ML20134A940
| ML20134A940 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Marble Hill |
| Issue date: | 04/30/1980 |
| From: | PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA |
| To: | |
| Shared Package | |
| ML20132B505 | List:
|
| References | |
| FOIA-84-293 CC-ME-01-MH, CC-ME-1-MH, NUDOCS 8508150473 | |
| Download: ML20134A940 (91) | |
Text
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/Z/ f2 ?f? Y 1 Prepared by Date R. J. Suslick, l Project Manager PbusWE Approved by i/rhr Date P. L. Wattelet, Mechanical Project Engineer j
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- C. M. Chiappetta, Senior Electrical Project Engineer AM@ l0 W
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Date G. A. Chauvin, Senior Structural Project Engineer l Auth'orized by Date R. J. Suslick, Project Manager ISSUE
SUMMARY
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r PUBLIC SERVICE INDIANA MARBLE RIII NUCLEAR GENERATING STATION UNITS 1& 2 PROJECT NO'S. 4808/4923 R Classification Criteria of Structures, Systems and Comoonents CC-ME-01-MH ISSUE
SUMMARY
(CCNT'D.) Reason Revision For Prepared Reviewed Approved Number Date Issue By 4.By Bv 2 6-13-75 For Use k.I. N ANS . - Pages 18thru o > .Y l e-- 16 are Rev.2 j-/6-/I" k'4 b8* i 0h' Y O.%n ( R0 vision Reason I 7 For Pages Prepared Reviewed Approved Number Date Issue Revised By Bv Bv 3 5-3-76 Add proj. 1,11,iii. [ [,(difE Q h_. - no.s titLet 1 g. 5 74 T-t4-74 ..=/j// w ' List pg*s. pg, j ,ff),Q _ _ g _g revised. (CAR-16) ggg g_g.75 g-4 Q%y Ss -7t* pn.,1c. . i 4 8-11-76 Update 4 , 6 , 9, ~2;t, WMf (( 8'Wh [. for use 10,12,13, F/as/7' 15,16 C,% r_ h, " --. g.y 7g q $dtLr rpin i4 Cam 1rl h 6 11 of 111 i
, CC-ME-01-ME Rsvision 3 May 3, 1976 i R' PUBLIC SERVICE INDIANA MARBLE HILL NUCLEAR GENERATING STATION
, UNITS 1&2 PROJECT NO'S. 4808/4923 Classification Criteria of Structures, Systems and comoonents CC-ME-01-MM J
TABLE OF CCNTwis t Pace 1.0 SCOPE 1 I i
2.0 REFERENCES
1 3.0 DEFINITIONS 1-2 4.0 FUNCTIONAL REQUIREMENTS 3 5.0 DESIGN REQUIREMENTS 3-4 6.0 SAFETY CLASSIFICATION 4 7.0 TABLES 4
- 1. Relation Between Quality Group 5 and Safety Cat. Classifications
! 2. Safety Category and Quality 6-16 Group Classifications for Structures and Components i . 4
- 3. Code Requirements for Components 17 '
l and Systems l
; 4. Cross Reference From Westing- 18
{ house RE3AR (ANS) Syatem of j ! Safety classification to Marble Hill Safety Classification System ' I i l ( i 111 of 111 e
.. , \
CC-ME-01-MH l ReviDion 3 May 3, 1976 r Rl CLASSIFICATION CRITERIA OF STRUCTURES, SYSTEMS AND COMPONENTS 1.0 SCOPE - The purpose of this Criteria is to establish the scheme by which structures, systems and components are classified in relation to their importance to safety. This criteria also sets the general classi-fication of the major structures, systems and components and.is to be used as the basis for establishing the more detailed classification required in project documents such as Design Criteria, l PSAR. Equipment, Valve and Piping Lists and Cable Tabulation.. ,
2.0 REFERENCES
2.1 Appendix A, 10 CFR 50 2.2 Regulatory Guide 1.29 2.3 Appendix B,,10 CFR 50 2.4 Regulatory Guide 1.26 2.5 Byron /Braidwdod PSAR, Chapter 3 ' i 2.6 Regulatory Guide 1.32 (Augus t, 1972) and IEEE standard 308-1971 2.7 RESAR, Chapter 3 I ( 2.8 DC-RN-01-ME, Design Criteria for Replication 3.0 DEFINITIONS l .. 3.1 Safety classification - Structures, systems and components
~ are classified;for design purposes as either Safety
' Category I or Safety Category II. Systems and Components
- are further classified by the appropriate Quality Group
' (See 3.4 below) or Class 12 designation (See 3.5 below)'
as applicable. The safety classification of Duplicate Features is identical to that of the Base Plant as defined in Reference 2.8. 3.2 Safety Catecorv I structures, systems, and components are those necessarf to assures (a) the integrity of the reactor coolant pressure boundary, (b) the capability i to shut down the reactor and maintain it in a safe i shutdown condition, or (c) the capability to prevent or mitigate the consequences of accidents which could result in potential off-site exposures comparable to the guideline exposures of 10 CFR 100, in the postulated ! _( events of the safe shutdown earthquake (SSE) and other design basis events including tornado, probable maximum flood, operating basis earthquake (OBE), missile impact, l or accident intainal to the plant. l \ Page 1 of la e
cc-ME-01-MM Rsvicion 2 Juno 13, 1975 f~ 3.3 Safety categorv II - Those structures, systems, and components which are not designated as safety category I are designated as Safety category II. This category has l no public health or safety implication. 3.4 Quality Group classification - The quality group 4 classification system defined in Regulatory Guide 1.26 ,
- (Ref. 2.4), established for water, steam, or radioactive !
material - containing components important to safety, is i directly applicable. 3.5 class 1E - Electric Systems - The systems that provide the electric power used to shut down the reactor and , limit the release of radioactive material following a design basis event. 3.6 Sinctle Failure - A single failure is an occurrence which results in the loss of capability of a component to perform its intended safety functions when called upon. Multiple failures resulting from a single occurrence are considered to be a single failure. Fluid and electrical systems are considered to be designed against ( an assumed single failure if neither (1) a single failure of any active component (assuming passive components function properly): nor (2) a single failure of a passive component (assuming active components function properly) results in a loss of the safety function to the nuclear steam electric generating unit. 3.7 Active Failure - An active failure is the failure of a powered component such as a piece of mechanical equipment, component of the electrical supply system or instrumentation and control equipment to act on consnand to perform its design function. (Ref. 2.7) 3.8 Passive Failure - A passive failure is the structural failure of a static component which limits the component's effectiveness in carrying out its design function. (Ref. 2.7) 3.9 Desien Basis Event - A design basis event is a natural phenomenon or failure of a r,Mem, component or structure I which is postulated to prs %Cs the basis for designing the safety-related asptf', of .he plant. Examples are safe shutdown earthquak+ (sh , wind and tornadoes, probable maximum flood, missiles and loss of coolant ( accident (LOCA) . J i l Page 2 of 18 a
CC-ME-Ol-MEI
- Rnvision 2
*. Juno 13, 1975 4.0 FUNCTIONAL REQUIREMENTS 4.1 Safety Category I structures, systems and components l
shall perform their intended safety functions in the event of the safe shutdown earthquake (SSE) and other design basis events. 4.2 Safety Category I structures, systems and components shall retain their own integrity and/or shall not constitute a hazard to other Safety Categorf I structures, systems or components during the safe shutdown earthquake and other design basis events. 1 4.3 Safety Category I systems and components shall perform their intended safety functions assuming a single failure and loss of off-site power. 4.4 The plant design shall ensure that safety Category II structures, systems or components do not constitute a hazard to Safety Category I structures, systems or components during the safe shutdown earthquake and other design basis events. ( 5.0 DESIGN REQUIREMENTS 5.1 Safety Category I systems and components shall no t be located in Safety Category II etructures. 5.2 Systems or portions of systems which are designated
- Safety Category I shall be identified as appropriate in the various design documents associated with that system.
5.3 The division between Safety Category I and II portions of systems shall be in accordance with the intent of Regulatory Guide 1.29. The seismic design of Safety Categorf I items is in accordance with the requirements of Regulatorf Guide 1.29. i 5.4 Quality Assurance Requirements for Safety Categorf I systems or portions of systems and components shall l meet the requirements of Appendix B to 10 CFR 50. ( Page 3 of 18
cc-ME-01-ME R0vicion 4 August 11, 1976 I 5.! Safety Category II structures, systems and components need not be specifically designed for dynamic operating-basis-earthquake loadings ; however, a reasonable margin of safety shall be considered in the design as dictated by local requirements, such as the Uniform Building code. 5.6 Safety category II systems or portions of systems and components need not follow the requirements of Appendix B to 10 CFR 50; however, the Quality Assurance standards for these systems and components shall follow normal industrial standards and any other requirements deemed necessary by the owner. 6.0 SAFETY CLASSIFICATION 6.1 Table 1 indicates the overall correspondence between safety categories and Quality Groups and the general j boundaries of systems to be considered part of each
! quality group.
6.2 Table 2 lists all major plant structures and components , which shall be designated as Safety category I and ( their respective Quality Group / Electrical classifications. Table 2 also lists the major plant structures and several l components which shall be designated as Safety category II. The safety classification of all piping, valves and in-strumentation within each system in Table 2 is not feasible R within this classification criteria document. The Scope section of this document references sources containing detailed classifications of piping, valves and instru-mentation. 6.3 Table 3 identifies the applicable codes and standards to be used for each quality group. ; 6.4 Table 4 gives a cross-reference which can be used to translate from the Westinghouse (RESAR or ANS) safety ! classification system tioo the classification system established in this document when utilizing more detailed Westinghouse documents such as the NSSS Systems Standard Design criteria. 7.0 UELES ( l Page 4 of la
=
l
CC-ME-01-ME Revision 2 June 13, 1975 TABLE 1. Relation Between Quality Groue and Safety Categorv classifications GUALITY GROUP SAFTTY CATEGORY GENERAL SYSTEM DESCRIP"'!ON A I Reactor coolant pressure boundary and extensions thereof B I Emergency core cooling, post-LCCA heat removal and cleanup, safe reactor shutdown and heat removal, portions of main steam and feedwater associated with containment isolation C I Systems required to support those in Quality Group B, spent fuel cooling, radioactive ( waste systems which normally contain a high level of radio-active material C II Parts or portions of systems which contain or may contain radioactive material, which have been upgraded to Quality Group C to meet NRC requirements- , o . D II Parts or portions of systems which contain or may contain radioactive material
?
l ( i Page 5 of 13 i
' A CC-ME-01-ME I *
. Revision 4
*s August 11, 1976 r TABLE 2_
l SArr.,fi CLASSIFICATION OF STRUCTURES, i
- sTrrr -is AND CCMPONr.m J QUALITY GROUP SAFETY or CATEGORY
*12CTRICAL CLASS-COMPONENT
_ Reactor Coolant System _ I A Reactor Vessel I Steam Generator A I Tube Side B Rl Shell Side I A Reactor Coolant Loop Stop Valves I A Pressurizer II D Pressurizer Relief Tank I A Reactor Coolant Pumps _ _ II Rl Motors . . . Ch =4 cal And Vol m contre,1 System , l B I
- Regenerative Heat Exchangers i Letdown Heat Exchangers B I Tube Side .
C I f Shell Side i Seal Water Heat Exchangers B I Tube Side I ' C Shell Side Excess Letdown Heat Exchangers . B I Tube Side C I / l Shell Side I l B t ' Volume Control Tank B I i ' Reciprocating Charging Pumps I B Centrifugal Charging Pumpe C
- I l Mixed Bed Domineralizers Page 6 of 18 e, l .- - - - _ . _ _ _ _ _ . _ _ . . - ~ . ..--.__ -- . _ _ _ _ - . . . . _ _ _ _ _ _ _ _ .- , . . _ _ _ _ . . - - - - - - - _ , . . . , - - _ _ . _ . _ . . . - . . , _ . _ . - _ _ _ _ , . - -
CC-ME-01-MH R vicion 2 June 13, 1975 r s TABLE 2 (Ccrt tinued) QUALITY GROUP or SAFETY ELECTRICAL CLASS CATEGORY COMPCNENT C I Cation Bed Demineralizers D II Resin Fill Tank D II Chemical Mixing Tank Moderating Heat Exchanger I C Tube Side I Shell Side C Letdown Chiller Heat Exchanger C I Tube Side II Shell Side D ( Chiller Pumps D II D II Chiller Surge Tank Letdown Reheat Heat Exchanger B I Tube Side C I Shell Side I Thermal Regeneration Domineralizers C C I Boric Acid Tanks , Boric Acid Batching Tank D II J C I Boric Acid Transfer Pumps I Reactor Coolant Filter B B I Seal Water Injection Filter B I Seal Water Return Filter C I
> Boric Acid Filter k I Boric Acid Blender C i
I Page 7 of 18 _-----_..-_.----.--..--.,--~..--.,.----.----r -. - . - . - - . - - . . -
CC-ME-01-MH 6- Revicion 2 June 13, 1975 TABLE 2 (Con tinued)
- QUALITY GROUP or SAFETY I
COMPCNENT ELECTRICAL CLASS CATEGORY Boron Reevele System Recycle Evaporator Feed Domineralizers C I Recycle Hold-Up Tanks C I Recycle Evaporator Feed Pumps C I Recycle Evaporator C* I Recycle Monitor Tanks D II
~'
Monitor Tank Pumps D II Recycle Evaporator Condensate Domineralizar D II { Recycle Evaporator Feed Filter C I Recycle Evaporator Concentrates Filter D II Recycle Evaporator Condensate Filter D II Reactor Makeup Water Storage Tank D II** Safety Iniection System i Refueling Water Storage Tank B I Accumulators B I Boron Injection Tank 8 I Safety Injection Pumps 3 g Boron Injection Surge Tank C I Boron Injection Recirculation Pumps C I i l ' The steam side of the evaporator is Quality Group D. Only
" hose portions containing radioactive liquid are designated I-c.
Msigned to Safety Category I seismic requirements. ! % ,. o 4 io s
- . . , . . , . - , . , . . - - . , , . . , - . . . _ . , ~,, -, ,. , , . , , , . , - . . ,-. , . , , , , , . , . , . . - - . . . , . - - . . , _
CC-ME-01-MH r Revision 4 ( August 11, 1976 TABLE 2 (Continued) QUALITY GROUP or SAFETY , COMPCNENT ELECTRICAL CLASS CATEGORY Residual Heat Removal System Residual Heat Removal Pumpa B ! I Residual Heat Exchangers Tube Side B 1 Shell Side C I I Containment Sorav System J Containment Spray Pumps 3 I , Spray Additive Tanks B I .i Spray Eductors 3 I ( Commonent Coolina Syst== 4 I Component Cooling Heat Exchangers C I Component Cooling Pumps C I Component Cooling Surge Ta.Jcs C I I Essential Service Water System Essential Service Water Pumps
- C I
- , Essential Service Water Strainers C I
- R j Spent Fuel Pit Cooline System i
i Spent Fuel Pit Heat Exchanger C 1 I l Spent Fuel Pit Pump C I ( '- I Skimmer Pump o gg Spent Fuel Pit Filter o gy Pace 9 of 18 '
CC-ME-01-ME t Revision 4 August 11, 1976 TABLE 2 (Continued) OUALITY GROUP or SAFETY COttPCNENT ELECTRICAL CLASS CATEGORY Scent Fuel Pit Cooling System (Continued) Spent Fuel Pit Domineralizer D II 1 Ref*,.teling Water Purification Pump C I R} Motor - II , Reactor Coolant Drain System i Reactor Coolant Drain Tank D II a Reactor Coolant Drain Pumps D II t i Gaseous Radwaste System Wasta Gas Compressor C I ( Gas Decay Tanks C I
~
Gas Analyzer C II Nuclear Samnling Svstem Sample Heat Exchanger Tube Side C I - Shell Side C I Auxiliary Feedwater System Auxiliarf Feedwater Pumps C I R l Auxiliar/ Feedwater Pump Diesels - I Diesel oil Svstem ! Diesel Oil Storage Tanks C I ) ! Diesel Oil Transfer Pumps C I ( Page 10 of 18 e
-.. . - - , - - - . . , . - - - - , - n. , . . - _ - - - , - , - - - . , - , _ _ - . - , - - - - - , , . , . . - - - , , , , , , . , - , - - -
CC-ME-01-ME Revision 2 June 13, 1975 TABLE 2 (Continued) QUALITY GROUP or SAFETY COMPCNENT ELECTRICAL CLASS CATEGORY Licuid Radwaste System Blowdown Condenser D II Blowdown Condenser Pump D II Blowdown Domineralizers
- D II Blowdown Profilters D II Blowdown Monitor Tanks D II Blowdown Monitor Tank Pumps D II Blowdown Evaporator D II l
( Auxiliary Building Floor and Equipment Drain Tanks D II Turbine Building Floor and Equipment Drain Tanks D II Spent Resin Storage Tank C I Liquid Radwaste Pumps D II Laundry Drain Tanks D II i Release Tank D II
. Liquid Radwaste Filters D II Radwaste Evaporator D II Waste Evaporator Monitor Tanks D II chemical Drain Tank D II i
( i i Page 11 of 18 R
' CC-ME-01-ME R;vicion 4 August 11, 1976 TABLE 2 (Continued)_
( QUALITY GROUP or SAFETY FTICTRICAL CIASS CATEGORY COMPCNENT Instmment Air System II Instrument Air Compressors ' .
- II Instrument Air Receivers
- II R Instrument Air Afterfilters
- II Instrument Air Dryers
- II Instrument Air Profilters Contalmment Ventilation and Purge System l
NA* I Reactor Containment ran Coolers Hydrogen Recombiners NA* I Control Room EVAC System .
- I Makeup, Supply and Return Fans and Motors R
C I Cooling coils
- I Filters .
Fire Protection System D II Centrifugal Pumps Piping TT Turbine Building D R Auxiliary Building Q
- Quality measures equivalent in intent to those in Quality 4 Group B will be applied.
** Quality measures equivalent in intent to those in Quality t
( Group C will be applied. i Page 12 of 18 .
.. CC-ME-01-ME R vicion 4 August 11, 1976 ~
TABLE 2 (Continued) QUALITY GROUP or SAFETY CCMcCNENT ELECTRICAL CLASS CATEGORY Main Steam and Feedwater Svstems Piping from Steam Generators Out to and Including First Stop Valves outside containment B I R Main Steam Safety Valves B I Main Steam Relief Valves B I Miscellaneous Components New Fuel Storage Racks NA** I Spent Fuel Storage Racks NA** I Containment Building Crane NA** I r-Fuel Handling Building Crane NA** I . l t l ** Quality measures equivalent in intent to those in Quality Group C will be applied. l Page 13 of 18
. CC-ME-01-MH Revicion 2
June 13, 1975 TABLE 2 (Continued)
QUALITY GROUP or SAFETY COMenylyt*y RLECTRICAL CLASS CATEGORY Eneineered Safety Features (ESP) Electrical Components 4160 V ESF Buses lE*** I 480 V ESF Buses lE*** I Diesel Generators, ESF lE*** I 125V d-c Buses, ESF lE*** I 125V d-c Batteries & Chargers, ESF lE*** I 120V a-c Instrumant Buses, ESF lE*** I 120V a-c Inverters, ESF lE*** I ( 480V a-c Motor Control Centers fed from 480 V ESF Buses lE*** I Electrical Penetrations 1E*** I Con *minment Cooling Fan Motors 12*** I Auxiliary Feedwater Pump Motors lE*** I Containment Spray Pump Motors lE*** I Essential Cooling Tower Fan Motors lE*** I cantrifugal Charging Pump Motors IE*** I Residual Heat Removal Pump Motors lE*** I Safaty Injection Pump Motors 1E*** I Essential Service Water Pump Motors 1E*** I
'- *** Electrical Class per IEEE-308 endorsed in RG-1.32.
Page 14 of 18 e 1
CC-ME-01-ME
% {
R0 vision 4 August 11, 1976 I TABLE 2 (Continued) i 1 QUALITY GROUP or SAFETY COMPONENTS ELECTRICAL CLASS CATEGORY i Encineered Safety Features (EST) Electrical Comocnents (Continued) Component Cooling Pump Motors 1E*** I Diesel Generator Room Fan Motors LE*** I Interconnecting cables between Safety Category I Electrical Equipment 13*** I Non-ESF Electrical Systems and Components -- II ! STRUCTURES 1 Solid Radwaste Storage Building E II I l ( Service Building MA
, II i
Essential Service Cooling Towers & Basins NA I circulating water Cooling Towers R II 4
,R Circulating Water Pumphouses NA II
- Main Steam Tunnels NA I Auxiliary Feedwater Tunnels MA
- I
, River Pumphouse NA II l R Reactor Containment Structures NA I 1 Auxiliary Building NA I I Fuel Handling Building NA I l ( Turbine Building NA II i Ilecurical Class per IZEE-308 endorsed in RG-1.32. I Page 15 of 18 . e
. - _ , . _ _ _ _ , . , , .,.__ ,,_._. ,_ , - _ _ . , ..,.r._._,, -
CC-ME-01-ME Revicion 4 August 11, 1976 TABLE 2 (Con tinued) QUALITY GROUP or SAFETY S.CMPCNENTS ELECTRICAL CLASS CATEGCRY Blowdown DischarJe Structure NA II Switchyard Structures NA II R Water Well Structures NA II All Site Development Civil Works NA II t C k Page 16 of 18
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hi- *= - - 5%+ J [ O ' 1, , 4 Tsett 3 4 Cett ^ - 7 NR L. - Ti asse St81tast I epellfy coeur I Casecutut 98SDTM MII IIII SII I 45ss telles and psessere I AS E telles and pseasese assa telles and heseuse pseseuse Deseele Aas telles and heseere to wel Code, sestles til . gewel Code. Suties 9888 i' gueel Cede. Sestles Ill . Weasel Cede. Su ttee til . Div. 1 1994 - 8934. Claes 3 1974. Class 3 1974. Close 4 u e .see.ese ..s. . es .e4 es.. se . .l .l.. . it,,, Code g ..,te. ..s. .les .e4 se. se vueel Code, Sestlee llt . Weseet Cede. Sestles Ill - teseet Code. Su ties til . 8974, Close 3 fes Ps u eese tiples I ag 3914. Close 1 1974. Close 3 else telles and Prosesse am5t 838.8.4 1973NI sCode Aast telles med hosesse & asst telles and Pseeemse fes Pressese FBplog Fa t a pe end valves , Vessel Cede. Seattee Ill . 4 peoul Code, Sestles til = teeeel Code, tuttee Ill = 1974. Close 3 8974. Claes 3 ~ 1974. Clase 1 . O & asst toiles and prosesse aise telles and Prosesse meestsee potselees testitete, N Cee-heseuse Teeke Weseel Code, Sestlee llt =
' Dessel Code, Sestles til . B u ess.eeded soles los ese.lge ed 1 and it 4. Ciese it .. Clos. 3 C.eeteou le. of C.s e Presomse Stosage Teoke, att ele, l
. .6973 ediales
.i - 48s$ Belles med heesses &&ssE 9elles and Psosesse Amesigen Waleswerbe Asseslettee. j eneeophesle $tesege Wessel Code. Su ttee til . Stendsed fu Steel Teoks. Stande spes, Tee 6 e Doesel Code. Sestles ill . S uesvolse and Elevatsa teeAs les 1974. Clase 3 8974, Claes 3 ,q Wetes Stesege. AtAeA-6400,197 8 settleeg es Wolded Steel Tests les Olt $tes*4e. API-4M. 8913 eettleages Amit 994.8 4 3933 edittee tes eluele m teste Ases telles and hoseere Aass telles med Pressere A5ss telles and Pressese Wessel Cede. Ineet Bubeagere adus Seites and hoessee 5estlee TRII. Div. l . 19743 and Tebelos 9essel Cede. Gestles Ill . vespel Code. Bestles 888 - seeeel Code. Sesttee til - 8914. Claes 3 sub.eges snee.f usesess asenleesee 1974. Claea 8 8974, close 3 ! (itasal Close C C4 *)2 ( .
. g: e (i (t) Centelement e ee.1 outoded D4 l' O >** U i (3) Pos pumpe apeselleg ebeve lle pet and all*f 43ss Sest.les Witt 68v 8.
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cc-M.E-u a-Mti T vision 2 Juno 13, 1975 ( TABLE 4 CROSS REFERENCE FROM WESTINGHOUSE RESAR (ANS) SYSTEM CF SAFETY CLASSIFICATION TO MARSLE HILI, SAFETY CLASSIFICATION SYSTEM
- 1 t
i WESTINGHOUSE MARBLE FUL RESAR-3 (ANS) QUALITY GROUP SAFETY CATEGORY l A I i 2 B I 3 C I i i NES D - II i )
- The following exceptions to the above cross-reference are notedt in these cases the Marble Hill Safety classification is to be used: Refueling Water Purification Pump, Spray Additive Tanks, Excess Letdown Heat Exchangers - Shell Side.
1 i i I l k Page 13 of 18 e I
QrsfT {jfd> hl)3Y~ I r 4 hotes from Marble Hill Case Study 'P II. A. What Happened at Marble Hill In April 1978, NRC issued to PSI construction permits for the con-struction of two 1150 Mw Westinghouse four loop PWRs at the Marble Hill site near New Washington, Indiana. PSI had announced construc-tion of the units in November 1973 and applied for a CP in July 1975. A limited work authorization was granted in 1977, and PSI acted as general contractor for the project, which was the first nuclear project undertaken by the utility. Sargent and Lundy was retained as architect / engineer. The Newberg Construction Company, which had participated in the construction of a number of fossil-fired plants for PSI in the past, was retained as the civil contractor for the Marble Hill Nuclear Station. Subsequent paragraphs describe the problems of quality in construction that developed at Marble Hill. This material is excerpted from testimony delivered by J. J. Harrison, NRC Senior Resident Inspector at Marble Hill, to Congressional aides i in February of 1982. PHA M3 K ls/6
c, l NRC inspections of concrete work underway in April and May, 1979, identified deficiencies in the control of quality during concrete placement at Marble Hill. In a meeting with Region III on May 15, Public Service of Indiana (PSI) agreed to upgrade its quality assurance program for the concrete work and to determine through testing if previously poured concrete was adequate. In June a former site employee alleged that surface defects in the concrete had been improperly patched, and in July the National Board of Boiler and Pressure Vessel Inspectors identified code-compliance problems with piping installation. Concrete work was halted June 26 at the request of Region III; then briefly resumed in July before all safety-related construction work was halted August 7,1979, by PSI after NRC inspectors determined there was significant questions concerning PSI's quality assurance program and its con-struction management. These findings were based on NRC inspections of concrete placement, repairs and testing procedures, on the con-firmation of allegations by construction workers at the site, and on the finding of the National Board of Boiler and Pressure Vessel Inspectors. A confirmation order was issued by the NRC staff on August 15, 1979. A full time NRC Resident Inspector was assigned to Marble Hill on December 3,1979. After numerous meetings with the NRC, PSI submitted on February 28, 1980, its formal reply to the order, detailing its effort to upgrade and implement its revised QA program. One month later, on March 25, 1980, a public meeting on the proposed corrective action was held by the NRC before some 500 local residents in Madison, Indiana. To assure that PSI's corrective actions were properly and effectively implemented, the Commission approved a five-step plan for gradual recission of the order. The five stages would be subject to intensive reviews by NRC inspectors with an NRC " hold point" at each stage before the next could be undertaken. Additionally, there were intermediate " hold points" within each stage.
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\
l l The plan covered: (1) Revised Quality Assurance Program; (2) Receipt Inspections; (3) Material Verification Program; (4) Construction Verification Program; (5) Resumption of Constuction. One major concern of the NRC's was the apparent low rumber of qualified QA and management personnel at the site. This concern was addressed by the licensee with an accelerated hiring and training program and a shifting of personnel to the plant site. Currently the entire Nuclear Division is at the site. Two independent outside consultants were also retained by ' the NRC to provide an independent' analysis of the concrete work, which had been requested by Save-the-Valley a Madison, Indiana, public interest group. A third engineer, repre-senting Save-the-Valley accompanied the NRC consultants during their review at the site. After PSI restructured its QA and Construction Management Programs, it was pemitted on July 7,1980, to resume receipt inspections of materials at the construction site, ' and later contractors were also permitted to undertake receipt inspections. , On December 5,1980, the NRC pemitted limited electrical work and pipe installation to resume by Cherne Contracting Co., the piping contractor, and Commonwealth Lord, the electrical contractor. Then on March 27, 1981, PSI was authorifed to resume all remaining safety-related work, including concrete placement. Unrestricted authority to continue the work would not be granted until the utility successfully demonstrated that its quality assurance and construction management programs were implemented properly. The additional work authorizatrion included concrete repair and placement, structural steel installation and protective coatings. In addition to new concrete work, PSI contractors began removing and replacing all patches previously made to repair surface defects in the concrete, about 6,400. As of February 13, 1982, the patching program is about 82 percent ' completed. An NRC review of tests and examinations concluded that the exishng in-place concrete work was structurally sound. ' This determination was based, among other things, on tests performed by PSI contractors and observed by NRC personnel.
) 1, The NRC's independent consultants also concluded that
, the quality of the concrete at Marble Hill was acceptable.
B. Marble Hill Today ! d . In an October 26, 1981 inspection report on Marble Hill, Region III inspectors stated in item 12, " Summary Findings j lof This Special Inspection: It is Region III's conclusion that PSI has adequately implemented its commitments made , in response to the August 15, 1979, Order Conforming Sus- , pension of Construction and the related conventions and
! agreements in accordance with the NRC's document entitled .
I Graduated Recission of Order August 15, 1979." l On February 12, 1982, following a site visit by NRC manage- : ment, the ' Confirming Order" was lifted, thus enabling , construction to continue with no restrictions. i Note: Region III has rated the Marble Hill 0A program " outstanding" l in the last two SALP reports. I f 1 , III. Root Causes of Marble Hill's Problems with Quality in Construction t Based on our review o,f NRC and other documentation regarding the Marble Hill case and our discussions with cognizant NRC, licensee, and contractors j staff, the following appear to be the primary and secondary root causes of i ; j the quality problems that manifested themselves in 1979 and led to the ' j cessation of safety-related work at the project. 4 i l
- A. Primary Root Cause t
i ! The primary root cause of PSI's problems at Marble Hill was their ! 1 lack of experience in building a nuclear project. They simply did ! j not understand or fully appreciate the several quantum jumps of I ! complexity difference between building fossil plants and building , l i l t
., __ . .__._ _...-_._,__,.--- -,.. _._,-._, , . . _ . . _ . . . _ ~ . , _ _ , . _ . , . . _ . _ _ . , . _ , . ._ ., _ _,. _ _.,_., _ ,,..._ _.,__ _ . , ,.
nuclear plants. Their experience in building fossil plants had been quite positive: they had built nearly a score of successful fossil plants in the past thirty years, generally completing the projects on schedule (orbefore)andwithinbudget. This led to the development of a mind set sometimes referred to as a " fossil mentality" - the feeling that building a nuclear plant could not be ruch more difficult than building a fossil plant, the main difference being in how' the steam was generated. Their inexperience with nuclear projects, their failure to appreciate the legal and engineering complexity of a nuclear project, and their overall fossil-oriented outlook manifested itself in the manner in which they addressed the project, resulting in several managerial errors which ultimately led to the stoppage of safety-related work. Primary among these errors was a failure to staff the nuclear project adequately with sufficient personnel having applicable nuclear-related experience. They did staff a few key positions with personnel who had good nuclear credentials, but their procurement of personnel with - appropriate nuclear experience was of neither sufficient breadth nor depth to provide reasonable assurance of success. Another error lay in their understanding, or perhaps misunderstanding, of NRC and its role in the licensing and oversight of nuclear con-struction projects. With their strictly fossil background, they tended to view NRC as another government agency with another set of regulatory hurdles to engage and complete, much like an EPA or an
OSHA. This lack of understanding of NRC contributed in part to their failure to recognize the extent of their problems earlier than they did - they heard what NRC said but they were not really listening (NRC is not above reproach either as will be described later). I Another management error on PSI's part was their over reliance on contractors. They tended to view their contractors as the experts in the areas in which they were working and generally not to question their activities. Moreover, they turned over defacto management cf the project to their contractors. (More about this later.) Similar to their lack of understanding of the importance of NRC and its rules, was a lack of understanding of the importance of various ASME and other codes. This misunderstanding caused them to be 51% to recognize the importance or significance of the July 1979 findings of the National Board of Boiler and Pressure Vessel Inspectors referred to in the excerpt from Mr. Harrison's testimony. Finally, their inexperience (and over reliance on contractors)
- resulted in their not recognizing or being able to recognize that the symptoms of construction quality problems they saw with the honeycombing of the concrete and improper patching were indications of a much deep' tie'r underlying mailiase in their entire program of project and '
quality management. In short, they saw the symptoms but did not understand nearly how much deeper the underlying causes ran.
i 1 B. Secondary Root Causes l ! Based on our reading, discussions, and analysis, we have identified 4 four secondary root causes of the construction problems experienced at Marble Hill in 1979. They are: 1
- 1. lack of understanding of the potential merit of a formal program fnr quality, '
J
- 2. development of a false sense of security by PSI, l
- 3. failure of PSI to manage the Marble Hill project from the 9
outset, and 4 NRC licensing, inspection, and enforcement practices. 4 l We will explain each of these in more detail. l i 1. Lack of understanding of the potential merit of a formal program for quality. As indicated above, PSI has a history of completing successful fossil projects on time and within budget. PSI viewed quality j in such a project as something that just gets built in - it comes naturally as the result of good management and an able, i knowledgeable, and dedicated staff. Everyone from the top down 4 b _ _ . ._--____,_.c.. _ _ - . . . ~ , _ - _ . _ . _ , _ . , _ _ - _ _ . . - - , _ _ _ _ , _ , . . _ . - _ , - , , , ~ _ _ _, _ _ , _ . r__.-,__.
knows what it takes to build a successful fossil plant, and they all work together to ensure that the overall project and final project works and is safe. PSI viewed their success record as the result of teamwork and dedicated personnel. It was a record w.n v established without the help of, or need for, a formal organi-a zation until they decided to build a nuclear plant, and they then established such an organization not because they believed they needed one, but because NRC's 10 CFR 50 Appendix B required one. Moreover, NRC required that the head of this required quality organization report to the highest levels of utility management. This organization also has the authority to audit the activities of many of the other utility managers who report in at very high levels. Given the situation that (a) PSI did not believe it needed a quality assurance organization to obtain quality in power plant construction, (b) NRC mandated such an organization for nuclear work and (c) the new quality organization not only was vested with certain broad powers but neither it (nor its head) had paid their corporate dues in obtaining these powers, the new quality assurance organization a't PSI was greeted with a lack of enthusiasm, a lack of management support, and even a mistrust. Region !!!'s 1979 investigaiton produced internal PSI documentation which showed that PSI executives were cold to i the idea of hiring very many people for the quality assurance organization, fearing the development of a quality assurance
" empire."
PSI management mistrust of and lack of enthusiasm for the mandated quality assurance organization resulted in a lack of adequate authority or staff (either in size or qualifications) ! for the quality assurance organization (see Region III report 79-11 on Marble Hill for a more complete discussion of this point).
- 2. Development of a false sense of security by PSI.
i
! This secondary root cause is somewhat related to the primary i ; root cause, inexperience. NRC's region based inspectors found numerous problems at the Marble Hill site throughout 1978 and i
j 1979, but until right before the August 1979 stoppage of work, 1 1 PSI (and NRC) did not recognize the full extent of the problems. 1 ] One PSI staff member (quality assurance) who was there at the 1 * { time of the problems put it this way (paraphrased): "NRC came I in and they found a few things wrong, but that's their job. They i l didn't communicate to us that we had any really serious problems. Since we viewed them as the experts, we felt that we probably j didn't have any major problems." This opinion was corroborated by others involved at the time, including very senior PSI manage-ment. 1 ] i Heavy reliance on contractors also caused PS! to develop a false i , sense of security. Here, too, PSI felt that the contractors were the experts and that'if anything went wrong, the contractors 1 would address it. i I
Another contributor to PSI's false sense of security is the fact that Harble Hill is a replicate of the Byron plant, which is being built for Comonwealth Edison. PSI made extensive use of design and licensing documents prepared for Byron, and PSI felt that most major problems in construction would surface at Byron first and the Marble Hill project could be reprogrammed to take advantage of the Byron experience.
- 3. Failure of PSI (or someone) to manage the Marble Hill project from the outset.
This secondary root cause overlaps the primary root cause, inexperience, but it is of such fundamental importance that it should be highlighted as a root cause in its own right. Perhaps PSI did not effectively take control of the Marble Hill project from the outset because they know they had no prior nuclear project experience, and so they would rely more heavily on contractors than was their normal mode of operation. In any event, PSI, acting as the project's general contractor, did re-linquish too much of the day-to-day management of the project to surrogates, they failed to establish an 8 effective project management presence at the construction site (they tried to manage in a natrix arrangement from corporate headquarters), and they diluted accountability within the corporation for y project responsibility. All of these failure-to-manage factors-
i i ^ { (plus over reliance on replication) contributed to the con- i l struction problems that led to the 1979 shutdown. ; I
- 4. NRC licensing, inspection, and enforcement practices.
i i
- NRC's licensing review for a construction permit is largely limited to technical issues and conformance with 10 CFR 50.
I Although NRC does review an applicant's financial position, NRC does not (and did not in the case of Marble Hill) perform a i t formal review of the applicant's ability to manage, and carry j through to completion, the construction of a nuclear reactor. l t I l NRC's inspection progran for the Marble Hill project consisted j of a series of visits by regional based (Chicago) inspectors. A
< i resident inspector was not assigned to the site until December 1979. During our visit to Marble Hill, PSI's president (and other PSI officials) expressed the view that a constant NRC l presence in the form of a resident inspector is most critical
- from the very beginning of construction. They felt that occasional visits by a series of regional inspectors would not provide any of them individuality or NRC with the comprehensive feel for or comand of a project that a resident would obtain. Mo reover,
'they felt that bad practices developed during the early stages of construction carry over into later work and the time to catch j these practices and correct them is at the beginning. Waiting
- until the project is 15% complete can permit poor practices to i
. - _ _ _ . _ _ . - __ .. _ , _ _ . . _ . . __ . . . . _ . . ~ , . . _ , _ - . . . - . _ _ _ _-_
+ci r,u become accepted and ingrained and much harder to farm around.
They said they thought assignment of a resident to Marble Hill from day one of construction would have been great help in recognizing Marble Hill's problems earlier and before they became as extensive as they were. Finally, the enforcement signals sent to PSI by NRC were confusing to PSI. On the one hand, NRC was late to recognize the extent of the problem. This helped reinforce PSI's false sense of security. On the other hand, when NRC did recognize or suspect the extent of the problems, PSI was late to understand the significance of NRC's new, stronger message. 9
MARBLE HILL PROJECT QUALITY ASSURAt1CE MANUAL _ g,,, g
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- FAILURE TO COMMUNICATE MANAGEMENT COMMITMENT DOWNWARD
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- ORGANIZATION STRUCTURE AND GE0 GRAPHICAL LAYOUT T00 COMPLEX
- FAILURE TO IDENTIFY TRENDS REQUIRING CORRECTIVE ACTION EA Ts a
v i
POSTULATED ROOT CAUSES AND SYMPT 0MS (CONTINUED) NO CONFIDENCE IN QA/0C AS A CONTRIBUTOR TO PROJECT MANAGEMENT LACK OF UNDERSTANDING OF QA/0C PHILOSOPHY QA/0C LOOKED UPON AS A NECESSARY EVIL (D0ING MINIMUM T0 i GET BY) UNRESPONSIVENESS TO REQUESTS FOR STAFFING AND CORRECTIVE ACTION FAILURE TO RECOGNIZE NEED FOR QA/0C PROGRAM ' 5 l l f
! $a e
POSTULATED ROOT CAUSES AND SYMPTOMS (CONTINUED) II. INADEQUATE FRONT END DEMONSTRATION BY UTILITY OF ABILITY TO MANAGE A NUCLEAR PROJECT I INADEQUATE SELF-ASSESSMENT OF CAPABILITY FAILURE OF NRC TO PROPERLY ASSESS UTILITY'S NUCLEAR PROJECT CAPABILITY
= ._
POSTULATED ROOT CAUSES AND SYMPTOMS (CONTINUED) III. LACK OF UNDERSTANDING 0F COMPLEXITY AND MAGNITUDE OF A NUCLEAR PROJECT INSUFFICIENT NUMBERS OF QUALIFIED PEOPLE AND WEAK QUALIFICATIONS COST AND SCHEDULING EFFORTS INADEQUATE TO GET REALISTIC PICTURE
- LACK 0F UNDERSTANDING 0F NUCLEAR CODES, STANDARDS, AND REGULATORY GUIDES HEAVY RELIANCE OR REPLICATION APPROACH 4
POSTULATED ROOT CAUSES AND SYMPT 0MS (c0NTINUED)
- FAILURE TO RECOGNIZE NEED FOR A COMPREHENSIVE AND INDEPTil TRAINING PROGRAM' -
- OVER RELIANCE ON SUBCONTRACTORS QA/0C PROGRAM INADEQUATE PROJECT MANAGEMENT MECHANISM FOR PLANNING
. CONTRACT WORK SUFFICIENT TO ALLOW FOR EFFECTIVE QA/QC WORK PACKAGES O
n .
~
POSTULATED ROOT CAUSES AND SYMPTOMS (CONTINUED) IV. CREDIBILITY AND COST EFFECTIVENESS OF GA NOT DEMONSTRATED
- EXCESSIVE CONTROLS ON QA
- STOP WORK AUTHORITY LIMITED
- LIMITED MANPOWER V. NO FRONT END DIRECTION GIVEN TO INEXPERIENCED UTILITIES BUILDING FIRST NUCLEAR PLANT (UTILITIES GET COMPLETELY IN TROUBLE BEFORE NEED FOR CORRECTIVE ACTION IS IDENTIFIED) 1
^' _ _ _ _ _ _
o
' l 7
MEMORANDUM FOR:
\
Terry L. Harpster, Chief, Quality Assurance Branch Division of Engineering and Quality Assurance, IE FROM: Willard D. tman, Project Manager, Special Study of Nuclear Qual ty Assurance
SUBJECT:
TRIP REPORT ON T E MARBLE HILL CASE STUDY During the week November 15-19, 1982, a team of consultants and I conducted a quality assurance case study of the Marb e ill construction project. On Monday November 15, we briefed interested embers of the Region III staff on our project and solicited their commen on our project and approach in general and about Marble Hill in particular. /We spen Tuesday through Friday at the site, interviewing members of the st'affs of PSI (Public Service of Indiana) and their contractors, and reviewing t eir project gnagement, construction,and quality assurance programs.. Enc osure 1 gives a da
/
for the team and includes list,ings of attendees fo\ y-by-the November 15 neeting with Region III and the November 16 and 19 entrance (and exit meetings, respectively, with PSI. Enclosure 2 consists of the\b riefing slides presented
/
at the meeting at the region and the entrance briefin\g with PSI.
' Enclosure 3 consists of the briefing slides I used for the exit meeting with PSI on November 19.
- At this point.individualteam members are reviewing their potes and preparing formefeederinfo/ 8 rmation that will be used as background and source infor-mation for our eneric reports to Congress and the Comission. While this Fora-t4-2A3
.m -
Klloo
~
~
. . , , v.
v information is being prepared and an lyzed, I thought it would be instructive i to share with you some preliminary lessons learned from the Marble Hill case study and what the information we have so far\ obtained on Marble Hill (from reports, investigations,RegionIII,the\r /ent, PSI executives and staff, PSI contractors, etc.) may portend for the/ rest of our study. These prelimi-nary thoughts and ideas form the basis for th exit briefing we have with FSI on November 19. Subsequent paragraphs will descr be what quality p' oblems have occurred at P.arble Hill, and where PSI is ,now in terms of thei quality program. We will then describe the root causes of their past quality roblems, how they turned
/
their program around, what generic implications their; experience may have, and
/
\
finally what effects NRC is QA initiatives and the Ford Amendment alternatives
\
would have had had they been in place at the time Marble Hill's quality problems surfaced. g y gg f,WhatHappenedatMarbleHill jg
~ ,A e,~
r-<(m & In April 1978, NRC issued to PSI construction permits for the construction of two 1150 Mw Westinghouse four loop PWRs at the Marble Hill site near New Washington, Indiana. PSI had announced construction of the units in November 1973 and applied for a CP in July 1975. A limited work authori-zation was granted in 1977, and PSI acted as general contractor
._ for the p'roject, wh'ich'was the first nuclear project undertaken by the utility. Sargent and Lundy was retained as architect / engineer. The Newberg Construction Company, whicn had participated in the construction i
4 e e
.- 3 of a number of fossil-fired power plants for PSI in the past, was retained as the civil contractor for the Marble Hill Nuclear Station. Subsequent paragraphs describe the problems of quality in construction that developed at Marble Hill. This material is excerpted from testimony delivered by J.
J. Harrison, NRC Senior Resident Inspector at Marble Hill, to Congressional aides in February of 1982.
.BeckgmEWtr"(
4Yf
; NRC inspections of concrete work underway in April and May,1979, identified deficiencies in the centrol of quality during concrete placement at Marble
/d Hill. In a meeting with Region III on May 15, Public Service of Indiana (PSI) agreed to upgrade its quality assurance program for the concrete work and to determine through testing if previously poured concrete was
, adequate.
/
I t f In June a former site employee alleged that surface' defects in the concrete l had been improperly patched, and in July the National Board of Boiler and Pressure Vessel Inspectors identified code-compliance problems with piping finstallation. l i Concrete work was halted June 26 at the request of Region III; then briefly resumed in July before all safety-related construction work was
~ '
halted August 7,19N,'by PSI after NRC inspectors determined there was
~
significant questions concerning PSI's quality assurance program and its construction management. . l l i j . . ~- **
- i W
F/fA These findings were based on NRC inspections of concrete placement, repairs and testing procedures, on the confirmation of allegations by construction workers at the site, and on the finding of the National Board of Boiler and Pressure Yessel Inspectors. A confirmation order was issued by the NRC staff on August 15, 1979. A full time NRC Resident Inspector was assigned to Marble Hill on December 3, 1979. After numerous meetings with the NRC, PSI submitted on February 28, 1980, its formal reply to the order, detailing its effort to upgrade and imple-ment its revised QA program. One month later, on March 25, 1980, a public meeting on the proposed corrective action was held by the NRC before some 500 local residents in Madison, In' diana. To assure that PSI's corrective actions were properly and effectively implemented, the Commission approved a five-step plan for gradual recission of the order. The five stages would be subject to intensive I reviews by NRC inspectors with an NRC " hold point" at each stage before the next could be undertaken. Additionally, there were intermediate " hold
- points" within each stage.
p." aq$y% The plan covered: (1) Revised Quality Assurance Program; (2) Receipt Inspections; (3) Material Verification Program; (4) Construction Verifi-cation Program; (5) Resumption of Constuction. One major concern of the NRC's was the apparent low number of qualified QA and management personnel at the site. This concern'was addressed by the licensee with an accelerated hiring and training program and a shifting of personnel to the plant site. Currently the entire Nuclear Division is at the site. Two independent outside consultants were also retained by the NRC to provide an independent analysis of the concrete work, which had been requested by Save-the-Valley a Madison, Indiana, public interest group. A third engineer, representing Save-the-Valley accompanied the NRC con-i sultants during their review at the site. I After PSI restructured its QA and Construction Management Programs, it was permitted on July 7,1980, to resume receipt inspections of materials at the construction site, and later contractors were also permitted to under-take receipt inspections. On December 5,1980, the NRC permitted limited electrical work and pipe installation.to resume by Cherne Contracting Co., the piping contractor, !. and Comm6nwealth L6rd,the electrical contractor. Then on March 27, 1981, PSI was authorized to resume all remaining safety-related work, including concrete placement. Unrestricted authority to continue the work would not l . . .. -- - l
., </;M}.u#
'be granted until the utility successfully demonstra'ted that its quality '
assurance and construction management programs were implemented properly. The additional work authorizatrion included concrete repair and placement, structural steel installation and protective coatings. In addition to new concrete work, PSI contractors began removing and replacing all patches
'previously made to repair surface defects in the concrete, about 6,400.
As of February 13, 1982, the patching program is about 82 percent completed. An NRC review of tests and examinations concluded that the exisitng i in-place concrete work was structurally sound. This determination was based, among other things, on tests performed by PSI contractors and observed by NRC personnel. The NRC's independent consultants also concluded that the quality of the concrete at Marble Hill was acceptable. ! Recent Statistical Issue
\
The Commisisoners recently declined, on January 6,1982, to review Director
\
Stello's Marc 27, 1981 order \ allowing [resumptionofsafet-related N/ concrete work a Marb e Hill. The equest had been made through a 2.206 l petition from Say - e-Valley, which claimed that the statistical metho-dology us~ed'to te \ l . int place concrete'was faulty. The NRC had approved a l \
- four-stage sequ tial testing plan to detennine the adequacy of in-place
\
concrete at Marde Hill. .The concrete had to meet the NRC's 95/95 criteria; A 4
4 i I that is, the NRC had to have 95 percent assurance that no nore than 5
\
j percent of the concrete was possibly ifefective. Save-the-Valley claimed the sequential plan, if carried through, would provide only a 90/95 assurance factor. The plan: if one defect was found ; ! in the first 59 areas tested, then the test would be expanded to 93 areas.
\
If another defect was found, the test ould be expanded to 124 areas, and i :
- finally to 153 areas if a third def twasfo\und. t j
l L.D.Y. Ong, of NRC's Office of olicy Evaluation . agreed with Save-the-Valley ,
- /
- stating that the sequential Jan umuld indeed only\ provide a 90/95 factor, ,
j i However, it was pointed out hat the whole argument was moot since no
/
defects were found in the/first 59 areas tested. As a result, there was
~
no need to go any further. Zero defects 1n the 59 areas equaled 95/95, ,
/
and thus met NRC requirements. I e i { d Marble Hill Today , i Y 1
}InanOctober26, 1981 inspection report on Marble Hill, Region III inspectors stated in item 12 "Sumary Findings of This Special Inspection:
- MN It is Region III's conclusion that PSI has adequately implemented its
- ad comitments made in response to the August-15,1979, Order Conforming
! ' /NO Suspension of Construction and the related conventions and agreements in A accordance with thf art's document entitled Graduated Recission of Order i ugust 15,1979." ( , 1 3 5 j . ,. . .
Y L'M* M0 >/h <<
-9
'On February 12, 1982, following a site visit by NRC management, the
" Confirming Order" was lifted, thus enabling construction to continue with (no restrictions.
p,,:.e . QL 5 % wid 4-W 1%I k SU $h pp m..) %h % * .: &cr k+ :t ML? + h-III. Rcot Causes of Marble Hill's Problems with Quality in Construction Based on our review of NRC and other documentation regarding the Marble Hill case and our discussions with cognizant NRC, licensee, and contractors staff, the following appear to be the primary and secondary root causes of the quality problems that manifested themselves in 1979 and led to the cessation of safety-related work at the project. A. Primary Root Cause The primary root cause of PSI's problems at Marble Hill was their lack of experience in building a nuclear project. They simply did not understand or fully appreciate the several quantum jumps of complexity difference.between building fossil plants and building nuclear plants. Their experience in building fossil plants had been quite positive: they had built nearly a score of successful fossil plants in the past thirty years, generally completing the projects on schedule (or before) and within budget. This led to the development u of a~ mind setionietimes referred to as a " fossil mentality" - the feeling that building a nuclear plant could not be much more difficult i
- -- 4
= , . . -. . - . - . ~ . . . . - - - - - _ - _ . - - - - . . - - _ - - - .
i 4
.- 7 l !
i than building a fossil plant, the main difference being in how the l steam was generated. ; l Their inexperience with nuclear projects, their failure to appreciate j the legal and engineering complexity of a nuclear project, and their l 4 overall fossil-oriented outlook manifested itself in the manner in which they addressed the project, resulting in several managerial ! ! errors which ultimately led to the stoppage of ' safety-related work. Primary among these errors was a failure to staff the nuclear project j adequately ith sufficient personnel having applicable nuclear-related / experience. They did staff a few key positions with personnel who j had good nuclear credentials, but their procurement of personnel with 1 appropriate nuclear experience was of neither sufficient breadth nor
- r l depth to provide reasonable assurance of success. ;
Another error lay in their understanding, or perhaps misunderstanding, i of HRC and its role in the licensing and oversight of nuclear con-
~
l i
- struction projects. With their strictly fossil background, they tended to view MRC as another government agency with another set of j regulatory hurdles to engage and complete, much like an EPA or an
- OSHA. This lack of understanding of NRC contributed in part to their
!' failure to recognize the extent of their problems earlier than they 1 ! did - they heard what NRC said but they were not really listening f= (NRd is not above' reproach either as will be described later). i l 9 3 en k
. , , _ , _ _ _ . . . . , . - - - ~ , . , ,..,_m..,. ,._ ._ - .- . _ . , ...-.,, - - y-
.e
/b Another management error on PSI's part was their over reliance on contractors. They tended to view their contractors as the experts in the areas in which they were working and generally not to question their activities. Moreover, they turned over defacto management of the project to their contractors. (Moreaboutthislater.)
Similar to their lack of understanding of the importance of NRC and its rules, was a lack of understanding of the importance of various ASME and other codes. This misunderstanding caused'them to be slow to recognize the importance or significanfof the July 1979 findings < of the National Board of Boiler and Pressure Vessel Inspectors referred to in the excerpt from Mr. Harrison's testimony. Finally, their inexperience (and over reliance on contractors) resulted in their not recognizing or being able to recognize that the o symptoms of constructin quality problems they saw with the honeycombing 1 of the concrete and improper patching were indications of a much deepter underlying mailiase in their entire program of project and qua Q management. In short, they saw the symptoms but did not 1 understand nearly how much deeper the underlying causes ran. B. Secondary Root Causes gwj n w <Ay cur,wh W
- _ We h' ave ident!Nied four6 con y root causes of the construction A
. problems experienced at Marble Hill in 1979. They are:
f :
~ -
il
- 1. lack of understanding of the potential merit of a .ormal program for quality, se
- 2. development of a false soucee of security by PSI, I
- 3. failure of PSI to manage the Marble Hill project from the i
outset, and l 4. NRC licensing, inspection, and enforcement practices. We will explain each of these in more detail.
- 1. Lack of understanding of the potential merit of a formal program for quality.
As indicated above, PSI has a history of completing successful fossil projects on time and within budget. PSI viewed quality in such a project as something that just gets built in - it comesnaturallyastherEIEEIEofgoodmanagementandanable. F knowledgeable, and dedicated staff. Everyone from the top down
~ knows what it takes to build a successful fossil plant, and they
_ all work together to ensure that the overa11 project and final project works and is safe. PSI viewed their success record as
' ~'
the resu1t of teamwork and dedicated personnel. It was a record established without the help of, or need for, a formal organi-zation until they decided to build a nuclear plant, and they 4
.i . .
1 % i i 1 then established such an organization not because they believed they needed one, but because NRC's 10 CFR 50 Appendix B required one. Moreover, NRC required that the head of this required quality organization report to the highest levels of utility management. This organization also has the authority to audit the activities of many of the other utility managers who report in at very high levels. Giventhesituationthat(a)PSIdid not believe it needed a quality assurance organization to obtain
; quality in power plant construction, (b) NRC mandated such an organization for nuclear work and (c) the new quality organization
. v es +d not only was vestted with certain broad powers but neither it 3 (nor its head) had paid their corporate dues in obtaining these 7 powers, it is net surprisin; th new quality assurance organization at PSI was greeted with a lack of enthusiasm, a i lack of management support, and even a mistrust. Region III's 1979 investigaiton produced internal PSI documentation which showed that PSI executives were cold to the idea of hiring very many people for the quality assurance organization, fearing the development of a quality assurance " empire." PSI management mistrust of and lack of enthusiasm for the mandated quality assurance organization resulted in a lack of adequate authority or staff (either in size or qualifications) u for the duality assurance organization (see Region III report 79-11 on Marble Hill for a more complete discussion of this
- h. l
J . ',
/3 i-i
- 2. Development of a false sense of security by PSI. i
! This secondary root cause is somewhat related to the primary ' root cause, inexperience. NRC's region based inspectors found
- numerous problems at the Marble Hill site throughout 1978 and
? 1979, but until right before the August 1979 stoppage of work, I PSI (and NRC) did not recognize the full extent of the problems. One PSI staff member (quality assurance) who was there at the , time of the problems put it this way (paraphrased): "NRC came in and they found a few things wrong, but thats their job. They didn't communicate to us that we had any really serious problems. l Since we viewed them as the experts, we felt that we probably l didn't have any major problems." M "T ^ y tg a w w .o.J & n LM , a .@ "t S~ E U " *** l Heavy reliance on contractors also caused PSI to develop a false j sense of security. Here, too, PSI felt that the contractors f were the experts and that if anything went wrong, the contractors ) would address it. i
- Another contributor to PSI's false sense of security is the fact
! that Marble Hill is a replicate of the Byron plant, which is being built for Consnonwealth Edison. PSI made extensive use of i design and licensing documents prepared for Byron, and PSI felt
~
I a that mosEina3or problems in construction would surface at Byron l, first and the Marble Hill project could be reprogransned to take l adyantage of the Byron experience. ! E m- - , ,n, , + , . ~ - m -. ~e-, -
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- 3. Failure of PSI,to manage the Marble Hill project from the outset.
This secondary root cause overlaps the primary root cause, inexperience, but it is of such fundamental importance that it should be highlighted as a root cause in its own right. Perhaps PSI did not effectively take control of the Marble Hill I project from the outset because they know they had no prior nuclear project experience, and so they would rely more heavily on contract rs than was their nonnal mode of operation. In any su
- ar %.h~ 4 % W W, event, PSI,di relinquish too much of the day-to-day management of the project to surrogates, they failed to establish and effective project management presence at the construction site (they tried to manage in a matrix arrangement from corporate headquarters), and they diluted accountability within the corporation for project responsibility. Ali of these failure-to-manage factors (plus over reliance on replication) contributed to the construction problems that led to the 1979 shutdown.
- 4. NRC licensing, inspection, and enforcement practices.
NRC's licensing review for a construction permit is largely
~
limitedio'technicalissuesandconformancewith10CFR50. Although NRC does review an applicant's financial position, NRC l doesnot(anddidnotinthecaseofM ble Hill) perfonn a l s l . .-
b-I formal review of the applicant's ability to manage, and carry through to completion, the construction of a nuclear reactor. NRC's inspection program for the Marble Hill project consisted , of a series of visits by regional based (Chicago) inspectors. A r resident inspector was not assigned to the site until December 1979. During our visit to Marble Hill, PSI's president (and , other PSI officials) expressed the view that a constant NRC presence in the fonn of a resident inspector is most critical from the very beginning of construction. They felt that occasional visits by a series of regional inspectors would not provide any j of them individuality or NRC with the comprehensive feel for or , ccmand of a project that a resident would obtain. Moreover, they felt that bad practices developed during the early stages of construction carry over into later work and the time to catch these practices and correct them is at the beginning. Waiting until the project is 15% complete can permit poor practices to become accepted and ingrained and much harder to farm around.
, They said they thought assign t of a resident to Marble Hill 4 from day one o'f construction would have been great help in recognizing Marble Hill's problems earlier and before they f
became as extensive as they were. 4
~
Finally,lh'e' enforcement signals sent to PSI by NRC were confusing a
;, to PSI. On the one hand, NRC was late to recognize the extent of[the problem. [This helped reinforce PSI's false sense of 4
5
" 4. ,
=
. r e
4 4 security. .On the other hand, when NRC did recognize or suspect the extent of the problems, PSI was late to understand the significance of NRC's new, stronger message. 4 4 e d 4 e P 9 4 ea m p b . l s
. o' .
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,' PUBLIC Date SERVICE "
INDIANA CONDITIONAL RELEASE FORM , Serial No. t LF 85-174 R 6/82 p PROJECT CONTR ACT MAN AGER / Date PROJECT CONTR ACT VANAGER MATERIALS / Date To: QUALITY ENGINEERING MAN AGER Conditional refecse of the items listed below is requested for the following reason: Description Procurement P.O. Number Spec. Ship 1.D. Supplier Storage Level Piece Mark I.D. Tag No. NCR/DDN No. Fora-BY -2'l3 4 61 RECEIPT INSPECTION SUPERVISOR DATE QUALITY RECORDS VERIFICATION SUPERVISOR OATE Conditional release approved with the following conditions: QU A LITY ENGINEERING MANAGER DATE Authorization to release to contractor Closure of conditional release PROJECT CONTRACT MANAGER MATERIALS DATE RECEIPT INSPECTION SUPERVISOR OATE (7 12) (7 9)
, l REPORT NO.
i PUBLIC RECElVING INSPECTION I SERVICE DATE INDIANA REPORT I 1 i ITEM NAME: l PIECE NO: ; l P.O. NUM B E R: P.O. ITEM NO: ' i SPECIFICATION NO: SIZE & QTY.: ! HEAT NO: DRAWING NO. I 4 LOT NO: VENDOR NAME: I MATERI AL SPEC: CHECKLIST & REV. - ITEM ITEM NO. SAT. UNSAT. , N/A SIGNATURE DATE NO. . SAT. UNSAT. N/A SIGNATURE DATE
! i l i ! I i l I I I I I I ! l
; I I I I i ! i
- 1 ! 1 1 l l I l i l l l I l l l l l
' l i l l I I i i l I i l I RESULTS: ACCEPT REJECT i
L ] ACCEPTWITH COMMENTS: l DON. NO. ' NCR NO. MEASURING & TEST EQUIPMENT USED: INSPECTED INSPECTOR DATE 1 CEVIEWED BY I AECEIVING INSPECTOR SUPRV. DATE b ACCEPT TAG NO: WITNESSED REJECT TAG NO: b RETAIN TAG NO: ANI OATE CONDITIONAL RELEASE TAG NO.: LF 85-170 R 6/80 i l 1 . - ..
-_ -- .. - .__..-: _. u = - :. _. = . = . ; . : - ..-- .: -
o NCR/ CAR CONTINUATION SHEET ' ' ' ' ' ' ' ' '
- MARBLE HILL PROJECT t F S1-479 R 12/90 THIS SHEET IS A CONTINUATION OF 8 LOCK NUMBER TITLE OF THE BLOCK i i
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, . I e
[ CONTINU ATION SHEET FREPARED BY PRINT NAME SIGNATURE -DATE INSTRUCTIONS: EACH BLOCK CONTINUED SHALL HAVE A NEW SHEET STARTED WHICH SHALL BE NUM8ERED PAGE 1. ANY SUBSEQUENT SHEETS FOR THE SAME BLOCK SHALL BE NUMBERED CONSECUTIVELY EACH SHEET SHALL BE SIGNED ANO DATED. ENSURE THAT THE APPROPRIATE ATTACHMENT BOX ON THE NCR/ CAR IS CHECKED OR THE BLOCK NO. CIRCLED IF NO BOX is PROVIDED. ;
,, CORRECTIVE ACTION REQUEST MARBLE HILL PROJECT 1. Control Number 2. Date LF 85103 R 12/80-2 i e i i e i r i i i t i i !
- 3. Safity Related? 4. Code ID 5. Procedure / Specification Violated O ves O No i e e t , i t , t i t i t i t t i i t i i e i t i 1 ' f i t t ?
- 6. PO Number 7. Spec. No. 8. Stop Further Proces- 9. Stop Work 10.Stop Work Order 11. NCR No. Attachment O sin 9? Order? No.
, , , , , , , , , , , O vos O No O ves O No , , , , i , , , i i , i
- 12. Surveillance / Inspection ' 14. R esponsible Organization
- 13. Initiators Or9antration ' Code . Code Report No.
f t t t t t i l ! t 1
- 15. Adverse Condition:
I - t Attachments O l '
- 16. Initiator s 17. Validated By:
Print Name ' Signature Date initator's Suoervisor Date
- 18. Reportable Per 10CFR21 Or 19. Request for 20. 21. Response Due Date 50.55(el? Evaluaten No.
ves O No O . , , , , Quality Engineer Date , , , , .
- 24. Corrective Action: 22. Deficien. 23 Cause cyCode Code i i t f I._
1 I l I t Attachments O 23-
- 26. Date Corrective Action Will Be Fully implemented.
Responsible Organisation Disoositioned By/ Title Date ! 27. Aporoval:
- 28.
Quality Assurance Date Authorized Nuclear inspector i Date 29-l Code Verification of 30. I Complet6cn of Verifying Organisation Conocme Acten l l , , O A Inspector / Engineer i t
l b NONCONFORMANCE REPORT MARBLE HILL PROJECT 1. NCR Control Numtur ! 2. Date I LF 61109 R 1/82 ; : i , i i , , , l
. 3. Equipment 1.0. Nurnber
- 4. Serial / Heat /Betch/ Lot /etc. No. 5. Location Cocw t t . , i t , ;
. . i ! . . . i !
. t y
, 6. Safety Re4eted? 7. Cooe 104 8. P.O. Number 9. Specification No. j 10. Procedure / Specification Vioisted 11. Surweilmce/ Inspection e Report No.
l Yes O No O ! , i
! t i ! t i t ? I I f f I J i e i ! . '
i 12. Drawing Number 13. Stop Further 14. Stop Work Order? 15. Stop Work i 16. Car No. Processing? Order No, j! i e i e . . . t i Yes O No O Yes O No O i e i j 17. ResponsstHe Organization Coco 18. Retain Tag No. 19. Conditional Release Tag No. , 20. Init4;t3r Or9eairaten Ce t f, . - t
' 21. Descnotion of the Nonconformance:
- 22. Affected Documents:
e 23. Initiator ! 24. Vehdated By:
/ / (
Print Name Signature Date inetietor's Supervisor Date ' E 25. Reportabse Per 10CFR21 Or 26. Roquest for 27-y= 10CFR50.56e? Yes O No O Evaluation No. / [$"CVj 29. Cause j l
, , , ! , aussity En.neer Date t t i
- 30. repositioning Organization i Code 31. Dispoestion:
yie.As-1: Repair i (Circle One Only) ASME O Rework i f f Relect
- 32. Disposition Justafscation:
= ,
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- 33. Implementation Instructions:
I 34. Implementing Organization ' Code 35. Proposed Completed 36. Venfy6ng Organization Code De o
+
1 ! ' ! I Dispoortten Approval ' 38. e t / i Signature Date j Company l PSI Protect Engineer Date , i Disposation Approves i 1 d.39.
, - _ _ - . . / i 40. / . ;
i PSI Quality Engineer Date , PSI Authorized Nuclear inspector Date ! l
< i i '
HOLD POINTS: none O attached O i HOLD POINTS: none O attached O I implementation Verified
- 41. ! 42. /
PSI QA Dept, Date ANI Date @b Tags Clee ed: 43. P5I QA Dept.
! i i Date l
l
~P 9
Ii , l SALP HISTORY- , l 1 DATES SALP NtNBER NONCOPPLIANCES HOURS 7/1/79 SALP I 24 4110
~
- 6/30/80 7/1/80 SALP II 3- 3910
- 9/30/81 10/1/81 SALP III 6 1924 9/30/82 1
i rol A -3 + 1' 3 K I63
y MARBLE HILL NONC&PLIANE HISTORY i INSPECTOR TOTAL 1 YR. INSPECTOR Yf.e8. HotRS NONCOMPLIANCE IDURS/ NONCOMPLIANCE 1977- 138 2 69 1978 421 9 46.7 1979 1836 22 83.4 1980 4634 13 356.5 1981 2296 3 763.3 1982 (Tm u 9/30) 1_Hi 3 482.0 10,771 52 207.1
- .tIII ( Six (6) YEAR HISTORY)/ SITE
- INSPECTOR IDjas. NONCOMPLIANCE HotRS/MONCOMPLIANCE tm (RIII) 2,649 (BRAIDN000) 43 61.6 4,653 (BYRON) 77 60.5 HIGH (RIII) 22,390 (LASALLE) 141 158.8 AVERAGE 5,463 53.7 101.7
- NOTE: 1982 DATA INCOMPLETE 4
S
NRC INSPECTION HOURS PER YEAR RESIDENT INSPECTION HOURS 1s-CUMULATIVE INSPECTION HOURS 11 } - l 10. , n . n 3 .. .
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NRC INSPECTIONS PER YEAR 66 i j 60- ! j s5-i ( j 50-45-n c l O
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- NRC NONCOMPLIANCES l
30-29-l 28-27. 28-25-24-23_ 22. i 21 20. 19_ 18_ 1 T. 18. l 15. I 14. , 5 13.
- 12. I 11-j 10-i s_
- 8. ,SALP i ,SALP N , SALPHi,
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- 1978 1977 1978 1979 1980 1981 1982 1983 1984 1985 1 2 3 } k (1) LWA-2 8/24/77 (3) CP 4/4178 (8) LIFTING OF ORDER 2112182
. (2) LWA-2 12/13177 (4) ORDER 8/18179 l
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LONG TERM REVIEW b ** h sus lo ewr P d m 54. u, f al'e s, MARBLE HILL CASE STUDY g4fa pry n ,.+- 4 ~ re + causes
? 4Af * #'."i'~"Y
- i t ,J -y ROOT CAUSES
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pglyggy -1 G y + L t A g.L < y ~ < y d INEXPERIENCE WITH NUCLEAR PROJECT
/,6 9 au % o ug,1 LACK OF ADEQUATE STAFFING COMPLEXITY OF PROJECT FOSSIL MENTALITY MISUNDERSTANDING OF NRC OVER RELIANCE ON CONTRACTORS LACK OF APPRECIATION FOR CODES FAILURE TO RECOGNIZE SYMPTOMS
~
SECONDARY LACK OF UNDERSTANDING OF MERIT OF INSTITUTIONALIZED QUALITY PROGRAM THOUGHT QUALITY COMES NATURALLY RESISTED QUALITY ORGANIZATION - FEAR OF EMPIRE ONE ARM COMMUNICATION FALSE SENSE OF SECURITY NRC - CONTRACTOR.S REPLICATION .
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REPLICAT-ION DILUTED ACCOUNTABILITY NRC LATE INTO PICTURE . LICENSING LIMITED TO TECHNICAL ISSUES 9. IRREGULAR (NONCONSTANT) PRESENCE SIGNALS CONFUSING j!EATT .
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TURN AROUND 4 ,, a . gg - y % M a M& RECOGNITION OF PROBLEM
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- DECISION TO ADDRESS IT SUBSTANTIVELY gy,, rm -g f u %LA PA* .
HUMILIT.Y *w ~w, / ~ 4 / 4 *** y A W, # a"'~ J='4JLp ?). 4~'# BE THE BESTha- %+kA' ksc
% - ~ 1 % f i h a n -
- STAFFING, ATTITUDE, MORALE, ETC. - W W J:W M A F'HY p .se 4 +C '*^*7-'
$ j_,Nw
. DECISION TO MANAGE '. W,$"h* :[a yr ,r4 .- -1' p + e 3.t u aak EVALUATE QUALITY ORGANIZATION -
99 # A %.a/ +, wi< +, 7-~.uf L rio A A'"* % . ny o uM 'r
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e OUALITY IS COST EFFECTIV.E s, 4, .:., e m ,
+<~. P ~r~t e < %+ y edJ .
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- dELP FROM NRC ,
2X4 HIGH STANDARDS GOOD RESIDENT 5
. . . . - y ~
J,QEEING FAPIR 6 4 I I I l
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e preA LONG TERM REVIEW MARBLE HILL CASE STUDY GENERIC IMPLICATIONS
- NEED MGMT COMMITMENT TO QUALITY e -
! - EDUCATION
- MANAGE PROJECT
- RESOURCES AND SUPPORT FOR QUALITY ORGANIZATI0'N j - TEAM ATTITUDE l - OVEPALL GOOD MGMT
- INTERFACE BETWEEN, PROJECT MGMT, CONSTRUCTORS, QA, ETC.
- NUCLEAR EXPERIENCE NECESSARY BUT NOT SUFFICIENT
- CuMiry Pene e
i I nm% womu m rass O e e 4
r .. 1 absKING7 M
~
LONG TERM REVIEW MARBLE HILL CASE STUDY NRC INITIATIVES
. WHICH INITIATIVES MIGHT HAVE MADE A DIFFERENCE AT MARBLE HILL I. MTOL
- 1. SELF EVALUATION NO
- 2. REGIONAL EVALUATION NO
- 3. INTEG. DESIGN NO II. INDUSTRY INITIATIVES
- 1. INPO (INCL. MGMT. AUDITS) YES
- 2. UTIL EVAL (WITH OUTSIDE HELP) YES III. CONST. INSP. PROG. ,
- 1. ' REVISE PROCEDURES & INCREASE RESOURCES YES
- 2. CAT (WITH INPO)' YES
- 3. INTEGRATED DESIGN INSPECTION- Nd ,
4 EVALUATION OF REPORTED INFORMATION MAYBC IV. DESIGNATED REPRESENTATIVES MORE NO THAN YES V. MGMT
- 1. SEMINARS YES
- 2. QUALIFICATION / CERTIFICATION OF QA PERSONNEL NO
- 3. CRAFTSMANSHIP NO ,
f VI. MGMT AUDIT (SUGGESTED BY PS'I) YES i
-: yam 1M7#
1 e ? - l . .. . .
- -~ .
/ -
, 1
. l J
. :. WGih LONG TERM REVIEW MARBLE HILL CASE STUDY FORD
- 1. MORE PRESCRIPTIVE A/E CRITERIA NO
- 2. CONDITIONING CP ON DEMONSTRATION OF QA MGMT YES ABILITY
- 3. REVIEW BY INDEP ASSOCIATION OF PROFESSIONALS MGMT AUDITS YES
- 4. IMPROVE NRC'S QA PROGRAM YES
- 5. CONDITIONING CP ON COMMITMENT TO USE NOT LIXELY/NO -
INDEPENDENT INSPECTOR.S e parara P
** a e
F 0 t h 9 e 9-
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.. %d4(cd SOME OBSERVATIONS ON QUALITY ASSURANCE AT MARBLE HILL NUCLEAR STATION - BEFORE AND AFTER The l'arble Hill nuclear station of Public Service of Indiana was a splendid example of competent personnel, thorough procedures, staff esprit de corps, and top management commitment and involvement in quality matters, all combining to produce what appeared to be a quality construction job.
But this had not always been the case. Prior to the NRC shutdown, the licensee had a " fossil fuel mentality". They had successfully built and operated modern fossil fuel plants, and their attitude toward nuclear was founded on their approach to fossil. Fossil construction was performed under fixed-price (almost turnkey) contracts. Quality-related problems were taken care of after the plant came on line. Many years of experience on the part of vendors, contractors, and utility virtually guaranteed an adequate facility. So, on Marble Hill, which is a replication of Byron, the licensee had a staff of 75. Now it is 750. The fixed-price contracts were n'ot geared to the level of quality which goes into nuclear plants on an as-constructed basis. Post-startup changes were not permitted. THI and other added safety considera-h tions were added to the " replicated" design. Still ,the licensee was insisting the construction contractors meet schedule and cost. So quality suffered, and poor concrete placement practices resulted. The whole concept of QA was not understood or ignored. It didn't exist as a fonnal activity on fossil plants, j so it was an add on for nuclear, required by NRC. It was resented by all. And the matter was not helped as the QA staff politicked for position within the company. The key factor in the Harble Hill turnaround was the admission by the
~
CE0/ Chairman that their approach to nuclear plant construction was wrong. Rather than fight QA and all it implies, the necessary steps must be taken to embrace it. This required a top management commitment to quality which
/
manifested itself as follows: 1) an ooenness, or honesty which permits problems to be aired without threat, 2) an intolvement in the " day-to-day" problems which arise in a major construction project, 3) an encouragement to team building (there must be no "we" and "they" anywhere in the organization but an overall common objective to build a quality plant on time and within cost),4) adequate fundinglas manifest in adequate staffing and systems) to do the job. This was 0 the first big change. Fo/4-f+493 K/w
f , y The second major step was to renegotiate all construction contracts to ' b include quality requirements. This necessitated a change from fixed-price contracts to cost plus-type contracts. Under the former contracts the licensee 1 had no say in how poor quality construction should be corrected. In fact, if 1 the licensee could not specify " quality" in the contract, he had no say in how quality should be achieved.
, The licensee has found that a constant effort at affirming the commitment j to quality is required.
This is not a one-time pronouncement. The quality assurance attitude must pervade everybody down to the construction forces. A good QA attitude in management and engineering is not enough. , It must be pushed to the grass roots, and that takes some doing because, while the concept 4 of good workmanship is typically there in the crafts, the concept of QA isn't. So team 'uilding efforts are required at all levels (including construction craft and so .or personnel, forcmen, area superintendents) and there must be a QA discipline instilled in the entire team. The evidence of this is ihanifest by unifonnity in construction (e.g., all bolt heads are on one side, nuts on the other), good housekeeping, lack of graffiti and girlie calendars, no O '" '*"*" S*5 "5'**'**'- "d "" ""* d'""" "' " """*" called for. All of this is present at Marble Hill. As previously stated, the licensee had a nuclear staff of about 75 persons devoted to Marble Hill when construction commenced. And most of these had no nuclear experience. It soon became apparent that fossil experience was not applicable to nuclear. The work was far more complex and could not be left to inexperienced (nuclear) construction forces. The licensee had to provide direction. That takes superior personnel in key positions. Obtaining them wa_s the third major step in turning the project around. It takes staff who I are experienced and who know they are competent to create a nonthreatening work environment in which openness to problems will be tolerated (and so they can be dealt with). The licensee sought such personnel through recommendations of consultants (MAC) and through head hunters. Tney were attracted by the opportunity to put good systems and procedures into effect, as well as by position and salary. Obtaining what they have always wanted in systems / procedures and work environment was precisely the challenge they needed to see the job to completion. [Said another way, adequate procedures / systems O exist t c mplete nuclear plant construction. But superior personnel know that more efficient procedures / systems could be developed to really do the job right. Unfortunately, there are few opportunities to develop them. When l
./: . .
3 someone is writing to put money where its mouth is (e.g., Public Service of fo Indiana), the superior personnel sense the opportunity "to do the thing right this time", and buy in.] The fourth major step was establishino the procedures and attituk which would permit a quality job. The key personnel knew what procedures were available in the industry, and knew how they should be implemented and/or improved. So from having almost no formal pmcedures for document control, design changes QA training, team building, cost / scheduling, etc., the licensee has very solid project controls. The fifth major step was establishing an esprit .de corps to do a quality job on schedule and within cost. The preshutdown organization was divisive, withy a thing to be tolerated, the construction contractors a " labor force", the NRC the enemy, etc. A lot of things went into this change. The starting point had to be the management attitude and comitment to seeing the job done , well. All is not sweetness and light at Marble Hill. There are stonn clouds on the horizon. t 0 - Recall that the _three components of any project 'are cost, schedule, and quali ty. If one can control two of them, then the third can be achieved every time. So for quality to be achieved, there must be flexibility in the schedule and adequate funding. This observation holds true for Marble Hill to the l present, but financial constraints on PSI (which also reflect into getting the ( station completed in the shortest possible schedule) may sorely press quality goals. - i i 0 4 i 5 i l
I i . I **"*"'=""'"'""'a"**'d"' are average of 84 feet tNck encircles the re- Tour Information d p e A 4Wices Inch wenforted conce N Group tours of the Marth His project can be ar-cal sM sunounds the weation M ranged through the Marble He Whors Center by
*The reactor vessel and sNeed waBs are calling (R12) 293-3429 Arrangements shoukt ,
housed Iri a ccetamment structure mac'e up % be made in advance. of a shet of Wbth steet. encased by anouter You may aho enjoy a wNt to 5%bik Service IrwS wmas of retnforced concrete that s an aw rage of 3% feet ENctL ana's Herteige Square Nuclear Information Center , in Madim The centet is located at the comer of Evere icy people Steg right next to Marble HIE. soueme releases of sacRatiori wouki be only abour F4sr_ T-~ 4 Mairs and lefferson streets-across from the lcf-ferson County Courthouw-and is open from 9 MNM as vnucts as that from wasching co6or tetewNort a m to 5 p m Monday through Irtriay anrs f0 a m. Marble He h ahodesigned tomorhstaruf scenados to 3 pm on Saturday or earthquakes that can be expected art the area Additional hformation about the Marble H4 Nothing can be totapy safe. And rhts associated protect or nuclear power can be ottamed by metti the procbction of electractry from nuclear wnting the Marble HillWMors Center.f'ost Omcc power plants areconsiderably less than many rhks Bom 190. New WasNngton. IN 47162. or camng the retephone number above. l that are reactly accepted by society. Contrary to a j w6despread reds.w A . ..bn. It is kuposelbee for a nuclear power plant so emplode he a nuclem ; ! bomtt i Waste Storage The technology lor safely storbg NgMewed waste The Conclusion m&ar power @ does W ancHs W demonstumi The waste can be tumed into send Nuclear power kn't perfect. It has les problems
% anct stored deep in h e ance compromises pse as any method of produc-i Ing energy flut we beneve le cdfers an em4ron-l When spent fuel % reprocessed. the wchme of C
-i figMewel e @ed in a nuclear power 8E' '* "'*$ U8 '**C
- C *'# PE*"d' i
We must aho continue to uw coal arut practtce q waste from a fut year of operanton would As ya energy conserwarlors Anct we must develop the AI potenetal new es that may W our -
**'* S energy in the neut century. Energy shortages can the 000 M uf be we make fut use of the energy op wa,se_ . tor,a - ..c m ,ast- ,a ut 30 feet Ngtt *
. The federal government contvois as nuclear wasie l In the courey les poRcy ca8s por &A ., of t permanent sees for waste dkposal owr the neut sewraf m t>va ihen. nucicar waste W stored ter,,orar.y , ~ r-s ep-tes nuclear veactors Temporary ssorage m Marbee H2 can handie to to 85 yeari worth of ' pent W pb/g, yQ-% PUBUC SEFWICE INDIANA
l l 1 l l l l l 4 1 . { Sarue cornumers in the state contiruse to use en-l creassig amounts cd electricity arut present gwwwer i plants will eventuaNy mem out. Ibt2C Servk e truis-j aru must keep up werh the demarwf arut bued Safety K a top priortry at a nuclear power plant ( more power plants And as a result, no other industry has as erwtable a An adequate supply of circ trkary supports jobs in safety record Safety has been bust an from the te as sorts of ku%stries br an eveNnc reasing wo,,, ginning and has been connnually improved force; provktes power for our environmental 3 _ l clearvup prograrrt replaces those fuels that me in Several layers of protecrton for each system in ste short supply; and prowules the rneans to anow plant have provkted the ertra margin of safety that I even the lowest trxome farruhes to improwe thew has proter ted the pubik, even in the worst nuclear standard of IMng A shortage of elec tndry, on the plant ac(klerws Marbie Hm. as one of the gen-other hand. would mean economec disrupnans cration of nuclem power plants to be completed
,te,I . I __ and hardsheps for everyone after the Three Mde Islanct accktent. wis contain i even more sophisticated safety systems than ks prectecessors.
l The Marble Hill Project Why It's Needed As an example, look at the wartous layers built inro the Marbie Han iant = praeo the pue* and -+ pioyees from the accidental release of harmful In t973. Ibbac Serwke instana announced plans Marble Hit is bemg built to supply electricky to g f4 anourws of radLattori: .l so taand a nuttear poner plant. That faceiry-the Martde H.E nuclear power stanori-is now under people h Indiana During those atmes when Hoosier consumers may not be using at the *m. e The uranium fuel peacts are made of hard ceramic to hold the uransurn arut other radio-cc3 strucnon in southeastem butana at a site of power from the plant. some may be sold i active marertals { y ime usesin ienmen courwy nem Ma eiscwhe,e out our o-, customers come n,st i N compics economy m) Wh h The Economic Choice ""*"*="d'"'P"'"'"*"*'"'"' e The rextor vessel where the nuclear reaction
; Marbie Hits sole Onction web be to generme cicc- einerktry The goods and serwec es we dermd on "
mcky The power was be used by more than three Throughout the narkn nuch m power plants have J, would no longer be reactsy avamabic if the state's been generming electruky for years at a lower he ' ernthese people h Indiana The plant wig contaan utanes couldn't supply enough electricity two generating unirs, exh capatde of produces cost thare their oil. gas or coal firect counterparts . II3 moon kdowatts of electrutry Marble H+5 we be no excepncn ! F ' ,,,,,,,,,,,,,,,,%,,,,,,,,,,,,, i , Marble Hat is expected socost $51 bears ars erst Marble He we cost more than $5 belhon to bued - ==aa= =a === ====we aw=*** urut n schechied for completion in late 3980, with , I a staggering Agure that represents the largest s.=w .m. m the second unit espected to go bro operatton in - amount of money ever spent on a <onstruction -~**'""'**"" 1 mock t988 when the plant is fuey operanonal. It projet t h inctlana Ent this cost wm be spneact out ",";***** O "*
,,,, over the Die of the pi.ent ,,,, !
- was employ about 750 peopie . -
,,,,,,,,",,,,,y N
1 J;=,, j i , The savings come in the operation of the plant. me ** **mese 7 i fbbec Scrwc e indlana meR operate the power plant and own 83% of es 2 26 matun uowart capacity sNosANA [ The fuct topower Marble Has for 30 years m411 cost about $11 tnRiors But the luce to power a < ompara-7.=*,***"* I i } The remauung 87% we be ommed by the Wabash a c.,,,,,,- _ j tde cod Ared power plant (the nest cheapest al-j Vancy l'ower Assorianon,a groupof 24 suraleiec-a,
**** W a====_...
1 c_ temate e) for the same 3G year penod mould cost j enc cooperattwes and be used by ars 300.000 cus- e j an esthiatect $28 txikon That's a $17 twihon fuel 4 somers f afNTUCme saving for the peopic who will use electnc sty from the plant e.
.e
" ~
The nuclear reactors along with the surtenes and J""'****" e4ectrical generators are being supphed by West- , mghcasse IJectnc Corporanors Desrgn and enge
/ So when the tugher cornrrut twin costs are Rgured w..,se W esm me I' l in wth the lower operanns and m.untenarse '"'**== j neenng for the piant are by Sargent lL Luncty [ngs- l ricers of Oscago
, <osts the resuit rw lower < ost electraivy from a <
ruxtear gwwver plant _
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9 DOCU \A EN-~ PAGe PJ_ LED i l A\ O . zoo - zs NO. OF PAGES / REASON O PAGE ILLEGIBLE: O HARD COPY FILED AT: PDR CF OTHER O BETTER COPV REQUESTED ON / /
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On June 26, 1979, a second meeting was IAL 06-27-79 0 held with PSI officials to discuss the findings of the investigation at that point and the fact that the deficient , repairs of concrete had been identified. As a result of this meeting PSI agreed to stop concrete activities for safety related structures, perform non-destruc-tive examinations of various concrete structures, identify and evaluate re-paired areas for adequacy and review i their entire program for concrete ac-tivities onsite. An Immediate Action , Letter (IAL) dated June 27, 1979, was issued confirming this agreement. On June 27-29 and July 2-7, 1979, inspec- IE Inspection tion was conducted relative to Items 1, Report No. 79-07 2, 3, 4 and 5 of the IAL. Based on the ' results of this inspection, Region III l concurred in the resumption of concrete placement for safety related structures. One item of noncompliance was identified with regard to failure to assure purchased services conformed to procurement documents. Initial results of the inspection con- IAL 07-23-79, IE ducted during the period of July 9 Inspection Report through July 27, 1979 lead to a site No. 79-09 management meeting on July 20, 1979, and an understanding that the licensee would again stop concrete activities for safety related structures. A second Immediate Action Letter (IAL) dated July 23, 1979, was issued docu-menting this understanding. Five items
- of noncompliance were identified with regard to: inadequate QC inspection, six examples; inadequate specification of quality requirements, four examples; -
lack of or failure to follow procedures, four examples; failure to take effective corrective actions, three examples; and lack of adequate training. On July 25, 1979, Region III learned that IE Inspection Report a team from the National Board of Boiler No. 79-11 and Pressure Vessel Inspectors had con-ducted an inspection on June 12-14, 1979, at the Marble Hill site during which numerous items of noncompliance with the ASME Code were found. As of the result 1 of the National Board's inspection and the Region III findings a comprehensive team inspection was conducted during the h % ,, g 4 Q p
period of July 26-28, July 31-August 3, 1979. The purpose of this inspection was to identify the underlying causes leading to the concrete and ASME Code Deficiencies and to determine if they were symptomatic of problems in other areas. The results of this inspection indicated that problems and the Quality Assurance / Quality Control (QA/QC) program in concrete construction activities extended to other construction areas as well. Four items of noncompliance were identified: failure to sufficiently implement the QA program; failure of estab-lished measures to assure the conditions adverse quality were promptly identified and corrected; failure to assure the special processes, including welding...are control-led...by... qualified procedures; and failure to properly control materials...which do not conform to requirements.
- 2. NRC Actions NRC actions following the identifica-tion of problems relative to placement and repair of concrete and prior to this SALP evaluation period are described in Paragraph 1, Basis.
. Region III issued a second IAL Letter 07-23-79 which confirmed that PSI would again stop concrete activities for safety-related structures. .
As a result of findings prior to this IE inspection Report evaluation period Region III conducted No. 79-11 a comprehensive team inspection during the period of July 26-28, July 31-August 3, 1979. The results of this team inspection are as follows. NRC concluded that effective implementa-tion of the documented Marbic Hill Quality . Assurance program for all safety-related construction had not occurred. PSI and their contractors had not sufficiently complied with its fundamental commitment to conduct all of these construction activities in accordance with the re-quirements of 10 CFR 50, Appendix 8, and other required codes and standards. The nrincipal causes a d these adverse
'conditinnc and nnnenmn iances were:
(1) insuf ficient manaaement and manace-
ment sunoort. (7T inenfficient number of Versonnel ( 4' ine'++i-4^-+ + ' 3] quotiricat' on of novennnel and (4) in-rui6acient v exnpriencon novennnej, The secondary but sianificant contributing causes were. (i raiture to acequately
< men u ry edi ' 6 sk or mission regarding the verification of the adequacy of work done by contractors, W ailure to devise a system to comprehe Wively account for and evaluate all identified nonconform-ances occurring on the site, La&, failure to recognize the generic implications of recurring , deficiencies, (gk failure to recognize that fixed price construction contracts, while not inherently defective, are likely to place heavier demands on the licensee verification of construction adequacy, failure to delegate sufficient authority o QC inspectors and their managers regarding stop-work authority, fjb) failure to institute employment smanning) and compensation practices which would attract adequately qual-ified and experienced job applicants,
,'}g,failureofcorporatemanagement
;o recognize the need to be more responsive to site QA/QC manning request, a failure to be respon-sive to n recognize the importance and authority of construction code enforcementbodies,andgg)dat-to recognize that the use a an failure tempted upgrading of laborers to supplement unavailable journeyman craftsmen requires more comprehensive training and oversite.
The above findings by their nature involved all safety-related construc-tion activity by PSI and their contractors at the site. Without extensive corrective actions, there was little likelyhood that continued construction could be accomplished with adequate assurance that quality requirements would be met. At the request of PSI, representa- IE Inspection Report l tives of Region III and PSI No. 79-14, and } management met again on August 1, Order 8-15-79 l 1979, to discuss PSI's planned ac-tions to correct the programmatic 4
QA/QC probicms at the Marble Hill site. Meeting included a discussion of the desirably of stopping all safety-related construction activities i at the Marble Hill site until such
- time as the licensee demonstrates that it has an effective QA program acceptable to the NRC. The licensee issued a stopwork order on August 7, 1979, for all safety-related construc-tion. An order confirming this suspensicn of construction was issued on August 15, 1979, by the NRC. A meeting was held with PSI management in the Region III offices on August 15, 1979, to discuss the conditions of the confirming order.
. Numercus management conferences were IE Inspection Reports held during this evaulation period No. 79-24, 79-28, after the issuance of the order. 80-05, 80-07, 80-12, these conferences occured on the 80-17, 80-24. ,
following dates: 11-08-79, 12-10-79, 01-21-80, 02-20-80. 02-27-80, 03-31-80, 04-30-80, and 06-27-80. On 03-25-80 a public meeting was held in Madison, Indiana to discuss the licensees re-sponse to the August 15, 1979 " Order Confirming Suspension of Construction." Upon issuance of the order an aug- 08-15-79 mented inspection program to verify compliance with the order was initiated. A full-time senior resident inspector 12-03-79 was assigned to the Marble Hill site. A formal briefing on resumption of 05-07-80 construction of Marble Hill was presented to the NRC Commissioners. The Director of IE issued a document 05-15-80 titled " Graduated Recission to the August 15, 1979 Order." This docu-ment prescribed a graduated rescission process for implementation at Marble Hill to assure that the licensee's corrective actions were implemented and effective. Construction ac-tivities at the Marble Hill site resumed in a graduated, step-wise fashion with review by the NRC at appropriate stages.
1 l
- 3. Licensee Corrective Actions Licensee Corrective Actions relative to each Immediate l Action Letter (IAL) are documented in the inspection reports referenced in Paragraph 1, Basis. The correc- ,
l tive actions relative to inspection findings that resulted in the issuance of the August 15, 1979 Order and those items identified in the Order are documented in virtually all of the inspection reports issued since i that time and during this SALP evaluation period. In addition the following documents which are available in the local Public Document Room describe the licensees corrective actions:
. Report SL-3753, Evaluation of Inplace Concrete, Marble Hill Nuclear Generating Station Units 1 and 2, prepared for PSI by 'Sargent and Lundy Engineers, November 20, 1979. Revision 1, ; November 21, 1980.
! . February 28, 1980, DISCRIPTION OF LICENSEE ACTIVITIES j ADDRESSING ORDER CCNFIRMING SUSPENSION OF CONSTRUCTION. i . April 28, 1980, CONSOLIDATED DESCRIPTION OF QUALITY ! ASSURANCE PROGRAM. September 12, 1980, CONSTRUCTION AND MATERIAL VERIFICATION PROGRAM, FINAL REPORT. REPORT REVISED May 15, 1981. B. Contention '
"The licensee had not sufficiently implemented Quality Assurance
- and Management Controls."
l 1. Basis , Major examples are the same as identified in Contention A. i 4
- 2. NRC Actions Major examples are the same as identified in Contention A.
- 3. Licensee Corrective Actions
. Major examples are the same as identified in Contention A.
C. Contention ' "There were ineffective controls over civil and mechanical ; construction." .i 1.' Basis I Major examples are the same as identified in Contention A. l l' . I ;
. - - . ~, , . . - .. .. - - , , -,_...
e i
- 2. NRC Actions Major examples are the same as identified in Contention A.
- 3. Licensee Corrective Actions Major examples are the same as identified in Contention A.
D. Contention "There were ineffective controls over stored equipment and ccaponents."
- 1. Basis During an inspection on November 14-20, IE Inspection Reports 1979, one item of noncompliance ident- No. 79-25 and ified relative to failure to provide No. 80-03 proper storage and maintenance of material with 19 examples. Six other
, items of noncompliance were identified 1 during an inspection on January 7-31, y 1980 with the following findings: failure to include quality storage require- , ments in procurement documents; failure to e prescribe a quality storage activitiy in documented procedure; failure to adequately implement (verify conformance) a storage inspection program; failure to provide adequate storage / preservation instructions and to provide such instructions in timely manner; failure to adequately identify storage nonconformances; and failure to provide prompt corrective action for storage nonconformances.
- 2. NRC Actions Same as identified in Contention A. IE Inspection Report No. 80-43
- 3. Licensee Corrective Actions The'11censee developed an extensive material control program which was implemented subsequent to this SALP evaluation period.
E. ' Contention
" Quality Control inspections by contractor personnel were not performed effectively."
l 1. Basis Major examples are_the same as identified in Contention A. l - 7-
,y , y ,_ - ,_,, __ -, -r *- -- *'W " ^ ~ * * ~ - " -
1
- 2. NRC Actions Major examples are the same as identified in Contention A.
- 3. Licensee Corrective Actions
, Major examples are the same as identified in Contention A. F. Contention
" Conditions adverse to quality were not corrected prior to concrete placement."
1.. Basis Major examples are the same as identified in Contention A. . 2. NRC Actions Major examples are the same as identified in Contention A.
- 3. Licensee Corrective Action Major examples are the same as identified in Contention A.
G. Contention
" Corrective actions were not taken for discrepancies."
- 1. Basis Major examples are the same as identified in Contention A.
- 2. NRC Actions Major examples are the same as identified in Contention A.
- 3. Licensee Corrective Acticns '
Major. examples are the same as identified in Contention A. + H. Contention
" Marble Hill received a relatively large number of items of non-compliance when compared to other construction facilities under construction."
- 1. Basis The number of items of noncompliance were IE Inspection Report high, however, in view of the fact that No. 80-45 '
safety-related construction work was suspended by an NRC order for most of the appraisal period, there was no basis to e w - - - - -
~
compare the licensee's regulatory perform-ance with other plants under construction. The majority of items of noncompliance dealt with activities in progress before work was suspended, except those discussed in Contention D.
- 2. NRC Actions Same as identified in Contention A.
- 3. Licensee Corrective Action Same as identified in Contention A.
, I. Contention "There were instances where the licensee required escalated NRC enforcement action, frequent management contacts, and stopwork orders to assure compliance with NRC requirements. An order suspending all safety-related was issued in August 1979, because of NRC concerns over the adequacy of the licensee's quality assur-ance program and controls over construction activities."
- 1. Basis Major examples are the same as ide'ntified in Contention A.
- 2. NRC Actions Major examples are the same as identified in Contention A.
- 3. Licensee Corrective Actions Major examples are the same as identified in Contention A.
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