ML20151K937
| ML20151K937 | |
| Person / Time | |
|---|---|
| Issue date: | 06/19/1985 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Bangart R, Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20151K612 | List:
|
| References | |
| FOIA-87-866 NUDOCS 8506260181 | |
| Download: ML20151K937 (2) | |
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MEMORANDUM FOR: hard P. Denise, Director, DRSP, RIV Richard L. Bangart, Director, DRSS, RIV FROM: Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
SUBJECT:
R_EGIONAL ASSESSMENTS .
The DEPER assessment of regional programs consisted of two phases this year.
The first phase was the evaluation of regional programs per IE Office Pro-cedure 0200. This was accomplished through formal, onsite evaluations docu-mented in individual reports for each regional DEPER program.
The second phase consisted of an informal evaluation of regional perfonnance by DEPER management, based on regional and reactor visits and or oily contacts and written correspondence with regional personnel.
The overall result of this two-phase assessment is sumarized in the enclosed I paragraphs titled "Safety Responsibility" and "Principal Regional Assignments." l Given the narrow scope of our formal evaluation and the breadth of our informal evaluation, we hope you will find our perception of your region's performance consistent with your own. We will appreciate your views in this regard.
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aw c . Jordan Director l Divisi of Emergency Preparedness and ngineering Response Office of Inspection and Enforcement
Enclosure:
Regional Assessment -
cc: R. H. Vollmer, IE J. G. Partlow, IE B. K. Grimes, IE
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l REGION IV ASSESSMENT Safety Responsibility Regional management generally exhibited a clear understanding of and concern for the safety significance of events. Examples including design deficiencies in the Waterford 3 plant protection system and the plant computer and Ft. St.
Vrain control rod drive problems. Daily Report follow-up of events was adequate.
Follow-u) of open items such as bulletins,_ tis, and licensee event reoorts 7 as not 3een rignrnos to assure closecut. A new standardiz W computer ba' sed tracking system for all sites in the region is being implemented to improve this area.
Principal Regional Assignments Regional management ensured adequate implementation of DEPER programs. However, the reaion ornvided minimal response to some IE reouests for information on events. Observation of a Regional EP inspection at Arkansas Nuclear reflected
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a strong emphasis on ensuring adequate implementation of the licensee's EP program.
Regional implementation of the response capability program area component, Other Organization Contacts, and Interface Component was minimally adeouate. Sub-stantial modification is necessary for completion. Procedure modifications were recently completed and the region committed to revise Supplement IV to NUREG-0845 by July 1985.
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June 21,1985 '
MEMORANDUM FOR: R. P. Denise, Director Division of Reactor Safety and Projects, Region IV FROM:
J. G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
ASSESSMEHLOF IMPLEMENTATION OF THE NRC INSPECTION 7 ROGRAM BY REGION IV_ AT RIVER BEND STATION 1
1 The Office of Inspection and Enforcement described to the Commission in SECY-82-150A the assessment of the implementation of the NRC inspection pril in conjunction with Construction Appraisal Team (CAT) inspections. Accord-tion program based on the July-August 1984 CAT inspecti ,
The results of the inspection were documented in Inspection Report 50-458/84-23, dated October 19 1984.
l The enclosure to this memorandum docu-ments the results of our assess, ment of the construction inspection program implementation.
Ma J. G. Partlow, Director Divission of Inspection Programs Office of Inspection and Enforcement
Enclosure:
Assessment cc: J. Taylor, IE Fezy M B/7
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REGIONAL CONSTRUCTION INSPECTION PROGRAM ASSESSMENT - RIVER BEND (RIV)
I. SCOPE The Construction Appraisal Team (CAT) of the Division of Inspection Programs conducted an announced construction inspection at the River Bend Station of the Gulf States Utilities Company during the period of July 30th - August 10th and August 20th - August 31st, 1984. While the pre-dominant effort of the inspection team was devoted to hardware inspection, the team also evaluated the control of design changes and corrective actions. In addition, a detailed examination was made of project con-struction controls.
The purpose of this assessment is to evaluate the implementation by Region IV of the Construction Inspection Program. A further purpose of the assessment is to make recommendations, if necessary, to improve the inspection program so that a comprehensive review of the licensee's construction activities is covered by the Construction Inspection Program.
II. ASSESSHENT ACTIVITIES A review was made of RIV's inspection and SALP reports of the River Bend Station RIV to identify those deficiencies that were previously identified by inspecters.
The inspection reports of 1979-1984, the 1982 and 1983 SALP reports, open items and violations were reviewed.
The Executive Summary and Potential Enforcement Actions of the River Bend CAT inspection report is provided as Appendix A and Appendix B.
The inspection reports for 1983 and the 766 inspection data were analyzed and it was determined that approximately 1850 man hours of direct inspec-tion effort were performed by Region IV at River Bend in 1983. The analysis of the reports and computer data indicated that the construction l inspection the program was approximately 85 percent complete at the start of CAT inspection.
The total man hours and percent completion is com-parable to other construction sites and Regional totals for the construc-tion status of the River Bend construction effort.
III. INSPECTION FINDINGS A.
Electrical and Instrumentation Construction
- 1. CAT Findings -
A number of cable and raceway separation deficiencies !
were identified. '
The CAT inspectors found that a number of cable tray supports did not meet the drawing configurations that were used for determining support loading.
- 2. Assessment The cable raceway separation deficiencies were previously identified by the Regional inspectors in Inspection Report 83-21 and was being carried as an open item. Further, the Region had endeavored to have an electrical construction consultant review the separation problem prior to the CAT inspection.
Inspection Procedure 27051, As-Built Verification has not as yet been implemented by the Region and it is possible that the cable tray support problem may have been identified.
- 3. Recommendation The existing Construction Inspection Procedures if properly implemented are adequate to have identified existing problems.
B. HECHt.NICAL CONSTRUCTION
- 1. CAT Findings Several instances were identified where engineering dis-positions of N & Ds and E&DCRs were not as thorough or extensive as necessary to address generic considerations of identified hardware deficiencies.
Problems were identified with pipe support / restraint lock mechanisms, improper protection and misuse of pipe supports.
- 2. Assessment The Region in the past has identified an inadequacy of the licensee's handling generic considerations of N & Os and E&DCRs.
The specific problem with the incompatibility of ASME snubbers was the subject of a NRC Information Bulletin but for different manufacturers.
The problems identified with pipe supports / restraint lock mechanisms, improper protection and misuse of pipe supports is common to most sites in the latter stages of construction and require more fre surveillance and follow-up by the licensee.quent
- 3. Recommendation The Construction Inspection Procedures for this area are evaluated to be adequate to have identified the exis';ing problems.
C. WELDING - NDE
- 1. CAT Findings Several discrepancies were identified concerning film supplied by a pipe vendor.
Discrepancies were also identified during the inspection of the vendor equipment and review of vendor film. !
- 2. Assessment The piping vendor film discrepancies were reported to the NRC and the Region is carrying the deficiency as an open item and is currently reviewing the licensee's corrective i action.
The deficiencies identified concerning vendor film and 1 l
equipment has been a recurring problem at~many of the !
nuclear construction sites and the current reorganization and redirection of the Vendor Inspection Program should i result in addressing these vendor deficiencies. '
- 3. Recommendation
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I The Construction Inspection Procedures for this area are l determined to be adequate if the program is properly imple- I mented. '
The identified problems with vendor film and equipment will be brought to the attention of the Vendor Inspection Program Branch for their evaluation.
D. CIVIL AND STRUCTURAL CONSTRUCTION
- 1. CAT Findings Identification of two cracks in concrete, and Roto Foam, debris and concrete in plant isolation joints.
A significant number of high strength bolts in the Reactor Building structural steel connections were found to be below minimum torque values.
- 2. Assessment ~
The current IE Inspection Procedures do not specifically call for the inspection of foreign material in isolation joints. However good inspection practice and a review of the licensee's construction and inspection procedures should have indicated the need for this inspection to be performed by the Regional Inspectors.
The current Inspection Procedure for Structural Steel :
and Supports does not specifically require a recheck of structural steel bolt torquing after initial inspec-tion.
i The relaxation of bolt torquing has been identified at previous sites and the Reactor Construction Programs Branch will evaluate including this recheck in existing procedures.
- 3. Recommendations Other than the evaluation for retorquing of high strength bolts the Inspection Pro !
adequate for this area. gram Procedures are evaluated to be l E. MATERIAL TRACEABILITY
- 1. CAT Findings The temperature control of weld filler material storage ovens was deficient.
Work or rawork of some flange joints was being accomplished without QC or engineering concurrence.
- 2. Assessment The regional inspectors have made frequent inspections 1 1
of the licensee's control of weld filler metal and have not found temperature control deficiencies. These inspec-tions are outlined in Re 82-5, 83-2, and others. gional Inspection Reports 81-8, The identified deficiency is apparently a result of a change in the licensee's monitoring procedures and is being reviewed for possible corrective action by the licensee.
- i The identification of undocumented rework performed on a i I
pipe flange is apparently an isolated case and was not identified in other discipline areas.
- 3. Recommendations i
The Construction Inspection Procedures for this area are evaluated to be adequate for the area of material traceability. ,
F.
DESIGN CHANGE CONTROLS AND CORRECTIVE ACTION SYSTEMS -
- 1. CAT Findings Incorrect mounting of diesel generator silencers.
Installation of ASME Class 3 orifice plates in ASME Class 2 lines.
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Inadequate corrective action being taken to preclude repetition of non-conformances or to properly disposition existing nonconformances.
- 2. Assessment The mounting of the diesel generator silencers was in accordance with the manufacturer's installation direction.
However, the design was found to be deficient. This problem has been identified by the CAT at other facilities.
The improper installation of Class 3 orifices in a Class 2 line was a result of an engineering specification error and it is possible the licensee would have identified the error during its ASME document review.
The necessity to continuously review the licensee's adequacy for corrective action is common to many construction sites.
- 3. Recommendation The regional inspectors should review previous CAT construction appraisal reports to better assist them in identifying deficiencies.
G. PROJECT CONSTRUCTION CCHTROLS
- 1. CAT Findings The GSU quality assurance audit section needs to periodically review its audit program.
GSU needs to develop and implement a quality concern program. l
- 2. Assessment The overall audit program for River Bend was adequate and failure to detect some missing audit criteria is not unexpected. The ,
failure of GSU to audit the engineering activities at Stone and '
Webster - Toronto will be addressed by the Vendor Program Branch.
The lack of a GSU quality concern program at River Bend has been the subject of prior conversations between GSU and the Region IV Regional Administrator.
- 3. Recommendation ~
The Construction Inspection Procedures for these areas are evaluated to be adequate for their intended s: ope.
IV. OVERALL ASSESSMENT CONCLUSIONS The implementation of the Construction Program Inspection Procedures at the River Bend Station was satisfactory. The majority of the CAT findings or related findings were identified by the Region. Those CAT findings not specifically identified by the Region will be the subject of evaluation by the Reactor Construction Programs Branch for possible specific inclusion in the current inspection procedures.
Those CAT findings that relate to the Vendor Program Branch will be trans-mitted for their evaluation and possible inclusion in their activities.
It is recommended that the previous CAT reports be made available to the Resident Inspectors for their review for possible applicability of the findings to their specific construction site.
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AppEN0!X A EXECUTIVE
SUMMARY
An announced Construction Appraisal Team (CAT) inspection was conducted at the River 1984 Bend Station during the period July 30iAugust 10 and August 20-31, Overall Conclusions It is the conclusion of the Construction Appraisal Team that the hardware, docu-mentation for construction activities, and project construction controls were generally in accordance with requirements, commitments and principles of prudent management. However, the team did identify a number of construction 1 program weaknesses that require menagement attention. These are:
1.
The inspection program, in the area of cable and raceway separation deficiency identification, requires improvement.
A number of cable and raceway separation deficiencies were identified by the NRC CAT in raceway and cable which had been previously inspected by site Field Quality Control.
2.
Numerous cable tray supports did not meet the drawing configurations that were utilized for determining support loading. 1
- 3. {
The applicant failed to consider the generic implications of identified deficiencies.
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i An identified problem with incompatability of non-ASME l snubber assemblies was not investigated to determine application to ASME snubbers, and a specification change requiring the installation of a fire barrier installedseal for fire dampers and accepted hardware. was not specified as applicable to previously 4
Imp.lementation of FSAR and procedural engineering requirements were not consistently control met in producing of hydrogen the areasmaterials.
of cable tray fill, cable spacing and -
I in sumary, the identified weaknesses require increased attention by management l to assure that completed installations meet design requirements. ;
AREAS INSPECTED AND RESULTS ~U Electrical and Instrumentation Construction ~
The majority of the electrical and instrumentation samples were found to meet I the appropriate design and construction requirements. However, deficiencies were NRC reviewidentified in several areas including items which will require additional and analysis.
Although not extensive, a number of cable and raceway separation deficiencies were in thisidentified, area wasandnotitfully waseffective.
determined that the applicant's inspection program Additional information is also required A-1
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'y regarding qualification and NRC approval of fire barrier materials used in cable wrap applications.
Implementation of FSAR and procedural engineering requirements were not consistently performed in the electrical area. Examples include failure to implement requirements limiting the use of hydrogen generating materials inside the containment drywell and failure to properly. incorporate FSAR requirements for items such as tray fill and cable spacing irito quality control procedures.
A number of cable tray supports did not meet the drawing configurations that were used for detemining support loading.
Several discrepancies were found in equipment environmental qualification reports indicating that review of reports of this type requires improvement.
The Class 1E 125 volt batteries had been charged and turned over to the startup organization even though the battery room ventilation systems were still urder construction and not in operation. This indicates that additional management attention is required for the control and maintenance of completed equipment turned over to startup.
l'echanical Construction The mechanical equipment and HVAC supports / restraints were found to be constructed in accordance with applicable requirements. Although discrepancies were noted on piping, pipe supports and restraints, concrete expansion anchors and HVAC ducting and accessories, no serious technical deficiencies were observed.
Several instances were observed where engineering dispositions on Nonconfonnance and Disposition Reports and Engineering _and Design Coordination Reports were not as thorough or extensive as necessary to address generic considerations of identified hardware deficiencies. Lack of thoroughness by engineers and-QA reviewers in this area could allow potentially significant safety issues to'-
be overlooked or inadequately resolved. Lack of attention to detail and poor construction practices with regard to installed and accepted hardware was evident.
Problems were identified by the NRC CAT with pipe support / restraint fastener i locking eechanisms, improper protection and misuse of pipe supports and the '
number of interdisciplinary clearance problems that had not been pre-authorized by engineering.
Welding and Nondestructive Examination ,
Welding and nondestructive examination activities were generally found to be in accordance with applicable codes and specifications. Howeve r,'several discrepancies were identified concerning film supplied by a piping vendor.
The applicant had previously reported similar problems to the NRC and the NRC CAT believes that the applicant should review additional radiographic packages in order to assure that discrepancies identified by both the applicant and the NRC constitute isolated cases.
In addition, some discrepancies were also identified during the inspection of vendor equipment and review of vendor film. The applicant has comitted to reviewing these discrepancies and the NRC will assess the results of this review.
A-2
.c Civil and Structural Construction Concrete quality, Cadwelding and Concrete Material Certificaticn were found to be acceptable.
cesign drawings. Rebar appeared to be placed in accordance with the, in gene two cracks in the concrete, and Roto Foam, debris an ant 1 solationactivities.
inspection joints (rattle spaces) are indicative of a need for improve ment in the Structural steel member size, configuration and connections were g found to be acceptable.
accordance with the design Two steel connections drawings wereevaluated and are being found notby toS&W.
be in These are also program. indications of a need for improvement in the construction inspe A significant number of high* strength bolts in the Reactor Building ral struc steel connections were found to be below minimum torque values.
that these bolts do not have the bolt preload required by AISC specifiThis indic cations.
Material Traceability and Controls in general, the project traceability and controls program was found to be acceptable.
A few deficiencies were found by the NRC CAT in the material j traceability and control of some safety-related fasteners :
, piping flange components and environmental control of weld filler material storage ovens Work or rework of some flange joints was being accomplished or without Q; engineering concurrence or knowledge which also resulted in a loss o control.
_Desian Chance Control determined to be generally in conformance n s.
, was with app number of isolated (non-generic) discrepucies were identified , of which the A
most significant were incorrect mounting of diesel generator silencers c an install'ation of ASME Class 3 orifice plates in an ASME Class .
2 line deficiencies were identified which could be generic; two Three .
ofencies these defici concerned failure to check and independently to release of design information to Construction. review design calculations i.'
E&DCRs to identify nonconfomances. The third was the use of Corrective Action Systems
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Disposition Reports to identifyIn general, the corrective action progr evaluate and correct nonconforming conditions was action found was beingtotaken be acceptable to preclude re excep,t that in certain instancesveinadequa dispose of existing nonconformances, petition of nonconfomances or to properly project Construction Controls The overall project construction contro"Is were found toure be adequate that construction and test activities will meet quality requirements . Specific A-3
management review of important quality The GSV quality assuranc5; control reports Project e improved.
program to make sure that all scheduled audit areas have actuallau An improvedand proceduralized, and more comprehensive quality concern implemented.
y been program need addressed.
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APPENDIX 8 POTENTIAL ENFORCEMENT ACTIONS__
As a result of the NRC CAT inspection of July 30 toand August 10 to August 31, 1984, the following items have bee August 20 Potential Enforcement Actions (section referencen referred to Region IV as of the inspection report): s"are to the detailed portion 1.
Assurance Manual (NOAM) Quality Assurance
, the applicant uality Pro Program management in that certain quality tr'ending review. document y Assurance receive adequate (section IX.B.2) 2.
design control has not been maintained as the ao ,
a.
Failed to verify adequacy of design.
does not represent as-built configuratiors.which Building ca
- b. (Section II.B.1)
Failed to properly translate FSAR requirements for items such cable tray fill, cable spacing and control of aluminum s perman plant materials inside of the containment tions, drawings, procedures and instructions.
drywell, -
into specific t
and II.B.2) (Sections II.B.1
' i 3.
reasures failed to assure that procedures and dr{
were used at the location where the prescribed activity isinpe f, includin '
that nine of the 37 inspection reports on anchor rand onned high had the incorrect revision of either the drawing or the prostrength bo on.them.
(Sections !!!.B.3 and V'B.2) cedure identified 4
Contrary to 10 CFR 50, Appendix B, Criterion X i cant failed to provide an adequate inspection p,rogram in that:and GSU '
a.
accomplished in accordance with the, criterik applicable procedures. n (Sectiori II.B.1) !
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Safety-related ASME class pipe support / restraints n have not' b constructed (SectionIll.B.2)and inspected in accordance with design requiremen .
5.
Contrary to 10 CFR 50, Appendix B Criterion XVI, and GSU n the applicant's program has failed to assure that conditions -
to quality have been promptly identified and adverse corrected in th ,
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i An identified problem with non-ASME snubber as semblies was not I assemblies supplied by the same vendors. snubber inves
- b. (Section Ill.B.2)
A new specification. requirement for the use of fire b s around tire damper to wall joints was notarrier sealant clearly identifi d backfitted III.B.5) to previously installed ano-accepted r ware.
e toha bed i (Section '
- c. Inadequate correct of nonconformances.ive action-is being taken to preclude repetitio i (Section VIII.B.1) t l
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[& #* Cut g 4'o UNITED STATES f j >N ".- (f( gr NUCLEAR REGULATORY COMMISSION s# REGION V 9 o, ( ' # 1450 MARIA LANE, SulTE 210 g % c ,o[fE WA LNUT CREEK, CALIFORNIA 94596 JUN 2 4198$
MEMORANDUM FOR: J. B. Martin, Regional Administrator FROM: D. F. Kirsch, Acting Director Division of Reactor Safety & Projects
SUBJECT:
CORRECTIVE ACTIONS: IE ASSESSMENT OF QA PROGRAM DESCRIPTION CHANGES By memorandum dated May 15, 1985, f rom B. Grimes to J. Martin, IE informed Region V of the results of the March 28 assessment of Region V's review of licensee's QAPD changes. The conclusion was that Region V was performing an effective and timely review of QAPD changes consistent with the 10 CFR 50.54 change rule and draft IE Inspection Procedure 35001. Three minor issues were raised in the report, nene of which require a response to IE. One of these was characterized as a generic concern to be further evaluated and commented on in a su= mary report for all five regions. The three minor issues and our corrective actions are:
- 1. Finding: Region V is considering an accounting method that would satisfy the LFMB memorandum (February 7,1985) concerning the review of QAPD changes.
Corrective Action: The corrective action (pertainino,,to the tracking of time expended in reviewing each QAPD change) had been taken prior to the assessment. It involves receiving a TAC number from DRMA for each QAPD change review, and entering the QAPD change action in the Operating Plan for tracking and accountability. The TAC number is used to record and account for all time expended on the reviews and is the source of information retrieved and reported to the LFMB for fee billing purposes.
- 2. Finding: Region V is in the process of developing a procedure describing the review process to provide additional assurance that reviews are consistent with respect to the required depth of review and the degree and method of documenting the results. (IE vants to review the procedure for consistency among Regions and to help in developing a final version of IP 35001).
1 Corrective Action: A copy of the Region III procedure has been l received. It will be used as a model in developing our procedure.
This action vill be completed by July 17 and a copy will be sent to .
v IE for their review. '
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