/or retraining where necessary.

Hardware quality was assessed during this period through inspections

performed using the NDE Mobile Lab. Numerous welds and supports

were inspected to verify component workmanship and quality. These

sample inspections found acceptable weld quality and verified the

installed product is constructed to acceptable quality standards.

To demonstrate the acceptability of using a flexible ring to main-

tain minimum gap on socket welds (trade name Gap-0-Lets), the lic-

ensee had extensive analytical work and flow testing performed on

simulated welds. This data supported the licensee's position on

acceptability; it demonstrates the licensee's willingness to resolve

any NRC quality concerns even when significant additional efforts

are required.

A " Construction Team Inspection" (CTI) performed late in the SALP

period found no significant problems in this area and verified ac-

ceptable construction practices were established. The CTI and NDE

independent inspections also found that the licensee, constructor

and contractors have excellent record-keeping and retrieval capa-

bilities.

In summary, the licensee has implemented numerous management pro-

grams supplemented by reinspection to strengthen tho programmatic

weaknesses identified in the last SALP report. From a programmatic

standpoint, these appear to be strong corrective actions and should

be effective in eliminating these weaknesses. However, for several

of these actions, implementation has been too recent to demonstrate

overall effectiveness. Control of reworked items needs additional

management attention to be effective. The CTI inspections found

this area to be adequately controlled. Overall, the licensee and

contractor have shown positive results and improvements since the

last SALP. With implementation of these programs and continuing

strong management support of the new controls, continuing satisfac-

tory performance should be assured and furthe.r improvements should

be achievable.

b. Conclusion

Category 2, Improving. Licensee / contractor initiatives have been

responsive to past NRC concerns in this area.

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c. Board Recommendation

Licensee

Continue to aggressively implement initiatives in this area.

NRC

Continue to monitor recent licensee / contractor initiatives to im-

prove the engineering / construction interface.

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3. Safety Related Components (15%)

a. Analysis

No significant problems were noted in this area during the prior

assessment period. Work on safety related components was found to

be well controlled; a Category I rating was assigned.

Most of the inspection activities in this~ area were by the resident

inspectors; there was one inspection by a region-based specialist.

The work activities in this area included connecting the main steam

nd feedwater piping to the steam generators, final assembly and

trial fitting of the reactor vessel upper and lower internals, re-

work of the main steam isolation valves, installing the reactor

coolant pumps and motors, and completion of the site fabricated

storage tanks.

NRC found that good controls were in place for the large amount of

work involved in welding, repairs, and heat treatment of steam

generator piping connections; fitting and welding of the reactor

vessel upper and lower internals; repairs of the main steam isola-

tion valves; and installation of the reactor coolant pumps and

motors. Two violations were identified during this assessment

. period; (1) failure to follow procedure for disassembly of a valve;

and (2) liquid penetrant indications found on previously inspected

and accepted reactor vessel internals. The licensee is taking cor-

rective actions on these items. The liquid penetrant indication

was found to be superficial when cosmetic sanding was performed and

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had no apparent effect on the structural adequacy of the reactor

vessel internals. Both cases appear to be isolated. However, bet-

ter controls on disassembly of components are warranted.

NRC found steel chips and other foreign material present on the in-

terior of the reactor vessel upper internals rod guides which indi-

cated a need to implement stronger controls on the fabrication and

installation of these critical components.

In summary, overall performance in this functional area is good.

The high performance levels noted in the previous SALP assessments

have been maintained except for isolated deficiencies.

b. Conclusion

Category 1, Consistent.

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c. Board Recommendation

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NRC

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4. Support Systems (9%)

a. Analysis

No significant fabrication problems were identified in this area

during the last assessment period. The licensee and contractor had

good controls; a Category 1 rating was assigned.

This area was covered by the resident inspectors and during two in-

spections by region-based specialists. Installation of the heating,

ventilation and air conditioning (HVAC) and fire protection systems

continued throughout the assessment period. No violations were

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identified.

Inspections were performed in several areas of HVAC installation

including vendor records and general construction. Limited inspec-

tions of records and procedures for fire protection systems were

performed. Good controls were found in each of these areas.

A 50.55(e) significant item was reported to the NRC. A Duquesne

Light Company Quality Assurance Audit identified that HVAC supports

failed to meet minimum weld sizes stated on the drawings. Investi-

gations performed by the licensee found the undersize welds were

missed primarily because of one inspector's errors. This indicates

some breakdown in the licensee's Quality Control Program; however,

the licensee's Quality Assurance Program was effective because their

internal audits discovered the deficiency. Management took neces-

sary punitive actions regarding the individual involved. In addi-

tion, management took good corrective actions by performing 100%

reinspection of the inspector's work and through sampling of other

inspectors' work. Overview inspections of new work as accepted by

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QC were also implemented. These aggressive actions were effective

in restoring confidence in the quality of support welds.

In summary, the licensee and contractor have good controls in this

area. The licensee's identification and correction of problems

indicates overall good control of quality. The contractor has also

demonstrated good fabrication controls.

b. Conclusion

Category 1, Consistent.

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c. Board Recommendation

Licensee

None

NRC

Reduce inspection coverage.

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5. Electrical Power Supply and Distribution (17%)

a. Analysis

Day to day construction and QC inspection activities were considered

to be under good control during the prior assessment period. How-

ever, the licensee / contractor had been very slow in developing and

implementing an approach that would meet cable separation commit-

ments and requirements so as to resolve widespread cable separation

problems. A Category 3 rating was assigned.

This area was covered by the resident inspectors, during six in-

spections by region-based specialists and by the CTI. Cable trays,

conduits, and cable continued to be installed throughout the as-

sessment period. The bulk of the remaining work involves cable

pulling and termination. Included in this area are cable support

activities (in trays and in free air) as well as wrapping cable for

fire protection, covering raceways with tray covers and other acti-

vities to meet the separation criteria required by Regulatory Guide

1.75.

One violation and one deviation were identified during this assess-

ment period. The violation involved failure to follow procedures

during cable pulling and inadequate controls for protection of cable

already installed. Exceeding cable bend radius, pulling cable with

nonconforming conditions on the cable, and damaging installed cable

because of sharp corners on tray side rails were examples cited in

this violation. These problems were attributed to lack of controls

in the interface between the Engineering, Quality Control and Con-

struction personnel regarding when cable pulling should be stopped

and/or started, timely issuance and disposition of nonconformance

and disposition reports, and written and/or verbal disposition by

Engineering. The deviation resulted from the licensee's failure

to fulfill commitments made to the NRC regarding controls on cable

overfill in raceways. Corrective actions regarding the deviation

have been taken and accepted by the NRC.

Other concerns were identified during this assessment period, many

of which represent lingering engineering / construction interface

problems similar to those discussed in the last SALP report. They

include:

--

Unsupported cable lengths in excess of specification which

could lead to support overloading and resultant cable damage

(denting). This issue now appears to be sufficiently clarified

to allow QC inspectors to perform inspections and identify

areas where additional supports are needed. In attempting to

resolve this issue, many conflicting requirements were pre-

sented to the NRC. The NRC's identification of these problems

and the constructor's failure to provide acceptable engineering

- * -

, ,

18

corrective actions at the outset of problem identification

indicates additional management attention is required to re-

solve technical issues as they arise in this area.

--

The retorquing of spring nuts, a problem identified by the

licensee. This a major problem which should have been avoided

with proper torque applied during installation. This was a

problem in the engineering area in failing to specify torque

4

requirements to the contractor for installation, consistent

with the spring nut manufacturer's recommendations,

i

--

The constructor's inability to provide satisfactory resolution

to the NRC's questions regarding consideration of side wall

pressure during pulling of cable. (Subsequent to the end of

the assessment period, the licensee was in the process of re-

vising cable pulling procedures and reviewing the acceptability

of existing pulled cable.)

--

NRC identified conflicting requirements between engineering

specifications and FSAR requirements regarding the identifica-

tion of cable runs from safety-related buses to non-Class 1E

loads. FSAR and specification changes were required to eli-

minate the confusion.

--

Other problems, such as the violation (see Functional Area

11) involving improper disposition of nonconforming condi-

tions on pull tension and bend radius, manual changes to en-

gineering cable pull tickets without design requirement con-

siderations and NRC concerns which involv:d the followup omis-

sion of shims on electrical supports, inacequate torquing of

anchor bolts used on electrical supports, inadequate control

of cable fills in raceways, tray-to-tray connections with use

of unqualified material, and lack of controls on storage of

coiled cable indicate weaknesses in the Engineering'and/or

Construction electrical discipline.

Many of these items have since been adequately resolved and in some

instances, reinspections to identify the need for rework are in

progress. The reinspection and/or rework of some of the other

items, such as retorquing the spring nuts, retorquing Hilti bolts

and inspection and installation of shims under baseplates is a con-

'

.

cern because of timeliness in commencing the reinspection. The plan

to inspect these items late in 1986 could create some accessibility

problems for Hilti bolts and baseplate shims. Also, further fabri-

cation and turnovers to DLC of these systems with existing known

nonconforming conditions is a concern because it creates the need

to perform construction rework on systems turned over to operations.

The last SALP identified that good corrective actions were being

taken on the majority of these items; however, since that time,

reinspections were stopped.

i

t

- - . . . - - ------.,-u-. -

- - - - nn-, - ,e-- - - - , - , , - - , , , - - , - . - - - , - ,

y ,.p.,.,

19

A' major area identified as a weakness in the last.SALP report re-

garding cable separation and compliance with Regulatory Guide'1.75

'has since received extensive management attention. Cable pulling-

was stopped by the-licensee until clear resolution and direction

was established. Stone and Webster Engineering established a pro-

~

gram to resolve all issues and systematically accomplished these

objectives. Construction and QC personnel have been trained with

respect to separation requirements. Effective May 18, 1984, subse-

quent electrical-installations (external to panels) have complied

with Regulatory Guide 1.75. -Also, Stone and Webster and Duquesne

Light Quality Control inspectors have completed an inspection pro-

gram which identified areas requiring rework. The rework is~ virtu-

ally completed. -Further, the licensee has implemented a test pro-

gram to support the cable separation program, regarding the. kinds

and amounts of cable wrapping and cable tray covers necessary for

compliance with the regulatory guide. Except for actual installa-

tion of cable wraps and tray covers, resolution of this item is

complete. This area has clearly shown positive involvement by the

licensee and Stone and Webster's management since the last SALP.

report, and as a result, corrective actions have been responsive

to past concerns.

Other areas discussed in the last SALP report have also received

increased management attention and are showing marked improvement.

The Integrated Construction Support Group (discussed in Functional

Areas 2 ard 9) established by Stone and Webster. Engineering also

plays an important role in resolving issues and questions in the:

field involving electrical issues. This concept of placing engi-

neers in the butidings where the work is being accomplished provides

an excellent contact to field personnel for clarifying and/or re-

solving issues.

The "Constructability Review Team" (also discussed in Functional

Areas 2 and 9) reviewed conduit support drawings and revised draw-

ings where necessary to provide concise and clear information to

the field. Again, this has helped eliminate confusion regarding

drawing requirements which existed during the last SALP period.

,

-

'

Generally, the electrical contractor (Sargent Electric) has demon-

strated a sound quality oriented approach to safety issues. With

, some exceptions, no major problems have occurred in the construction

'

and installation of cables and cable trays in accordance with

specifications and procedures. Exceptions are the violation in-

volving minimum bend radius of cable in pull boxes and failure to

cease pulling cable when nonconforming conditions existed on cable

from the pulling operation. Increased management attention is

,

warranted to assure compliance with requirements pertaining to

[ cable damage, bend radius and pull tension.

i

e

r

• ,

,

20

QC personnel and management are well qualified and knowledgeable

of work requirements, specifications and procedures. The training

program for QC inspectors is well conceived, thorough and well ex-

ecuted. Personnel are adequately trained.

In summary, improvement is noted in this area since the last SALP

report. Management, through reorganization and restructuring, has

effectively addressed the cable separation and other problems de-

scribed in that SALP report. This area has received significantly

increased attention by both the licensee and Stone and Webster since

the last SALP report was issued. Most of the identified problems

occurred earlier in the assessment period; resolution of cable

separation concerns is progressing well. Although improvement has

been shown during this assessment period, numerous lingering prob-

lems still exist.

b. Conclusion

Category 2, Consistent. This area continues to warrant priority

licensee / contractor attention.

c. Board Recommendation

Licensee

Complete development of an overall comprehensive plan to address

and resolve problems in this area. Implement an integrated plan

for timely resolution of remaining outstanding electrical issues.

,

Complete reinspections and rework prior to system tut aover.

NRC

Maintain present inspection level in this area to monitor licensee

resolution of past issues and completion of work.

.

n-

O ;- o ,

21

6. Instrumentation and Control Systems (11%)

a. Analysis

During the last assessment period, control of onsite construction

and inspection activities in this area was considered to be good.

However, several items fabricated offsite were identified as needing

significant inspections and rework. A Category 2 rating was as-

signed.

There was some coverage of this area by the resident inspectors,.

three inspections by region-based specialists, and the CTI included

these systems. Various work in this area continued throughout the

site similar to the last SALP period such as wiring and terminations

in the Control Building and terminations in various control panels.

Also, installation of various flow, pressure and temperature in-

strumentation began in several safety-related systems such as the

Service Water System and the Primary Component Cooling Water System

to support turnover of portions of these systems to the DLC Startup

Group.

Stone and Webster Engineering and DLC Site Quality Control devised

a program to inspect and correct various workmanship problems in

the internal wiring of numerous panels discussed in the last SALP

report. During this assessment period, the licensee completed a

100% reinspection effort of these panels and has corrected many of

the workmanship problems. Also, vendor surveillance inspection

plans were upgraded for any future inspections of wiring at vendor

facilities prior to panel shipment. These action demonstrate the

licensee's continuing commitment to quality.

Four violations were identified late in this assessment period with

three of these violations concerning the installation of instruments

and instrument tubing. The fourth violation concerned the failure

to implement the QualI y Assurance Program when inspecting panel

internal wiring against Regulatory Guide 1.75 separation require-

ments.

The three violations involving the installation of instruments and

instrument tubing were the result of inadequate engineering design

review and ambiguity in the specification and are indicative of a

problem in this area. Specifically, onsite engineering failed to

translate sufficient information from composite drawings to single

line construction drawings used by craft and QC personnel. The in-

sufficient information in tFese drawings regarding installation and

construction criteria such as instrument type, tubing size, loca-

tion, separation, slope and routing led to problems involving in-

adequate separation of redundant tubing, mounting of redundant in-

strument tubing on the same support and failures to mount instrument

vents and drains to direct the discharge away from personnel and

i

- -- -

_,_ _

- - . - _ _ _ . - _ _ . ..

?

m ,

.

,

i 22

electrical _ equipment. The licensee and Stone and Webster took rapid

corrective action by issuing a stop work order on the installation

of instrument tubing pending an engineering review and resolution

of the-discrepancies. The licensee has proposed tighter engineering

controls, but still does not require Quality Control personnel to

verify separation criteria for instrument tubing.

The violation concerning the lack of QC inspection of panel internal

wiring separation also occurred at the end of this assessment period.

The licensee and Stone and Webster developed a procedure to inspect

the internal wiring in all safety-related panels for compliance with

Regulatory Guide 1.75 and to define the rework necessary for com-

pliance. .While this process appeared to provide a method to upgrade

these panels, these inspection activities did not follow the DLC

Quality Assurance Program in that personnel performing inspections

were not part of the QA function, were not certified to perform in-

spections, and were not independently separated from the organiza-

tion directly responsible for performing the specific activity (Stone

and Webster Engineering in this case). The licensee / contractor needs

to provide additional attention to problem resolution to assure that

actions to resolve deficiencies do not circumvent the existing QA/QC

programs.

In summary, several violations were identified in this functional

area in the last two months of the assessment period. However, other

installation and QC inspection activities have been satisfactory.

Separation requirements for panels (internal wiring) and instrument

tubing are still being addressed; instrumentation separation clearly

received lower priority than cable separation (see Section 4). Clear

definition of engineering criteria and Qualit> Control functions

and responsibilities need to be addressed for instrumentation and

control systems. Further, inspections conducted on safety-related

equipment must be in accordance with the approved DLC Quality As-

surance Program. Additional management involvement is needed in

this area to maintain high quality standards and timely resolution

of separation problems,

b. Conclusion

Category 2, declining.

c. Board Recommendation

Licensee

Resolve internal panel wiring discrepancies in a timely manner.

Assure that separation inspections are in accordance with the DLC

Quality Assurance Plan and verify compliance with requirements.

NRC

Increase inspection effort.

7

( . <

-

.

23

-7. Licensing Activities

a. Analysis'

This area was categorized as satisfactory (Category 2) during the

previous SALP. Evaluation and monitoring of licensing activities

included routine contact between the NRC and DLC as well as con-

ference calls, site visits, meetings and audits as required. The

major licensing activities during this assessment period involved

the continuation of the NRC stcff review of the FSAR and ER, issu-

ance of the Draft Environmental Statement and Draft Safety Evalu-

ation Report, and preparation for Safety Evaluation Report (SER).

Based on a composite of a number of functional areas, the applicant

continues to demonstrate evidence of prior planning and assignment

of priorities. He has well stated, controlled and maintained ex-

plicit procedures for control of activities. This has been shown

by the applicant's approach to resolving approximately 350 open

items identified in the staff's draft safety evaluatior. report to

support preparation of the final SER. The applicant established

a program to identify and track the status of each item and main-

tained internal schedules for resolving each open item. Generally,

DLC management assigned the necessary technical people to develop

complete, high quality responses,. Further, he has been using the

NRC backfitting procedures provided (e.g., NRC Manual Chapter 0514)

in an attempt to assure that only cost effective safety measures

are implemented.

In a majority of cases the applicant nrovided timely responses to

open issues. The applicant was resptnsive to a majority of the

staff concerns, took the initiative to resolve issues by requesting

conference calls, and meetings, and promptly followed up with sub-

mittals of responses. Responses were generally technically sound,

concise, and addressed the staff's concerns in a professional man-

ner. Some exceptions occurred during the power systems, mechanical

engineering, radiological assessment, meteorology and effluent

treatment, auxiliary systems, and instrument and control systems

portions of the safety review. In these cases, several discussions

and meetings with the applicant were necessary in order to obtain

clarification and reach resolution. Although corporate management

reviews and signs all submittals to NRR, it is felt that increased

direct management involvement might have expedited the resolution

in these cases. Early on, while DLC management urged the NRC staff

to meet their scheduled milestones, they did not provide timely in-

puts of sufficient quality for NRC to meet those milestones. How-

ever, more recently this situation has improved.

DLC generally demonstrated a clear understanding of issues during

meetings and discussions with the NRC staff and in its submittals

to the staff. Its approaches to resolution of technical issues are

r

'

.

o .

24

viable and generally sound and thorough. The applicant was willing

to perform additional studies as necessary to resolve technical

issues. He performed detailed analytical technical work in a timely

manner to support the SER schedule. Generally, when the staff and

the applicant held differing technical positions, the applicant

provided a sound basis for his position. Some exceptions occurred

concerning the auxiliary systems, instrumentation and control sys-

tems, and power systems portions of the safety review. In these

-

cases, tne applicant did not always demonstrate a clear understand-

ing of the issues. Viable approaches to resolution were generally

proposed, however, in some cases it required much more interaction

than normally required.

Positions within the applicant's organization are identified and

authorities and responsibilities are well defined. Generally, suf-

ficient technical staff have participated in review meetings to

effect timely resolution of open items. DLC licensing staff have

been very, effective. However, it is felt that management involve-

ment in resolution of significant issues failed to prevent the need

for additional staff effort to obtain resolution and prevent schedule

-

delays.

Overall, our. conclusion is that, although the reported individual

ratings for the evaluation criteria were variable, the licensee's

performance in this area has been adequate and reasonably effective

in addressing nuclear safety considerations. The increased manage-

ment participation towards the end of the SALP period has contri-

buted to improved understanding and resolution of issues.

b. Conclusion

Category 2, Improving.

c. Board Recommendation

Licensee

None.

NRC

None,

i

--

.

1. '. .,

i

25

8. Storage of Safety Related Components (9%)

a. Analysis

This area is listed as a separate functional area because it was

assessed as a weak functional area in two of the last three SALP

reports. In addition to the resident inspector's daily site tours

and specific inspections, there were three inspections by region-

based specialists.

Storage conditions were observed throughout the site both for

equipment already installed and for equipment still in storage in

the warehouses. Four violations were issued during this assessment

period concerning storage of a variety of plant equipment - instru-

mentation, personnel airlock, piping and motor operators. Addi-

tional NRC concerns occurred involving storage of an assortment of

equipment - coiled cable, sealing electrical terminals, fan motors,

fuel pool heat exchangers, batteries, instrument valve manifolds,

and reactor vessel upper internals. Inspections found moisture

present on the inside surfaces of the fuel pool heat exchangers

(records indicated components were in dry lay-up). In addition,

records indicated water was found two years earlier in the same heat

exchanger and no corrective actions were taken.

With one exception, all of these findings pertained to in place

storage of components. These problems and other NRC findings indi-

cated that during the first part of this assessment period, the

Itcensee's storage program significantly deteriorated from the

category 1 condition which was present at the end of the last SALP

period.

In December, 1984, based on NRC findings, the licensee recognized

that strong corrective actions were necessary to upgrade the storage

program with particular emphasis placed on components requiring in-

place storage and maintenance. A Composite Review Work Group (CRWG)

was formed with construction, engineering and startup personnel from

Stene & Webster, Duquesne Light Ccmpany, Schneider Power Corporation

(SPC) and Sargent Electric Company (SECO). The CRWG conducted a

building-by-building review of the in place storage conditions of

safety-related components beginning in January, 1985, with the

Reactor Building and ending in March, 1985, with the Primary Intake

Structure. Subsequent to these building reviews, SPC and SECO

building and area foremen are being held responsible to maintain

equipment in a properly stored condition until it is accepted for

test. Also, a Management Oversight Committee (MOC) was formed to

review the reports published by the CRWG and by the Management Com-

i mittee for Storage Review which conducts regularly scheduled site

tours with emphasis on in place storage. The MOC, which began

'

functioning in February,1985, is charged with assessing the overall

storage program effectiveness as project conditions change.

.

.

____ ____-__-__ _ _ _ __

v

. t :. Lo.. <

_

-

!

26 i

s - o

,

l Although final reports of the'CRWG are not issued yet, positive re-  !

p _ sults are apparent to the inspectors during daily tours of the-site.

'This observation was confirmed by the Construction Team Inspection.

!

(CTI) performed in March,1985, when no NRC findings occurred in -

this area. At that time, in place storage of components was gener-

ally good; the team was favorably impressed by in plant conditions.

In summary, the ifcensee's corrective actions have reversed the

deteriorating trend previously observed earlier in theLassessment

. period. However, the long term effectiveness of controls in this

area will be determined by the attention devoted by the contractors

. to in place storage in-their respective work areas. Due to extended

L construction schedules, storage controls of critical components must

receive increased management attention and corrective actions must

, be taken when adverse conditions are found. Licensee management

r must review the storage program efforts on an ongoing basis to en-

sure that the in place storage of components continues to improve

and the recent positive trend in this' area does not become just a

momentary one.

<

1

b. Conclusion

,

Category 2, Improving.

c. Board Recommendation

'

Licensee

Provide continuing management overview to preclude recurrence of

.

past cyclic performance in this area.

NRC

!

,7 f None.

li  ;

,

\

f

s .f

F

b

-m_.-._._,, ,,,

- - . - . . - , , . . - , . ~ . . . - - - . - ~ . - - , , .,_.,.._,_.m.m.,_,,-._,.,,r.,_,,,.,_,,,myo--.,wy w- __,.,-,,m_m

-

. ,

., ,

27

9. Engineering / Construction Interface (6%)

a. Analysis

In the prior assessment period, a Category 3 rating was assigned

to this functional area, primarily due to numerous deficiencies

noted in the contents of design related documents issued by vendors

and contractors. Engineering documents frequently failed to contain

sufficient information and/or information that was clear enough for

field use by Construction and QC personnel. There was inadequate

interface between engineering and construction to resolve the field

problems that resulted from such engineering document deficiencies.

Inspections by the resident inspector included the " Engineering

Confirmation Program", the "Constructability Review Team" and the

Integrated Construction Support Group (ICSG). One inspection was

conducted by a region-based specialist inspector concerning the

" Engineering Confirmation Program" where the validity of an elec-

trical calculation affecting the sizing of 5 KV power cables was

in question. Region-based inspectors reviewed the engineering / con-

struction interface as part of the Construction Team Inspection

(CTI) performed in March, 1985.

Both the licensee and the AE have taken numerous steps during this

assessment period to correct weaknesses in this area and to

strengthen the engineering / construction interface. Some of these

actions concerning the " Engineering Confirmation Progran" had been

underway since October, 1983, as noted in the last SALP report.

The numerous steps taken to improve performance have required addi-

tional experienced manpower. Stone and Webster, in particular, has

substantially upgraded their Site Engineering Group (SEG) with the

addition of senior technical personnel. Several individuals were

added recently, but the major personnel changes occurred between

April and September,1984, when twenty-four additional engineers

were added to the SEG. This group included three new Assistant

Superintendents of Engineering, each of whom brought at least 10

years of engineering and construction experience to his position.

Also included in this staff increase were two principal engineers

in the pipe support area and a senior design supervisor in the

electrical design area. Further, Stone and Webster management ap-

pointed a SEG Site Sponsor who reports to the Stone and Webster

Engineering Manager at Boston, and provides upper Stone and Webster

management attention and support for SEG efforts.

The Duquesne Light Company (DLC) manpower commitment has also been

substantial. An example of such commitment is illustrated by the

expenditure of approximately 11,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> by forty-eight OLC engi-

neers in completing the design bases endorsement effort of the

" Engineering Confirmation Program" with the major conclusion drawn

that OLC has no unresolved concerns with the Beaver Valley Power

,

., . ,

28

Station - Unit 2 Plant Design Bases. NRC found this effort to be

thorough. DLC did identify some specific design discrepancies, but

these are being resolved with Stone and Webster through an effective

follow-on program.

Project utilization of this additional manpower has achieved posi-

tive results in strengthening the engineering / construction inter-

face. This was evidenced in the CTI when it was concluded that im-

provements had been made in the engineering / construction interface

for all functional areas

Distribution area where p,except the Electrical

roblems still Power Supply

exist. As discussed and

in more

detail in Functional Areas 2 and 5, the "Constructability Review

Team" and the ICSG have been instrumental in providing improved

communications between engineering and construction. In particular,

the ICGS has significantly enhanced the engineering / construction /QC

interface by improving the availability and timeliness of engineer-

ing involvement in problem resolution. Mechanical and Electrical

Constructability Review Teams (CRTs) were established in June and

July, 1984, respectively. These CRTs were effective in addressing

past concerns in this area involving cluttered and overly complex

drawings as well as ambiguous, confusing and sometimes conflicting

installation drawings and specifications which often led to inter-

pretations by crafts and QC personnel inconsistent with the de-

signer's intent. These CRTs reviewed all new or revised drawings

before issuance. Dramatic improvements were achieved (from initial

drawing revision rates to resolve CRT concerns of 50-75% to a 3-5%

revision rate by the end of the assessment period). Following the

successes achieved in improving drawing quality, CRT efforts were

also focused on "insta11 ability" reviews (assuring that installa-

tions could be made without problems regarding access, interfer-

ences,etc.). These initiatives (ICSG and CRTs) have been particu-

larly responsive to past NRC concerns in this area.

In summary, substantial improvements in the engineering / construction

interface have been made in all functional areas. In the electrical

and instrumentation Functional Areas, some lingering interface

problems still exist as noted therein. A substantial addition of

experienced, technical personnel by both Duquesne Light Company and,

in particular, Stone and Webster occurred during this assessment

period. Continued high level of management involvement is needed

to solve the weaknesses in the electrical / instrumentation areas

similar to the success achieved in the mechanical area. Also, man-

agement must continue to be sensitive to the engineering /construc-

tion interface in all functional areas to ensure that the recent

improvements remain until the project is completed.

T

.

.,.,

29

b. Conclusion

Category 2, Consistent.

c. Board Recommendation

Licensee

None.

NRC

None.

. _ . ._ . - .

-- . _ _ _ _ - - . -. - . - - -

F

' *

. .

30

10. Preoperational/Startup Testing (5%)

a. Analysis

This is the first SALP report to separately address this Functional

Area. Two inspections were made in this area by region-based

specialists and there was some additional coverage by the resident

inspectors.

During the assessment period, management changes were made in the

startup area to reorganize all startup activities into a single

group. This reorganization included the addition of personnel from

Shippingport Atomic Power Station and Beaver Vall.ey, Unit 1. These

changes have not been incorporated in the Nuclear Construction

Division Procedures Manual (see Functional Area 11).

Earlier in this period, NRC found that the licensee had not formally

issued a Startup Manual, even though some work was being accomplished

to individual test procedures. By the end of this assessment period,

the Startup Manual had been issued. Another concern identified by

NRC regarded the need for the licensee to provide a procedure which

established the criteria for turning a system over to the licensee.

System turnovers without established criteria limiting the types

of nonconforming conditions that can be accepted have resulted in

high numbers of or.en items. Some of these items require a substan-

tial amount of construction before they are complete. This is con-

sidered to represent a weakness in the program for system turnover

where pressure to show progress is a contributing factor. However,

the CTI did observe that, for the system sampled (primary component

cooling water), all significant discrepancies noted in an extensive

system walkdown were already being tracked in various site tracking

systems.

During the assessment period, the licensee accepted portions of 18

safety-related systems (38 subsystems) from construction; the major

1tems being primary component cooling, service water, main trans-

former and associated protection equipment, 480 volt buses, unin-

terrupted power supply, storage batteries and electrical panels.

One violation was issued during this period; failure to certify

personnel performing walkdown inspections in preparation for system

turnovers. The licensee promptly corrected this item and it has

been accepted by the NRC.

In summary, during this period only the programmatic a'id staffing

aspects of this functional area were evaluated. It is premature

to fully assess the overall quality and effectiveness of the program

implementation at this time. Preliminary reviews have, however,

found weaknesses in the program related to personnel qualification

and establishment of system turnover criteria, which warrant man-

agement attention.

_ _ .

l

• ...

• ..

31-

b. Conclusion

Category'2. Inspection limited to latter part of period, therefore,

no basis for trend.

c. Board Recommendation

Licensee

Assure that pressures to achieve system turnover do not lead to

turnovers with excessive construction items remaining to be finished.

NRC

'

None.

• .

• ,

32

11. Quality Assurance and Administrative Controls

a. Analysis

This is the first SALP report to separately address this functioral

area. Quality assurance activities and their associated admini-

strative controls are also a part of all other functional areas.

Startup operations involve many administrative controls to properly

test, operate and maintain equipment different than construction

activities require. Therefore, administrative controls within the

project take on increasing importance. The licensee's performance

concerning quality was closely monitored by NRC while several re-

organizations occurred within the licensee's Nuclear Construction

Division involving senior management changes during the project

transition.

Inspections performed by the Construction Team Inspection (CTI)

conducted in March, 1985, included specific reviews of the quality

assurance and project management areas. One violation involving

procedural compliance was identified during the CTI; two other vio-

lations involving failures to properly remove hold and reject tags

and properly disposition an N&D concerning cable pull tension were

also identified in othee inspections. All NRC open items are

tracked on a "Next Step List" which is published monthly.

In the past, the licensee has demonstrated an adequate QA program.

The overall QA and QC programs, organizations and responsibilities

continue to be well defined. QA/QC personnel are qualified and

+ rained; staffing has been adequate. QC management is strong and

.

responds to NRC issues as well as plant problems in a technically

sound and timely manner. The licensee is presently implementing

a new program called Quality Improvement Management Program (QIMP)

designed to involve the licensee and constructor / contractor upper

management in improving quality and construction. The program's

objectives are for the regular review of construction's quality

performance, clear assessment of causes for adverse performance

tr. ends, and implementation of appropriate corrective measures for

performance improvement.

Many positive facets of the licensee QA program were evident during

the CTI. However, certain NRC concerns were identified during the

CTI involving numerous organization changes and potential weaknesses

due to several reorganizations in the DLC Nuclear Construction

Division. NRC has expressed a concern that the organizational

changes wherein the QA/QC function reports to the Nuclear Group Vice

President who also functions as the DLC Project Manager may de-

crease the effectiveness of QA/QC.

_ _____ _ _ _ _ _ . _ _ _ _ __ _ - _ . _ _ _ _ _ _ _ _ _ _ _ .

• . ..

,

.

I

33

The procedure violation noted during the CTI affected various docu-

mentation including Stone and Webster Engineering documents, vendor

test reports, receipt inspections, and Westinghouse (NSSS) procedures.

While these items were relatively minor on an individual basis, when

viewed collectively, they show that the project needs to emphasize

the importance of following procedures. This fact was further

illustrated during the CTI when the DLC Nuclear Construction Divi-

sion Procedures Manual was found to be in need of revision in

several areas to reflect the organizational changes made in the DLC

Nuclear Construction Department when the OLC Startup Group was

formed. This was viewed as a project managament weakness since

these DLC Nuclear Construction Department organizational changes

had occurred approximately a year before the CTI. The DLC Nuclear

Construction Division Procedures Manual has not been revised to

reflect these changes.

'

. The licensee's audit program is being effectively implemented and

is generally thorough. Corrective actions for audit findings are

prompt and thorough. Staffing is adequate as evidenced in the ,

timely completion of the audit schedule and followup verification

of audit findings. One of the joint Stone and Webster /DLC audits

of SEG activities was exceptionally detailed and technical in nature

involving several Stone and Webster technical personnel. Such

audits are considered to be an improvement compared to past audits

which were more procedural in nature.

In summary, controls in this area are adequate. Quality Assurance

audits are effective. Quality Control management is effective in

resolving problem areas. Isolated cases of inspector errors have

been corrected and sampling over-inspection of all inspectors' work

should curtail future errors. DLC organizational changes need to

be reflected in the Construction Division Procedures Manual,

b. Conclusion

.

Category 2, Consistent. ,

c. Board Recommendation

Licensee

. Provide project organizational stability. Continue recent initi-

<

atives by completely implementing QIMP. Assure that proper QA in-

dependence from schedule and cost considerations is maintained.

-

NRC

Conduct a special inspection of new organization in about six months

to determine effectiveness of QA/QC functions,

i

___. .-.

o- , . . ,

34.

V. SUPPORTING DATA AND SUMMARIES

1. Construction Deficiency Reports (CDRs)

Nine CDRs were submitted by the licensee during the assessment period.

Six of the deficiencies were associated with vendor supplied hardware.

Two corrected CORs, 84-00-07 and 84-00-09, were reviewed by the inspec-

tor during this period, with corrective actions considered acceptable.

Deficiency reports are listed in Table 1.

2. Investigation Activities

The. licensee conducted numerous tests on containment coatings to deter-

mine the validity of an allegation received by the NRC. Based on work

performed by the licensee and inspections performed by the NRC, this

allegation was not substantiated and is closed.

3. Escalated Enforcement Action

None.

4. Management Conferences ,

June 12, 1984 - A special, announced management meeting at NRC request  ;

to discuss the results of the Region I SALP board convened to assess

Itcensee performance from December 1, 1982 to March 31, 1984.

October 29, 1984 - A special, announced management meeting at NRC request

to discuss the licensee's progress in problem areas discussed in the most

recent SALP report.

1

.

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s

_ _ _ _ _ _ _ _ _ _ _

• .$ ,

,

35

TABLE 1

CONSTRUCTION DEFICIENCY REPORTS

(April 1, 1984 - March 31, 1985)

BEAVER VALLEY POWER STATION, UNIT 2

CDR Number Deficiency Cause Code

84-00-05 Misapplications of solenoid-operated valves B

84-00-06 Removed, dismantled or partially dismantled pipe F

supports

84-00-07 Inadequate wiring on voltage regulators supplied by B

Power Conversion Products, Inc.

84-00-08 Potential cracking / breakage of the lube oil pump bosses B

on the diesel generators

84-00-09 Auxiliary feedwater pump impeller wear ring - change in B

material

84-00-10 Hydrogen Control System-spurious operation Determined

of motor-operated valve not to be

reportable

84-00-11 QC acceptance of u.1dersized/ incomplete welds on HVAC, Determined

pipe supports not to be

reportable

85-00-01 Inadequately torqued bolts for electrical support

connections D

i

'

85-00-02 EFCO-600 actuator latching mechanism for MSIVs - i

failure of latch roller bearing E

Cause Codes

A - Personnel Error

8 - Design / Fabrication Error

C - External Cause

0 - Defective Procedure

E - Component Failure

F - Site Construction Error

i

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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36

TABLE 2

VIOLATIONS

(April 1, 1984 - March 31, 1985)

BEAVER VALLEY POWER STATION, UNIT 2

A. Number and Severity Level of Violations

1. Severity Level

Severity Level I O

Severity Level II O

Severity Level III 0

Severity Level IV 11

Severity Level V 5

Deviations _1

TOTAL 17

B. Violations vs. Functional Area

Severity Level

Functional Area Deviations IV V

1. Containment and Other Safety-Related Structures 0 0 0

2. Piping Systems and Supports 0 0 0

3. Safety nelated Components 0 1 1

4. Support Systems (HVAC) 0 0 0

5. Electrical Power Supply and Distribution 1 1 0

6. Instrumentation and Control Systems 0 3 1

7. Licensing Activities 0 0 0

8. Storage of Safety-Related Compcnonts 0 2 2

9. Engineering / Construction Interface 0 1 0

10. Prooperational/Startup Test 0 1 0

11. Quality Assurance and Administrative Controls 0 2 1

TOTAL 1 11 5

. _ _ _

. , . ,

37

TABLE 3

INSPECTION HOURS SUMMARY (4/1/84 - 3/31/85)

BEAVER VALLEY POWER STATION, UNIT 2

Functional Area Hours % of Time

1. Containment and other Safety-Related Structures 50 1

2. Piping Systems and Supports 1039 27

3. Safety-Related Components 607 15

4. Support Systems (HVAC) 345 9

,

5. Electrical Power Supply and Distribution 668 17

6. Instrumentation and Control Systems 425 11

7. Licensing Activities 0 0

8. Storage of Safety-Related Components 372 9

9. Engineering / Construction Interface 219 6

-10. -Preoperational/Startup Test 192 5

-11. Quality Assurance and Administrative Controls *

TOTAL 3917 100

• Included in other functional areas

1,

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• .

• .

38

TABLE 4

INSPECTION ACTIVITIES

BEAVER VALLEY POWER STATION, UNIT 2

Report

Number Inspector Areas Inspected

~

84-04 Specialist Installation of safety-related electrical equipment

108 Hours and the status of the separation program.

84-05 Resident Followup on unresolved items, bulletins, 50.55(e)

107 Hours items, information notices, self-initiated INP0

audit; design and inspection of seismic Cat. 2 com-

ponents and daily site tours.

84-06 SALP Report.

84-07 Resident Followup on unresolved items, allegation on surface

127 Hours coatings, 50.55(e) items, deviation; cable separation;

activities of constructability review team; vendor

supplied material record review; qualification of

post weld heat treatment.

.

84-08 Specialist Work activities relative to the installation of in-

96 Hours strument cables and termination, and HVAC system to

ascertain whether these activities were being accom-

plished in accordance with NRC rec'irements and

licensee SAR commitments.

84-09 Resident Followup on noncompliances, unresolved items and

135 Hours 50.55(e) reports; in place storage; reactor vessel

internals; dispositioning Nonconformance and Dispo-

sition Reports; fire protection; record review of

steam generator tube rolling.

84-10 Specialist Work activities and documentation relative to the

96 Hours installation of instruments and electrical equipment

storage to ascertain whether these activities were

being accomplished in accordance with NRC require-

ments and licensee SAR commitments.

84-11 Specialist Followup on licensee actions relating to several

8 Hours open items in the area of HVAC, electrical, piping

and equipment supports.

84-12 Specialist Inspection of turnover portion of the Quality Assur-

104 Hours ance Program for preoperational testing, including

QA/QC overview and interface activities.

s

,

.

• ,

39

Report

Number Inspector Areas Inspected

84-13 Specialist Previously identified unresolved items, record re-

61 Hours view, qualification of post weld heat treatment,

observation of welding, visual inspection of welds,

review of welder performance qualification, filler

metal control,

s

84-14 Resident Followup on unresolved items and 50.55(e) items,

142 Hours Quality Control reinspection program of supports,

electrical cable, incorporation of Construction Re-

vision Notices, Engineering Confirmation Program,

drawing control, seismic and environmental qualifi-

cation reports, record-review of pipe welds,

84-15 Specialist Independent measurements inspection at the construc-

434 Hours Onsite tion site using the NRC mobile Non-destructive Ex-

192 Hours Offsite amination (NDE) Laboratory. Selected safety-related

piping, structural and support weldments fabricated

to ASME Code,Section III, Classes 1, 2 and 3, and

American Welding Society (AWS) Code D1.1 requirements

were inspected.

84-16 Resident Followup on unresolved items, in place storage of

247 Hours components, construction of Spent Fuel and Refueling

Cavity Liner, electrical and instrument tubing sup-

port installations, repair of main steam isolation

valves, Inst weld heat treatment of piping welds,

upper rea tor vessel internals, disposition of Non-

conformance and Disposition Reports.

84-17 Specialist Installation of safety-related electrical equipment

62 Hours and the status of the color separation program and

the vendor wiring inspection program.

84-18 Resident Followup on unresolved items, in place storage of

307 Hours reactor coolant system component fuel pool heat ex-

changers and batteries, installation of rigid sway

strut pipe supports, review of several information

notices.

84-19 Specialist Activities relating to the installation of safety-

16 Hours related electrical cable and equipment.

.

. . , .,

40

Report

Number Inspector Areas Inspected

85-01 Specialist Preoperational test and operational preparedness in-

72 Hours spection program including schedule of testing acti-

vities, construction program status, test program

requirements, responsibilities and involvement of

Quality Assurance and Quality Control, preoperational

test procedure status, test procedure review and

verification.

85-02 Specialist Safety Injection System piping, pipe supports, reac-

95 Hours tor vessel internals, preservice inspection and re-

view of certain open items.

85-03 Resident Followup on unresolved items, in place storage of

227 Hours components, installation of pipe supports, contain-

ment polar crane maintenance, weld material control,

weld material certification, review of welding, in-

spection procedures, and installation of high

strength bolts and nuts.

85-04 Specialist Work in process, completed work, and partially com-

62 Hours pleted work relating to the installation of safety-

related components and systems. Review and closeout

of open items.

85-05 Resident Followup on unresolved items, control of hold tags,

191 Hours inspection and disposition of electrical panel wiring

separation, cable pull ticket controls, pipe welding

and associated activities; installation of electrical

pull boxes.

85-06 Resident Followup on unresolved items, review of radiographic

100 Hours film, welder qualification, and review of nonconfor-

mance and disposition reports.

85-07 CTI Project management, engineering / construction inter-

693 Hours Onsite face, electrical, piping, and quality assurance.

235 Hours Offsite

-

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41

ATTACHMENT 1

ENFORCEMENT DATA

Report Severity Functional

Number Subject Level Area

84-08-03 Uncapped or unplugged instrument tubing and

instrument connection ports. (Closed 84-16) V 8

84-09-01 Failure to meet commitments to revise several

documents affecting raceway cable overfill.

-(Closed 85-05) Dev. 5

84-09-02 Failure to follow procedures to control storage

of the personnel air lock (Closed 84-16) IV 8

84-10-01 Sealing of electrical equipment in storage. V 8

84-12-01 Walkdown personnel are not certified / qualified

except group leaders and Site Quality Control. IV 10

84-18-01 Failure to adhere to procedures for stcrage

requirements for permanent plant equipment. IV 8

85-02-01 Failure to follow procedures for disassembly

of valve. IV 3

85-02-05 Liquid penetrant indications founds on pre-

viously accepted reactor vessel internals. V 3

,

85-04-01 Instrumentation separation did not meet

l criteria. IV 6

f_ 85-04-03 Vent drain lines not installed per

,

specification V 6

i

j 85-04-04 Instrumentation supports-redundant lines not

l supported from independent supports. IV 6

85-05-01 Failure to remove hold and reject tags in

accordance with procedure requirements. IV 11

(

85-05-02 Failure to perform QC inspections in accordance

l

'

with the QA program on electrical panel internal

wiring separation. IV 6

l

l

i

c . * d .>I ,

42

Report Severity Functional

Number Subject Level Area

-85-05-03 Failure to properly disposition Nonconfor-

mance and Disposition reports for cable

pull tension and bend radius. IV 11

85-07-01 Failure to follow procedures in electrical cable

installation IV 5

85-07-02 Failure to maintain records to show how or IV 9

whether cable side wall pressure was con-

sidered in cable pulling calculations.

85-07-03 Failure to follow administrative procedures. V 11

L

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