ML20235G849
| ML20235G849 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 09/24/1987 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8709300256 | |
| Download: ML20235G849 (2) | |
Text
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i SEP 2 41987 In Reply Refer To:
3
_3 Docket:
50-458 Gulf States Utilities ATTN: Mr. James C. Deddens Senior Vice President, (RBNG)
Nuclear Licensing P. 0. Box 220 St. Francisville, Louisiana 70775 Gentlemen:
This forwards, for your information, a copy of an internal NRC review of inspection activities at River Bend. The report is being released to Public Document Rooms today.
The report documents the NRC internal review of the scope and depth of the construction inspection program conducted by the NRC at River Bend. This review was initiated as a followup to a previous review of Region IV inspection act1vities at another site.
Press reports that discussed this review could have been construed as meaning that River Bend would be the subject of a reinspection.
Since this was not the case, we have forwarded the
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attached to you for information.
i Sincerely,
/s Robert D. Martin Regional Administrator
Attachment:
As stated cc w/ attachment:
Gulf States Utilities ATTN:
J. E. Booker, Manager-River Bend Oversight P. O. Box 2951 Beaumont, Texas 77704 Louisiana State University, Government Documents Department Louisiana Radiation Control Program Director bec:
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DRSP Resident Inspector R.;D. Martin, RA Section. Chief (RPB/A)
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MEMCRANDUM FOP.:
Chairman Zech Commissioner Ecberts Commissioner Bernthal Commissioner Carr Commissioner Rogers FROM:
Victor Stello. Jr.
Executive Directer for Operations SUBJECT ASSESSMENT OF THE NRC CONSTRUCTION INSPECTION PROGRAM AT RIVER BEND By memorandum dated May 12, 1987. Chairman Zech identified those recommendations pursuant to the OIA and Comanche Peak Review Group reports that have been approved by the Comission.
Item No. 3 of Chairman Zech's memorandum states:
3.
NRR should examine, in more detail, the inspection records for a facility within Region IV which did not receive as much attention from either NPC or utility conducted efforts.
If the results of such review require, further staff reviews of other plants should be performed.
The enclosure to this memorandum provides the results of a task group review of the construction inspection program conducted for the River Bend facility.
The overall conclusion reached by the task group is that the construction inspection program was adequately implegtgd b egion IV at River Bend, lemn hg, Victor St
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7 Executive Director for Operations
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Enclosure:
Review of the NRC Reactor Construction Inspection Program at River Bend cc: SECY OGC NWlh0f){hM
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Septe-be
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' MEPORANDUM l FOP.: Chairman Zech Commissioner F.cberts
+
Commissioner Bernthal Commissioner Carr Commissioner Rogers o
FROM:
Victor'Stello, Jr.
Executive Directcr for Operations SUBJECT ASSESSMENT OF THE NRC CONSTRUCTION INSPECTION PROGRAM AT RIVER BEND
'By memorandum dated May 12, 1987, Chairman Zech identified those
-recommendations.. pursuant to the OIA and Comanche Peak Review Group < sports that have been. approved by the Commission.- Item No. 3 of Chairman Zech's memorandum states:
3.
NRR should examine, in more detail, the inspection records for a facility within Region IV which did not receive as much attention from either NRC or utility conducted efforts.
If the results of such review require, further staff reviews of other plants should be performed.
The enclosure to this memorandum provides the results of a task group review of the construction inspection program conducted for the River Bend facility.
The overall conclusion reached by the task group is that the construction inspection program was adequately implemgtgd b egion IV at River Bend.
18 m n Q Ta' -
Victor Ste o,- J r.
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Executive Director for Operations
Enclosure:
Review of the NRC Reactor Construction Inspection Program at River Bend cc: SECY OGC
- i REVIEW OF THE NRC CONSTRUCTION INSPECTION PROGRAM AT RIVER BEND i
1 PURPOSE j
To determine whether the NRC construction inspection program was l
I adequately implemented at River Bend.
2 BACKGROUND This review was conducted to address a conclusion contained in the report of the Comanche Peak Report Review Group, NUREG-1257.
The conclusion stated:
"The CPRRG's judgement is that broader implications are likely for facilities in Revion IV other than Comanche Peak.
Additional considerations may influence the significance of these implications." In Chairman Zech's memorandum to the EDO dated May 12, 1987, the staff was directed as follows: "NRR should examine, in more detail, the inspection records for a facility within Region IV which did not receive as much attention from either NRC or utility conducted efforts.
If the results of such review require, further staff reviews of other plants should be performed." In response to that request the 4
River Bend site was selected and a team was formed to perform the review.
3 APPROACH A plan for an assessment of implementation of the construction inspec-tion program at a selected Region IV plant was transmitted to the EDO by a memorandum from Thomas E. Murley dated June 9, 1987. The plan stated that the plant selected for the assessment should be one which has not been subjected to a substantial augmented inspection effort by NRC, or to a major corrective action program or verification program by the licensee.
In addition, for a meaningful comparison of up-to-date inspection program requirements, the plant should have been initially licensed within the past two to three years.
Based on those guidelines, the River Bend plant was selected for the assessment.
A task group was organized to perform the assessment. The task group consisted of an NRR Section Chief, with previous regional construction inspection program experience, as team leader; a Region IV representa-tive who is knowledgeable of the construction inspection program at River Bend; and two consultants with previous experience in the development and implementation of the current construction inspection program.
The task group assessment of the implementation of the NRC construction inspection progran, at the River Bend Project was conducted et the plant site, the Region IV offices, and the NRR offices.
The assessment included interviews with regional and licensee personnel and the in-depth review of applicable reports, computerized data, and personal files relating to the application of more than 11,000 manhours of inspection effort during the time period from 1977 to 1985.
Task group activities involved in the assessment of the inspection program data for River Bend included the following:
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ENCLOSURE
-REVIEW OF THE NRC REACTOR CONSTRUCTION INSPECTION PROGRAM AT RIVER BEND s.-
'NRR Review Task Group' J. E. Konklin, NRR, _ Task Group Leader J. P. Jaudon, Region IV i
R. F. Heishman, Consultant-R. A. Rohrbacher, Consultant I
Review of individual inspection module completion status as 1.
documented in the NRC Form 766 data files and comparison with the completion status shown in other data sources such as regional files, and reports submitted by the region prior to plant licensing.
Comparison of inspection hours reported in the 766 system for 2.
specific construction inspection areas with inspection hours expended in these areas at other plants during construction, both in Region IV and in other regions.
Verification, for a sample of inspection procedures, that the 3.
effort described in the inspection reports supports the status reported for the procedures in the 766 data.
Comparison of conclusions contained in HQ assessments of regional 4.
performance and in SALP ratings for River Bend with other records to determine whether the construction inspection program adequately emphasized increased inspection of problem areas.
Selection of a sample of open items from the records, including 5.
violations, unresolved items, bulletins, and construction deficiency reports, and verification that the selected open items were properly closed.
4
SUMMARY
AND CONCLUSION The task group's assessment resulted in the conclusion that the overall NRC Inspection Manual Chapter 2512 (construction) inspection program was adequately performed for the River Bend Project.
Although the task group identified specific areas in which some of the inspection attributes were not addressed, or in which inspections were not performed as often or as many times as required by the current program, the numbers and types of such inspection program discrepancies are not considered to be significant, and are similar to what would be expected from a review cf the NRC construction inspection program at other sites.
In some cases, the requirements of an earlier version of the inspection program used by the region as an allowed option were met, even though Evaluation all requirements of the current program were not completed.
of each major program area showed that adequate technical overview had been achieved, either by performance of other related inspections or by later verification that licensee activities had been satisfactorily accomplished.
5 OISCUSSION Description of the Construction Inspection Program 5.1 The primary objective of the construction inspection program is to f
ensure public health and safety through evaluation of the adequacy i -
1 of. licensee performance during construction. This is accomplished by determining licensee effectiveness in identifying conditions that may adversely affect operational safety and in achieving compliance with NRC requirements and licensee comitments.
This determination is used to establish' a basis for the issuance of an operating license (0L).
Information for evaluating licensee effectiveness is obtained by direct l
observation of work activities, by review of procedures and records, and I
by evaluation of licensee involvement and control over licensed activi-ties, including contractor performance.
All NRC inspection programs are based on the principle that the licensee is ultimately responsible for the safety of the nuclear facility, and j
that self-inspection programs will be established to ensure adequate construction. Through an independent sampling of licensee activities, NRC ensures by its inspections that this responsibility is carried
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out in an effective manner.
In general, during the construction phase,
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more emphasis is placed on direct inspection of work and hardware than j
on the review of procedures and records. The intent is to determine whether safety-related materials, components, structures, systems, and construction activities are technically adequate and in accordance with NRC requirements and licensee commitments.
Regional management is responsible for assuring that the requirements of the program have been 1
met through regional and HQ inspections, or are otherwise adequately dispositioned.
The Construction Inspection Program has not been a static program over l
the years, but has changed frequently to incorporate improvements and to respond to regulatory changes.
Prior to 1970, the AEC inspection program was based on hiring very experienced personnel and allowing them to inspect what they considered to be important to plant safety. As the number of facilities increased, the number of regulatory personnel also increased and it became necessary to provide more detailed guidance and inspection program requirements.
NRC Inspection Manual Chapter (MC) 2512 was issued in 1975 and has since been revised a number of times. Changes made to MC 2512 during the period 1976 through 1979 were relatively minor.
In 1978, a companion manual chapter, MC 2592, was issued for use by assigned resident inspectors. MC 2592 was heavily weighted towards observation of ongoing work. New QA inspection procedures were issued in 1980, and then in 1981 a " priority plan" was issued. The priority nian varied the inspec-tion emphasis on different facets of construction during the construc-tion period. For example, management control and effectiveness were given greater emphasis during early construction, QA/QC and work proce-dures and their implementation received greater attention when a parti-cular activity or area of construction was starting and, as work pro-gressed, more emphasis was placed on inspection of installed components, structures and systems. )-
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The use of the priority approach was optional but preferred whenever the entire construction inspection program could not be accomplished within a specific construction inspection area.
The priority plan could be' i
tailored to individual regional office construction inspection resources and the. number of plants involved.
The amount of inspection effort
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required to assure the same degree of confidence that construction is adequate varies from site to site.
Similarly, dif ferent typ'es of construction activity at the same site may require varying levels of effort'to provide the same degree of assurance of quality work. The intent of the priority inspection plan was to provide guidance and flexibility in the construction inspection pregram to accommodate the resource-restrictions.
Based on a number of identified problems at construction sites, signifi-cant changes were made to the MC 2512 program during 1982, 1983 and 1984. _The stated purpose of these changes was to increase the amount of hardware (observation of work) inspection to approximately 50% of the effort and to decrease the " paper" inspections (procedures and records reviews). - Also included was the deletion of the " priority program" and the combining of the MC 2512 and MC 2592 programs into a single program.
Emphasis was also placed on the early identification of problem areas.
Comprehensive reviews of programs and procedures are conducted as a result of identified hardware problems with the objective of determining the underlying cause or generic implications of the problems.
In following up identified problem areas, the emphasis is on focusing the licensee's efforts to arrive at long-term resolutions.
The regional offices are given the responsibility to assign inspection requirements to either the resident or regional inspectors consistent with the qualifications of the individual inspectors.
In general, the resident inspectors provide a greater degree of direct verification of licensee construction performance for all activities while the region based inspectors provide the necessary expertise to complete the specialized technical inspection requirements of the inspection program. - _
o 5.2 Regional Activities at River Bend As shown in Tables 5.3-1 and 5.3-2 below, the overall level of inspec-tion activity at River Bend by Region IV was normal for plants which were under construction during the same time period.
The inspection ef fort, however, was influenced by a number of limitations and events involving both River Bend and other plants in the region. The task group interviewed the involved Region IV personnel, including the project inspector, the section chief, the branch chief, and the projects division director, to obtain the region's perspective of the history of the NRC construction inspection program at River Bend.
Gulf States Utilities received the construction permit for River Bend Unit 1 on March 25, 1977.
Following completion of the site preparation work, including excavation and backfilling for the foundation system, the River Bend Project experienced a significant work stoppcge from early 1978 to near the end of 1979 because of the utility's cash flow situation.
Construction effectively resumed with the placemer.t of foundation concrete for the containment in January 1980.
Region IV dispatched a team of inspectors to observe the placement around the clock until completion.
Shortly after that effort at River Bend, Region IV began to experience a significant drain on its limited construction inspection resources, which consisted at the time of 8 to 10 inspectors with the appropriate construction discipline backgrounds. The drain was primarily caused by a sequence of events involving the South Texas Project, including a show cause order, a period of hearings, a work stoppage, a change in the architect-engineering company, and an in-depth review of the design and construction status of the plant.
The Region IV construction inspection 4
personnel were involved in those events for nearly two years, effectively reducing the inspection resources available for other plants under construction in the region.
In late 1981, Region IV cssigned the first full-time construction resident inspector to the River Bend site. That resident inspector transferred to an NRC HQ position in mid-1982, and was replaced by another construction resident inspector. That inspector retired in mid-1983.
A third resident construction inspector was assigned in late 1983, and remained at the site until June 1985, at which time construc-tion was essentially complete.
The record indicates that a major part of the River Bend construction inspection program was accomplished by resident inspectors prior to 1983, except for periodic team inspections to inspect specific areas.
I Examples of these team inspections are the concrete inspection in 1980 discussed above, a major QA program inspection in 1981, and a team inspection in 1983 to inspect welding and NDE, pipe supports and l
l electrical and instrumentation cable. The HQ CAT inspection in 1984 also provided coverage of a number of inspection areas.
Beginning in 1984, augmented inspection activities at Comanche Peak and Waterford, and increased inspection efforts required prior to the licensing of Wolf Creek, further impacted the rtgion's resources available for inspection at River Bend.
In late 1984, Region IV initiated a review of the River Bend 766 System data and inspection reports to determine which inspection areas and procedures should be addressed to complete the construction inspection program prior to plant licensing.
As a result of the review, the region identified a number of procedures that had not been completed, developed a plan, and subsequently imple-mented a program to complete the required inspections.
A substantial amount of inspection effort was expended by the region in these inspec-tion activities during 1985, prior to the OL date of Hovember 20, 1985.
As discussed later in this report, that increased inspection effort resulted in the adequate completion of the construction inspection program, although some inspection opportunities were missed and some inspections were performed later than intended by the program.
1 I --
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- 5. 3 Comparison of 766 System Data 5.3.1 River Bend vs. Other Facilities 1
l The task group obtained data from the 766 system in order to compare River Bend with other facilities, both in Region IV and in o.ther regions.
The sites were selected to include other single unit plants constructed during approximately the same time period as River Bend.
l The plants selected for the review are shown below.
Facility & Type CP Date OL Date Region River Bend (BWR) 3/25/77 11/20/85 IV Limerick 1 (BWR) 6/19/74 08/08/85 I
Hope Creek (BWR) 11/04/74 07/25/86 I
Wolf Creek (PWR) 05/17/77 06/04/85 IV l
Clinton (BWR) 02/24/76 04/17/87 III The total MC-2512 inspection hours were obtained for each plant; this data is included in Table 5.3-1.
The hours represent the total inspec-tion time entered into the 766 system with the construction program prefix and indicates the time spent on inspections required by MC 2512.
The results for the five plants are considered to be within a normal variation ranging from 9545 hours0.11 days <br />2.651 hours <br />0.0158 weeks <br />0.00363 months <br /> at Limerick to 15238 hours at Clinton.
River Bend falls in the middle of the range at 11485 hours.
Thus, the total construction inspection effort for River Bend appears to be normal.
The number of inspection hours each year for a six year period ending in the year of licensing is shown for the same plants in Table 5.3-2.
These numbers for River Bend also appear to be in the normal range.
The six major areas of construction inspection were selected for the comparison, and data was obtained for each plant in each of those areas.
This data is also shown in Table 5.3-1.
The six areas chosen for comparison were selected to represent the major technical inspection I
requirements.
The areas and related inspection procedures are listed I
below.
Sample Area Inspection Procedures (IPS)
Structural Concrete IP Numbers 46000 & 47000 Series Structural Steel and Supports IP Numbers 48000 Series Piping IP Numbers 49000 Series 1 L_______-.-_-----.
7 _ - --
Mechanical-Components
'IP Numbers 50000 Series Electrical & Instrumentation IP' Numbers 51000 & 52000 Series
. Welding & NDE
.IP. Numbers 55000 & 57000 Series
' The percentage of t'he total construction inspection hours which was expended in the sample areas varies'from 38% for Wolf Creek to 52%
for Hope. Creek, with River Bend being above the average at 48%. This I
percentage providesJan indi. cation of the relative inspection effort applied to procedures, work activities and records associated with major technical construction areas, as compared to inspection program activities associated with other areas such as meetings, status reporting, followup on corrective actions, and response to bulletins and circulars.
In conclusion._ the 766 system inspection data indicates that the NRC construction inspection effort at River Bend received approximately average inspection when compared to other facilities in Region IV and in other Regions.
5.3.2 Required Inspection vs. Inspections performed at River Bend The task group compared the 766 system data for inspections performed at River Bend to the inspection requirements of the current MC 2512-construction inspection program. Table 5.3-3, River Bend Construction Inspection Program Status, contains the results of the comparison.
As noted earlier, the MC 2512 program was issued for implementation in 1975 and has undergone a number of revisions since that time. There-fore, the construction inspection program which was performed at River Bend was not done to the same set of inspection procedures as those contained in the current MC 2512, but rather, to the versions of the program in effect at the times the inspections were performed. This difference is accommodated in Table'5.3-3 by showing the current construction inspection program procedures in the left-hand column, with other related procedures actually perfonned listed in the right-hand column.
The following specific procedures from the current inspection program were identified by the 766 System data as not having been accomplished during the construction inspection phase at River Bend.
Inspection Procedure Title Comments 46061 Masonry Construction SeeNote(1) 46071 Concrete Expansion SeeNote(1) l Anchors I
.I 35960 QA Program Evaluation SeeNote(2) of Engineering Service j
Organizations 50051 Reactor Vessel & Inter-See Note (3) nals - QA Review t
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50095 Spent Fuel Storage See Note (4)
Racks 55093B Reactor Vessel &. Inter-SeeNote(5) nals 63050 Containment Structural See Note.(6)
Integrity Test f
i 64051B Fire Protection &
See Note (7)
Protection Procedures 64053B Fire Loop Installation SeeNote(7)
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Note (1):- Inspection Procedure 46061 - Masonry Construction.
Inspection Procedure 46071 - Concrete Expansion Anchors.
Both of these inspection procedures were issued for the first time after the completion of the construction inspection program at River Bend.
However, both construction areas were inspected during the Construction Appraisal Team inspection at River Bend in 1984.
Note (2): Inspection Procedure 35960 - QA Program Evaluation of Engineering Service Organizations.
This inspection procedure is designated in MC 2512 for performance "as required," and is written to cover QA program reviews for engineer-ing service organizations other than the architect-engineer or the NSSS supplier. Discussions by the task group with the involved Region IV personnel indicated that the region s River Bend inspection program evaluation in 1984 (See Section 5.2 above) did not identify any other engineering service organizations with significant involvement in the construction activities at River Bend.
Note (3):
Inspection Procedure 50051 - Reactor Vessel & Incernals
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QA Review.
The task group's review of 766 system data indicated that this inspec-tion procedure was not completed. Discussions with Region IV personnel detemined that this fact was discovered after the reactor vessel was installed, which meant that the window for performing the inspection had j
passed. Related inspections involving work observations and record reviews were satisfactorily completed, which indicates that the area was inspected, but not the QA procedures. Based on the fact that this is a one-time installation, the task group concluded that an after-the-fact review of the QA procedures now would not generate useful information.
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i Note (4): Inspection Procedure 50095 - Spent Fuel Storage Racks.
No data was found to indicate that this area had been inspected.
This inspection procedure was initially issued in Change Notice (CN) 79-05, dated April 1, 1979. On September 15, 1981, CN 81-22 listed this procedure as low priority. A discussion of the inspection program priority system is contained in Section 5.1 above. The construction inspection program review performed by Region IV during I
L late 1984 listed this inspection procedure as needing further inspec-l tion, but that was not accomplished.
Site records indicate that the spent fuel racks were received on site during the period February 1984 i
to January 1985, and that installation was accomplished during the
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period July 1984 to June 1985.
Physical inspection of the installed racks at this point in time is not practicable.
Review of the licensee's installation records could provide some assurance' of quality.
Note (5):
Inspection Procedure 550938 - Reactor Vessel Internals (Welding).
This inspection procedure, which involves the observation of welding and associated activities, was issued on July 1, 1977, and remains today as a part of MC 2512.
However, during the construction inspec-tion program rewrite in 1983, it was intended that this procedure be deleted, since this effort is covered in the revised welding proce-dures.
In addition, during a site visit to River Bend, the task group interviewed Gulf States Utility, General Electric, and Stone &
Webster personnel and determined that the installation of the reactor vessel internals was accomplished-in the fabrication shop (CBIN) in Memphis, TN.
Thus the only welding of reactor vessel internals per-formed at the site was minor fitting and tack welding plus several minor modifications (Surveillance Brackets, Shroud Head Nuts, LPCI Flow Deflectors).
Completion of this inspection procedure was not necessary at River Bend.
Note (6):
Inspection Procedure 63050 - Containment Structural Integrity Test (SIT).
The 766 system data indicated that this inspection procedure had no hours charged against it and was not completed. The task group's review at the River Bend site identified that the SIT and the Containment Integrated Leak Rate Test (ILRT) were inspected during the period April 3-8, 1985 by two Region IV inspectors and that the inspection time was entered into the 766 system under the ILRT inspection procedure, which is part of the MC 2514 inspection A review of the inspection report (50-348/85-31) indicated program.
acceptable completion of the SIT inspection.
Note (7):
Inspection Procedure 640518 - Fire Prevention & Protection Procedures.
Inspection Procedure 64053B - Fire Prevention & Protection Fire Loop Installation.
Inspection Procedures 64051B and 64053B were issued by Change Notice 79-13, dated July 1,1979.
These procedures were replacements for Inspection Procedure 42051B. The 766 system data for River Bend indicates that 42051B and 420510 (resident's program) were partially completed, however, no time was charged to the 64000 series proce-dures.
No explanation for the incomplete inspection was found during this review.
The task group concluded that this is no longer a signi-ficant concern, since fire protection inspections were done under the MC 2513 (preoperational) inspection program, and fire protection inspection requirements for the operating plant are contained in MC 2515, and are being accomplished. _ _ _ _ _ _ _ _ - - _ _ _ _ _ - - -
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a 5.4 Review of Inspection Procedures The task group's effort to verify the adequacy of the NRC construction inspection program at River Bend included an in-depth review of inspec-tion requirements associated with various areas of construction. A sample of NRC inspection procedures was selected for the in-depth review. The sample was chosen so as to include a number of major construction areas and to be in sufficient depth to allow a determina-tion of adequacy.
The specific inspection procedures selected for the review sample were in the areas of Structural Concrete (Procedures 46051,46053,and46055),
Hechanical Components (Procedures 50071, 50073, 50075, and 50090), Welding and NDE (Procedures 55100 and 57070), Electrical and Instrumentation (Procedures 51051,51053,51055,51063,and52053),ContainmentPene-trations(Procedure 53053),ReactorVesselandInternals(Procedures 50053 and 50055), Verification of As-Builts (Procedure 37051), and In Depth QA Inspection of Performance (Procedure 35061).
The procedures listed in parentheses above following the selected construction areas are current NRC inspection procedures (IPs) associated with that activity. Completion data regarding these and other construc-I tion IPs used at River Bend are included in Table 5.3-3, River Bend Construction Inspection Program Status. The far right column of the table shows earlier versions of inspection procedures in effect during the construction phase at River Bend.
In this review, the task group compared inspection requirements in the selected sample of inspection procedures to the actual inspection performance as reported in NRC inspection reports. Initial inspection requirements were obtained from the current inspection procedures.
{
However, since construction at River Bend started before many of the current inspection procedures were issued, earlier versiuns of the program were also involved. A sample of 19 inspection procedures were selected for the review from the approximately 80 inspection procedures in the current construction inspection program (Refer to Table 3-3).
In some cases, it was necessary to track as many as ten different old and new inspection procedures through the construction inspection reports in order to verify the completion status of a single selected current inspection procedure. The total number of construction inspection reports covering the period from 1977 through 1985 was approximately 125, of which about 50 were reviewed as part of the procedure status verification process.
NRC construction inspection program (MC 2512) changes implemented during construction of River Bend complicated the review. Not all of the current program requirements are included in the earlier versions of the program. In addition, some of the current inspection procedures (for example, in the areas of welding, structural concrete, and electrical components and systems) require periodic inspections, whereas earlier versions generally required inspection of a fixed sample size.
As discussed in Section 5.1 above, an inspection priority plan was established in 1981 because, in some cases, limitations on construction inspection resources had precluded completion of all inspection proce-,
u
1 dures.
This plan allowed some NRC inspection procedure requirements to be omitted at the discretion of the regional office when inspection resources were inadequate. The issuance of MC 2592, which provided for a
increased construction inspection by resident inspectors (the "C" modules), further complicated the tracking of inspection requirements through the construction phase.
The comparison of inspection requirements in the selected sample of inspection procedures to the appropriate NRC inspection reports during g
this review indicated that the NRC construction inspection program at i
River Bend was adequately performed.
The review also provided addi-l tional confirmation that the 766 system data for River Bend is reasonably accurate.
In some areas, the River Bend NRC inspection reports reflect more than the required inspection effort.
However, in four instances, involving NRC Inspection Procedures 35061, 50053, 50075 and 51051, the record indicates that some specific inspection require-ments were not completed or performed as required by these current procedures.
The items not completed are:
Inspection Procedure 35061 - In-Depth QA Inspection of Performance.
This inspection procedure requires an annual inspection of specific QA Program elements, some of which could not be verified as having been accomplished from the review of inspection reports.
However, the total QA Program inspection effort reported by the region was sufficient to indicate that the intent of the inspection procedure was accomplished.
Inspection Procedure 50053 - Reactor Vessel and Internals - Work Observation. This inspection procedure requires that a number of activities be observed quarterly. The review of inspection reports indicated that not all of these requirements were met.
For example, one requirement was to check installed vessel protection quarterly; protec-tion was only documented as reviewed during 1983, the vessel was instal-led in 1981.
Inspection Procedure 50075 - Mechanical Components and Equipment. This inspection procedure requires that records of personnel qualifications (craft and QC) be reviewed on a sampling basis.
Inspection reports indicated that training and qualifications records for QC personnel were reviewed, but no indication of the review of craft training or quali-fication was found.
Inspection Procedure 51051 - Electrical Components and Systems. This inspection procedure requires that work procedures and inspection procedures for receiving, storage, handling, assembly, inspection, testing and change control be reviewed. The inspection reports did not indicate that the procedures related to receiving inspection, storage, handling and testing of electrical components had been inspected. There was, however, indication that work activities and records for this area had been inspected.
Based on the number of inspection procedures and inspection reports which were reviewed as part of the task group's sample, the above discrepancies between the recorded inspection effort and the current inspection program requirements appear to be of a number and signifi-cance which would be expected to result from a review of the construc-tion inspection program at other sites.
Changes in the inspection L-__-____
program from the procedures in place at the time of the region's inspec-tions to the current procedures, against which the task group's compari-son was made, explain some of the discrepancies.
The remaining discre-pancies are not considered to be significant.
5.5 Review of Open' Items
' Procedures.and systems used to maintain control of open items vary among the regions.. These systems have been developed over the years and are
- currently computer listings generally titled "Open Inspection Items" or "Open Items List." The task group's assessment of the River Bend construction inspection program included a review of a sample of open items selected from _a variety of sources, including open item lists.
maintained by various Region IV individuals and groups, the Construction
. Deficiency Report (CDR) listing, the IE Bulletin list (both the' region's andthelicensee's),andsomeitemsextracteddirectlyfrominspection reports.
Detailed information regarding the sample selected, and the results of the review, are contained in Table 5.5-1, Sample of-River Bend Open Items.
The sample selected by the task group included 11 noncompliance, 8 unresolved items,1 deviation, 2 followup items, 50 of approximately 100 CDRs, and 16 of 97 IE Bulletins. The time period covered by the sample was 1977 to 1985.
The task group was able to determine that all of the open items in the selected sample were closed, although-the path was sometimes indirect.
The review identified several open items that were adequately closed in reports other than those listed on the open item list, or that were closed even though listed as still open. In the area of construction i
deficiency reports, the task group found that the region not only
. inspected all items detemined by the licensee to be reportable, but also a large fraction of those items reported to the region as poten-tially reportable which the licensee subsequently determined to not be l
reportable. Some of the.CDRs reviewed by the task group were based on.
10 CFR 21 reports from vendors. The task group also verified that all IE l
Bulletins issued in-calendar years 1977 to 1986 were on the region's and licensee's lists and had been accounted for in the respective reviews.
In addition to sampling the open items list, the task group also reviewed a listing of allegations from the Allegation Tracking System to verify that the region had considered and closed out allegations received during the construction phase. That verification was accomplished. Specific allegations from the list were not selected for in-depth review, since many of the issues had been the subject of prior investigations, and the task group considered that a sufficient sample to verify open item closecut could be obtained without the selection of allegations for the sample.
The results of the task group's review of open items indicates that this part of the construction inspection program was satisfactorily completed by Region IV for the River Bend facility prior to operating license issuance. L__-____-_____
I 1
- 5. 6 Previous Assessments' l
5.6.1. Systematic Assessment of Licensee Perftermance (SALP)
]
There were four regular SALP reports which covered construction activities at River 8end.
In addition, there was a " regional evaluation of licensee performance" for the period September 1, 1979 to August 31, 1980, which occurred just prior to the establishment of the SALP program.
These reports were:
j SALP Report Number Dates Covered 50-458/80-10 September 1, 1979 - August 31, 1980 l
.SALP 1 50-458/81-15 July 1, 1980 - June 30, 1981 j
SALP 2 50-458/82-12 September 1, 1981 - August 31, 1982 i
SALP 3 50-458/83-15 September 1, 1982 - July 31, 1983 SALP 4 50-458/84-40 August 1, 1983 - December 31, 1984 i
These reports are hereafter called SALP:1, SALP 2, SALP 3, or SALP 4, as indicated above. The task group was unable to identify a reason for the gap between SALP 1 and.SALP 2; however, the gap did not have a significant effect on the conclusions which follow.
j River Bend was licensed (low power) on August 29, 1985. Construction i
activities between January 1, 1985, and operating license issuance were not addressed in the SALP report for the period which ended January 31, 1986 (SALP 5).
The reason given for this by one SALP' Board member was that construction was complete and an additional l
assessment was not an effective use of resources.
j l
Review of assigned SALP categories indicates that only cne Category 3 rating was ever given to River Bend. This was on SALP 1 for a failure to make reports required by 10 CFR 50.55(e) and to take effective corrective action.
Escalated enforcement action was taken l
in that case.
Each construction area is discussed below, including the implementa-tion of inspection activities, as reported in the River Bend SALP reports.
Soils and Foundations.
In SALP 1 this area was rated as Category 1.
SALP 1 also indicated that work in this functional area was complete. This functional area was not assessed in subsequent SALP reports.
Containment and Other Safety-Related Structures. This was assessed as Category 2 in SALP 1, SALP 2, and SALP 3.
It became a Category I rating in SALP 4.
There were no recommendations to increase inspec-tion activity beyond normal levels.
SALP 4 recommended reducing NRC activity in this functional area; however, by the end of the SALP 4 rating period, work in this area was essentially complete.
Piping Systems and Supports.
SALP 1 through SALP 4 rated this area as Category 2.
SALPs 3 and 4 recommended a normal level of inspec-tion in this functional area. Between SALP 3 and SALP 4 there were r l
. +
eight inspections, which is an average of more than one inspection per quarter.
Support Systems. This functional area was not assessed in SALP 1 or SALP 2.
It was rated as Category 2 in SALP 3 and SALP 4.
There were no recommendations of significance in this functional area.
Electrical Power and Distribution.
This functional area was rated as Category 2 in SALP 1 through SALP 4.
Inere were no recommendations to increase inspection activity above normal in this area until SALP 4, which recommended continuing the high level of inspection (ten inspec-tions of this area were conducted between SALP 3 and SALP 4).
The large number of inspections was related to work in progress during this period, concerns with separation between Class 1E cables, and the recommendations made in the functional area of Safety-Related Components.
Instrumentation and Control. This area was not assessed in either SALP 1 or SALP 2; it was rated as Category 2 in SALP 3 and SALP 4.
There were no recommendations of significance in this area.
Safety-Related Components. This functional area was not assessed in SALP 1; however, it was rated as Category 2 for SALPs 2 through 4.
SALP 3 recommended that inspection effort be focused on piping and electrical hookups. SALP 4 showed that only three inspections had been attributed to this functional area, but it also showed 18 inspections in the piping (8) and electrical (10) areas.
It appears that the recommendation for increased effort was effectively imple-mented by the inspections in the electrical and piping functional areas.
Corrective Action and Reporting.
SALP 1 rated this area as Category 3.
SALPs 2 and 3 rated it as Category 2, and SALP 4 placed it in Category 1.
Although SALP 1 discussed this area at length, recom-mendations of significance were not made in that report or in subse-l quent SALPs. The inspection activity in this area during tie assess-ment period for SALP-4 was high (eight inspections); this was primarily l
related to closing out the large number of construction deficiency reports that had been issued.
Quality Assurance.
This functional area was only assessed on SALPs 3 and 4.
It was rated as Category 2 in both instances. The only recommendation of significance in this area was to reduce the inspec-tion effort devoted to the programmatic aspects of QA, while main-taining the effort in other areas of QA and QC-.
A relevant fact is that the functional area of management control was rated as Category 1 in both SALP 3 and SALP 4.
Design Control. The functional area of design control was added i
as a part of SALPs 3 and 4.
SALP 3 recommended an in-depth review of design control both on-site and at the architect-engineer's offices.
l SALP 4 noted that there had been limited inspections of this area by the region, but that an Integrated Design Inspection (IDI) had been conducted by an IE team.
I 1 l
During the review of selected inspection reports, the task group identi-fied Inspection Report No. 50-458/80-10, which contains the results of the Region IV evaluation of licensee performance at River Bend for the period September 1, 1979 to August 31, 1980.
Significant areas noted in the report as requiring an increased inspection effort were the area of concrete activities and the area of quality assurance, management and training.
Review of subsequent inspection reports by the task group showed a significant amount of inspection in the concrete area during the period following the region's evaluation report.
In addition, a major team inspection involving 362 inspection hours by six inspectors was conducted at River Bend in February 1981 (Inspection Report No.
50-458/81-02).
That team inspection effectively covered the areas of l
quality assurance, management and training.
In conclusion, SALP reports for River Bend made few recommendations of significance (i.e., to increase inspection effort in specified functional areas). When recommendations were made, an appropriate inspection effort was completed.
The SALP process appears to have been adequately performed and to have contributed to the effective focusing of construction inspections.
1 5.6.2 Construction Appraisal Team (CAT) Assessment During July-August, 1984, an NRC HQ CAT inspection was performed at River Bend and Inspection Report No. 50-458/84-23 was issued in October 1984.
In accordance with SECY-82-150A, Region IV's implementation of the construction inspection program was also examined by the HQ team.
The results were documented in an assessment report transmitted to Region IV by J. G. Partlow in a memorandum dated June 21, 1985. The following excerpts from the memorandum summarize the results of the assessment:
"A review was made of RIV's inspection and SALP reports of the River Bend Station to identify those deficiencies that were previously identified by RIV inspectors. The inspection reports of 1979-1984, the 1982 and 1983 SALP reports, open items and violations were reviewed...
The inspection reports for 1983 and the 766 inspection data were analyzed and it was determined that approximately 1850 man hours of direct inspection effort were performed by Region IV at River Bend in 1983.
The inspection program was approximately 85 percent complete at the start of the CAT inspection. The total man hours and percent completion is comparable to other construction sites and Regional totals for the construction status of the River Bend construction effort.
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."
The results of the current review of the River Bend construction L
inspection program appear to be consistent with the CAT assessment.
l _ _ _ - _ _ _ _ _ _ _ _ _ _
e 5.6.3 IEAssessmentofRedionalperformance The NRC program offices are required to assess regional office performance in their areas of responsibility on a periodic basis.
Regional inspection programs were periodically assessed by the IE Division of Inspection Programs.
A memorandum from J. G. Partlow, Director, Division of Inspection Programs, IE, to Messrs. Denise and Bangart, Division Directors, Region IV, dated June 26, 1985, described the annual assessment of regional inspection activities.
The following extract from the assessment memo describes the results of the IE evaluation of the Region IV construction inspection program:
"The implementation of the construction inspection program at facilities in Region IV has been generally behind schedule and has in many instances required the use of other resources (regions, IE, NRR, and consultants) to verify the construction status (i.e., Wolf Creek, Comanche Peak, South Texas, and Waterford).
In addition, the letter of program status (per IP 94300) from the region on River Bend and the IE review of the River Bend inspection data indicates that little or no inspection time has been recorded for many inspection procedures, even though the total number of construction inspection hours (8250) for River Bend is above the average for
~
other similar plants.
Some of the procedures relate to major construction areas such as reactor coolant pressure boundary, safety-related piping, and reactor vessel and internals.
Discussions with regional personnel indicate that they are reviewing the status of inspections at River Bend to establish the inspection priorities. The region acknowledged that the 766 system had not been updated to reflect the inspection efforts of the past several months.
It appears that a consider-able amount of inspection effort will be required to complete the inspection program at River Bend.
The 30% of total construction inspection time recorded in the independent inspec-tion and followup areas is the lowest of all regions and is the approximate value expected.
The CAT inspection of River Bend showed that the region had previously identified many of the problem areas which were found in the CAT inspection."
The results of the current review of the River Bend construction program indicate that considerable effort was expended to complete the required inspection program and was generally successful. The regional review of the construction inspection progr6m at River Bend in late 1984 and early 1985, and the subsequent increased inspection effort was effective in completing most of the required inspections.
5.6.4 Review of IP 94300 Reports Inspection Procedure 94300, Status of Plant Readiness for an Operating License, requires the regional office to provide NRR with status reports starting approximately 90 days before the scheduled issuance of the operating license. These status reports culminate i
- . - (.,
s
- in a;1etter from'the Regional Administrator' recommending issuance of an operating license with-'any recommended temporary conditions.
In
.the case of River Bend, submittals from Region:IV to NRR relating the.
status of completion of 'the River Bend facility were reviewed by the!
l task group.
The initial report required by IP 943008 was submitted on March 22,
- 1985.
Subsequent updates were dated April 22, 1985; May 21, 1985;
' June 19, 1985;. and July 22, 1985.
Each of.the reports included
.information relative to the status of the MC 2512 inspection program,
~
and the July 22, 1985 report indicated that the MC 2512 inspection program had been completed.'
Review of inspection reports by the' task group' indicated that a significant amount of inspection was accomplished by the region during this period, and the review of the closeout of open inspection items-indicated that a' system'of control'of remaining inspection items was in place and functioning. The review of the IP 94300 reports indicates that the inspection program was completed in.
accordance;with the established inspection requirements.
i i
J :_.
.= _
e TABLE 5.5-1 SAMPLE OF RIVERBENDOPE% ITEMS 4
OPEN ITEM TYPE DESCRIPTION CLOSURE 79 U Control of rebar 80-01 Based on CDR.
r79-02 U
Certification of batch plant.
Shows as open on list.
Effectively closed in 80-01.
79-02 U
Fine aggregate selection Shows as open on list.
criteria.
Effectively closed in 80-01.
79-05 NC Certification of FQC personnel.
82-03
. 80-07 DEV Hot weather concreting.
82-03 81-02 NC Storage of safety equipment.
Shown on list as closed in 82-04. Actually closed in 82-08.
82-03 NC Storage of safety equipment.
Shown on. list as closed in 82-13. Actually-closed in 82-16.
84-02-V-03 NC Failure to meet radiographic 85-44 quality standards.
NDE van inspection.
84-13-U-01 0
Coaxial cable separating from 85-54 connectors.
Followup on previous actions not reported.
82-15-V-01 NC Welder failure to follow welding 85-14 procedure.
83-19-V-02 NC QC inspector failed to follow QC 85-14 procedure regarding signing for QC hold points (LP for welds).
84-04-V-02 NC Failure to control welding 84-24 material 84-16-V-01 NC Failure to effectively control 85-01 documents.
L 84-13-V-03 NC Failure to provide adequate 85-23 f
Class IE circuit separation.
85-01-V-02 NC Control of Nonconformance.
85-44 i
TABLE 5.5-1 SAMPLE OF RIVER BEND OPEN ITEMS OPEN ITEM TYPE DESCRIPTION CLOSURE i
?
85-22-0-16 0
Unreviewed safety questions per 85-45 j
83-08-U-01 U
Drawing not consistent with FSAR 83-19 84-24-V-01 NC Failure to maintain protective 84-28 environment.
84-25-U-01 U
QA audits of preventive 84-28 maintenance.
Upgraded to violation 84-28-V-01.
i 84-36-U-12 U
Errors in translation of E&DC 85-19 information.
j i
83-20-0-03 0
Procurement of spare parts from 85-23 GE.
85-01-U-03 U
Radiography defect.
85-26 DR 6 CDR Containment embedment plate "T" 81-12 welds.
DR 16 CDR Primary shield wall accident.
81-13 DR 31 CDR Limitorque valve motor operator 82-13 loose parts (limit switches)
DR 32 CDR Lack of full penetration welds -
82-14 pipe whip restraints.
DR 45 CDR Failure to meet specification 82-13 l
requirements for limited access welding.
DR 68 CDR Tectyl preservation used 85-30 in HPCS diesel.
DR 160 CDR Cable lead lug on high voltage 85-52 terminations.
DR 175/176 CDR APCS diesel generator batteries 85-37 procurement / cracked cells.
DR 177 CDR Pulling of neutron monitoring 85-44 system cables. _ _ - - _
4 - d g
TABLE 5.5-1 SAMPLE OF RIVER BEND OPER ITEMS I
l l
OPEN ITEM TYPE DESCRIPTION CLOSURE I
DR 188 CDR Socket weld flange hubs.
85-44 DR 190 CDR Gould fill pumps.
85-37 DR 194 CDR Jacket water pump, TDI diesel.
85-52 DR 199 CDR Separation of coaxial cable from 85-44 coaxial connectors.
i DR ?02 CDR Turbocharger thrust bearings, TDI 85-37 diesel.
DR 178 included DR 206 CDR Fuel cooling pumps and motors.
85-37 DR 215 CDR Inverters supplied by Elgar.
85-37 DR 216 CDR Conductors supplied by CONAX.
85-44 DR 218 CDR Boveri 5HK circuit breakers.
85-37 DR 222 CDR Relocation of 125V DC panel (HPCS) 85-44 DR 225 CDR MOV supplied by Velan with 85-37 oversized moters.
DR 227 CDR Rocker arm pushed sockets in TDI 85-37 diesels.
DR 228 CDR Linear indications in valve stems -
85-44 TDI diesels, i
DR 234 CDR Velan valves with short cap screws.
85-37 DR 240 CDR Westinghouse SA-1 differential relays. 85-37 DR 243 CDR Incompatible parts of component 85-37 supports.
1 DR 246 CDR Discrepancy in BF Shaw shop weld.
85-44 DR 249 CDR WJ Wooley personnel airlock doors.
85-37 l
DR 250 CDR Leakage in pressure transmitter 85-44 supplied by Rosemount.
DR 255 CDR GE supplied Topaz inverters.
85-44 _ - _ _ _ _ _ _ _ _ _
e en g
~
TABLE 5.5-1 SAMPLE OF RIVER BEND OPEN ITEMS OPEN ITEM TYPE DESCRIPTION CLOSURE DR 258 CDR Containment isolation valve leakage 85-52 rate.
DR 259 CDR Terminal blocks in MCC loss of 85-52 continuity.
DR 260 CDR CRD scram discharge volume drain line. 85-44 DR 261 CDR ITE Rowan auxiliary relays.
85-44 DR 263 CDR NGS-D1 Rockbestos cable.
85-44
. DR 265 CDR Shielded cable conductors in standby 85-37 diesel generator.
DR 270 CDR Gaps between containment penetration 85-44 pipe and restraint lugs.
DR 271 CDR CONAX containment penetrations for 85-44 RTD's.
DR 272 CDR Pipe hanger pins on recirculation pipe. 85-44 DR 277 CDR Zincchlorideinsolderflux(cable).
85-44 DR 281 CDR Charcoal filter units on concrete.
85-44 DR 289 CDR HPCS diesel generator voltage 85-53 regulator.
DR 291 CDR Crankshaft plug on TDI diesels.
85-37 DR 298 CDR Starting air check valve - TDI 85-44 diesels.
DR 299 CDR Fuel oil back pressure valve - TDI 85-44 diesels.
I DR 3D1 CDR M0V's supplied by Limitorque/Velan 85-44 f
(alteredtorqueswitchifmiterplate).
DR 3D3 CDR Fluid transients from water hammer, 85-44 j
damage to bellows expansion joints.
DR 310 CDR Roll pins from fuel rack control 85-44 lever to the control shaft.
Part 21 __-___-______a
~
4 a o l
l TABLE 5.5-1 SAMPLE OF RIVER BEND OPEN ITEMS i
OPEN ITEM TYPE DESCRIPTION CLOSURE DR 312 CDR Turbo charger shaft inactive bearing 85-52 on TDI Diesel B.
77-03 IEB On line testing of solid state 84-10 protection system.
78-01 IEB Flammable contact arm retainers in GE 84-08 CR 120A relays 78-06 IEB Defective Cutler-Hamer Type M 84-08 relays with DC coils.
80-20 IEB Failure of W Type W-2 spring return 84-08 to neutral control switches.
78-14 IEB Deterioration of BUNA-N components in 86-04 ASCO solenoids.
Material replaced.
l 79-09 IEB Failure of GE Type AK-2 circuit 85-30 breaker in a safety-related system.
Not in use at RB 80-11 IEB Masonry wall design.
85-30 Not applicable at RB 83-01 IEB Failure of trip breakers to open.
85-30 Not applicable at RB 83-07 IEB Fraudulent products sold by 85-30 Ray Miller - includes Supplement 1.
No Ray Miller l
2 products at RB 79-15 IEB Deep draft pump deficiencies.
85-43 79-27 IEB Loss of non Class-1E instrumentation 85-43 and control power system bus during operation.
80-16 IEB Potential misapplication of Rosemount 85-43 Model 1151 and 1152 pressure trans-Equipment modified transmitters with either A or D output codes.
84-03 IEB Refueling cavity water seal.
85-43 79-21 IEB Temperature effects on level 85-54 measurements.
Marginal writeup _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _