ML20238A535
| ML20238A535 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/11/1986 |
| From: | Goldberg S NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | Connelly S NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| Shared Package | |
| ML20237K807 | List:
|
| References | |
| NUDOCS 8708210003 | |
| Download: ML20238A535 (507) | |
Text
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l Sharon R. Connelly, Director MEMORANDUM FOR: Office of Inspector and Auditor ( Stephen Goldberg, Technical Assistant FROM: Office of Inspector and Auditor
SUBJECT:
CORRECTED TABLES IN THE COMANCHE PEAK INVESTIGATIVE REPORT i f two tables that Report. The Per appear our conversation, I have attached corrected c This was due to my t MM) concerning underlined changing' Tom words in the attachment Scarbrough's analysis are of mythework correctio (Attac Phillips issues.
; change the thrust of the report. being finalized because l I was unable to review these pages prior whento k place.the report 21, 1986, these tables were 1
i 1 was on leave during the week of Novemberdevelo i z.
Attachment:
[ Corrected Tables , 4 4 O l 9 8708210003 870312 PDR ADOCK 05000445 . 0 PDR l I
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Goldber_g Scarbrouch. ; Inspection. Report 85-07/0_5 '" I Inconclusive Inconclusive
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' Concerns'l and 2 Reactor Vessel Installation Inconclusive Inconclusive Concern 3 Audit of Reactor Vessel Installation
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No Violation Inconclusive . 3 Concern'4- l Spool Piece Marking 2 Questionable No Problem in Concern 5 Handling of Handling of 1 Cement Mixing Blades Violation l Violation Inspection Report 85-14/11 Questionable Inconclusive on Concerns 1, 2 and 3 . Concern I and 2. Records Shipment to Stone Questionable on Concern 3. Inconclusive- Inconclusive Concerns 4 and 5 Records Shipment of CB&I Questionable Inconclusive - Concern 6 , Temporary Storage of Records
- Inspection Report 85-16/13_ !
Questionable Inconclusive 2 and 3 Concerns 1,55(e) 10 CFR 50. Questionable Inconclusive .' Concern 4 - NAMCO Switches Not Properly i Identified Refer.to IE; Refer to IE;
- Concern 5: Inconclusive Inconclusive BISCO Seals I Inconclusivewhether - There was insufficient information to determine a violation was appropriate.
2 Questionable cite- aThere was sufficient information available to violation. l
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p s f/ . OIS$7 f ', [p'ce-c4L (s Fnciosure 1 INFORMATION FOR COMANCHE PEAK OIA pEPORT 86-10 REVIEW GROUP RG IE-01 Current NPC Construction Inspection Prograt The current NRC inspection program for construction of nuclear power p1'a nts is described in IE Manual Chapter (MC) 2512, Light Water Reactor Inspection Program - Construction Phase, dated December 12, 1986. The purpose of the construction inspection program is to verify through sampling inspections of programs, procedures, work activities and completed work, and records 'that safety-related materials, components, structures, and systems are in accordance with NRC reovirements and licensee commitments. The program described in the current issue of MC 2512 is considered to be the minimum required to achieve an acceptable level of confidence with regard to the quality of construction at a facility. Thr inspection program consists of 88 inspection procedures that cover the followirg 23 inspection areas:
- Management Meeting (3)* - Electrical Components & Systems (6)
- Quality Assurance (7) - Instrumentation Components & Systems (3)
- Organization and Administration (1)- - Containment Penetration (3)
- Design Changes and Modifications (2) - Welding & Nondestructive Examination (10) ,
- Fire Prevention and Protection (3) - Containment Structural Integrity Test (1)
- Number of individual procedures devoted to inspection arer.
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--Geotechnical/ Foundations - Low-level Radioactive Waste Storage (1)-
Activities.(3)
- Structural Concrete (5) - Inservice Inspection (4) j
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- Environmental-Protection (1) 1
- Containment (3)
- Structural Steel'and Supports (3) - Event. Reports (1) ,
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- Peactor Coolant Pressure Boundary'- - Planned & Nonroutine Activities (f) 1 Piping.(3) - Technical Activities of an
- Safety-Related Piping (3) Administrative Nature (4)
- Mechanical Components & Equipment (12)
'A tabulation of the 88 construction inspection procedures with condensed scheduling information and basic inspection requirements is provided in Table I, attached.
The' program recognizes that some inspections cannot be fully completed in certain situations. On the other hand, inspection requirements may be satisfied through.other inspection efforts. These other related programs such as the Construction App *aisal Team Inspection Prooram (MC 2920), Vendor Inspection Program (P.C 2700), SALP, and Integrated Design Inspections (IDI) may appropriately he used to assist the regions in meeting the MC 2512 requirements. In such cdses, regional management should review, approve and document these modifications to the program. The program provides a framework for the regions to manage their inspection efforts without being overly prescriptive. i l Many of the inspection procedures (such as those dealing with mechanical components, piping systems and electrical installations) that specify detailed examination of construction drawings, specifications and/or items of hardware, i
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! recuire the inspectors to select a certain sample size and/or select a representative sample for examination. Inspection sample sizes that are given in the inspection procedures ero considered reasonable efforts in terms of coverage and depth. Regional management has some flexibility to j modify specified sample sizes when their evaluation and judgment of site l circumstances would so indicate. With respect to " hold points", the NRC i routine construction inspection procedures do not require the stoppage of work at any specified points for the purpose of conducting inspections. Only in very unusual circumstances has the NRC thought it necessary to impose such requirements. Implementation of the routine construction inspection program should provide a reasonable basis upon which the region can make a judgment 4 as to plant quality. To adequately fulfill the requirements of the construction inspection program, effective planning is required so that the various inspection elements are completed in a reasonable time by properly cualified inspectors. The majority of the 88 inspection procedures are keyed to plant construction milestones or degree of plant completion. There are a total of 25 milestones, (see Table II attached) starting with the docketing of the CP application and ending with issuance of the operating license. The milestones are generally focused on major work elements. The inspection procedures that deal primarily with the technical areas such as geotechnical/ foundations, concrete, containment, structural steel, pipino, mechanical components, and electrical / instruction are of three types: ; (a) quality assurance program and procedure review, (b) observation of in-prccess and completed work, and (c) review of quality control records. The program requires that these inspections be implemented in proper secuence l
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' and at the proper phase of construction. The program requires that before a particular construction effort begins the NRC inspectur determines whether
.uality q assurance plans, instructions, and procedures for the particuler area of work have been established. Later, with the work in progress the inspector, 1
{ utilizing other procedures.in the series, observes the work and audits the resultino cuality control records for conformance to the established require- I ments Many of the procedures are required to be performed only once (under optimum conditions); there are others that are required to be performed several , times during a particular phase of construction. The current inspection program defined in MC 2512 has resulted from many improvements in both scope and depth. The program requires that inspectors with certain skills and. training perform the various required inspections and that they are fully knowledgeable about the facilities, processes and activities they inspect. Both on-the-job training and formal classroom training are used to provide the required level of knowledge about NRC quality assurance requirements, methods of inspection, and enforcement policies. The inspector training requirements are included in IE Training ana Qualification Journal, MC 1231. Section 0783 of MC 1231 provides the mininum requirements for construction resident inspectors. The IE Journal has served as a guideline for development of the Recional Training & Qualifications Journals. The IE Journal consists of a series of Qualification Guides which list the minimum knowledge levels and areas of study that must be ccmpleted. The areas include such items as Renional and Site Orientation, the Code of Federal Regulations, facility Safety Analysis Report, Pegulatory Guides, NPC and IE Panual Chapters, selected industry codes and standards, and onsite training including inspector accompaniments during actual plant inspections.
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1 The concept of " readiness reviews" is embodied in the construction inspection !
1 program-to the txtent that the licensee / contractor.QA plans, instructions and .) procedures that apply to the various types of construction work, are reviewed. prior to or shortly after the start of the activity. This is accomplished through implementation of the first of the three types of inspection procedures in the program. These procedures are identified by the number 1 at the end of I the 5 digit numbering system used, e.g., 45051, 46051, 47051, and so forth. 1 (This concept should not be confused with the " Readiness Review" programs ; i being implemented at Vogtle and WNP-3). i i QA Prccedures - Inspection Requirements The NRC inspection program recognizes the dominant role of quality assurance and quality control as it applies to the plant owner's corporate organization, { contractors and subcontractors, vendors and other engineering service organizations. The program includes 7 procedures that deal specifically with quality assurance. See Table I for list of procedures and brief description of basic requirements. Five of the quality assurance procedures are required to be implemented at all plants under construction; the other two are for specialized applications and may not always be required. Inspection procedure 35100, Review of OA Manual, is considered a generic i type procedure in that its completion is called for during implementation of l 12 construction inspection procedures that are directed towards determining I readiness to start certain work activities. The purpose of IP 35100 is to determine whether cuality assurance plans, instructions, and procedures for
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' specific safety-related activities have been established in the facility's cuality assurance OA manual and implementing procedures, and whether these documents conform to the QA program as described in Chapter 17 of the facility l Safety Analysis Peport (SAR). '
j Even though IP 35100 is. referenced in a construction inspection procedure, l the program does not require that it be repeated for a specific organization ' 1 at a site if the same QA procedures and sane licensee / contractor were previously examined.1/ In general, the inspection requirements of IP 35100 need be completed only once for each site organization associated with a particular construction activity. It should be noted, however, that different aspects, requirements, and procedures of the QA program may apply to different activities performed by one contractor et the same site. For example, inspection and documentation procedures related to welding may be considerehly different for reactor coolant pressure boundary pipe welding as compared to structural steel welding. If this is the case, parts of IP 35100 would be repeated. Generally, the various inspection procedures indicate that changes to the applicable QA Manual should be considered for review during any scheduled followup inspections in each area. If the changes to the QA Manual for a contractor have not been reviewed i for a relatively long period of time (e.g., over 2 years), the inspector should, as a minimum, determine whether any changes are appropriate and adequate, Appropriate parts cf IP 35100 should be perfomed at least once 1 for every construction contractor doina safety-related work at the site. 1 The completion of IP 35100 requirements are recorded against the particular l inspection procedures that references IP 35100, not against IP 35100 itself. l
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-IP 35060, Licensee fianagement of QA Activities, evaluates the effectiveness of licensees' management and implementation of corporate QA programs. This procedure concentrates on the corporate QA program in the areas of design, procurement, and audits as it affects construction. IP 35060 is to be completed every 18 months or at least twice during the construction phase, with the OA program review concentrating on substantive program changes made since the
. previous inspection. The inspection requirements include organizational j interfaces; review of procurement, design, and audit documents; review of OA reports; and interviews with QA management, design engineers, and others. l IP 35061, In-Depth OA Inspection of Performance, determines the effect of the
-licensees' 0A/0C programs on the quality of installations. The thrust of this inspection procedure is to determine that the program is working in a manner to ensure that site work is in accordance with NRC requirements and licensee commitments. The procedure is to be performed annually with each inspection covering at least two general construction areas such as civil, structural, piping, or electrical / instrumentation. Each construction area should be covered at least once. The inspection requirements include review of drawings, installation and OC procedures, nonconformance reports, and OA audits; interviews with craftsmen and OC inspectors; and inspection of field installations and equipment. Although these types of requirements are also evaluated under the inspection prncedures for each construction activity, there they are performed over the full duration of construction. IP 35061 ,
1 concentrates the requirements to present a comprehensive evaluation of QA/0C j effectiveness, and therefore is performed when the applicable ennstruction activity is well under way. ) l
., 7 Modifications to Routine Inspection Program Several programs or efforts exist which may alter the inspection requirements in MC 2512 as they were applied at Comanche Peak. The SALP program pemits an increase or decrease in emphasis for specific areas based on their SALP ratings. Individua1' procedures provide guidance for increased inspections based on SALP 3 ratings in their applicable construction area. Temporary Instructions (tis) have been-issued which focus inspection efforts into areas of known concern er problems, or nay detail changes to the routine inspection program before formal incorporation into MC 2512. Regicns may take credit for Headquarters or special inspection efforts which parallel MC 2512 inspection requirements without having to duplicate those efforts. Those items which may have had an affect on the NRC inspection program at Comanche Peak are described below:
- 1. Construction Appraisal Team Inspection (CAT): A CAT was conducted at Comanche Peak during January-February 1983. A multi-discipline team inspection which concentrates on hardware installation, the CAT also reviewed QC inspector effectiveness arc' qualifications, overall 0A program effectiveness, and design change control. The regions can, and should, take credit for those items of inspection covered by the CAT inspection that appropriately match requirements in the current program.
- 2. TI 2512/6 Special Inspections on Implementation of Licensee and Contractor Quality Assurance and Quality Control Programs, offective April 1, 1980 to October 1, 1982: This TI increased the routine inspection program emphasis or, the effective execution of QA/QC programs by recuiring a more indepth OC inspection of ongoine work.
3.- TI 2512/07, Pegional Construction Appraisal Team Inspections, effective since. February 25, 1981: The TI defines the QA, design control, project management and other inspection areas fer CAT inspections the regions
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choosa to conduct. (These inspections were not required at all constructionsites). a ( s 4 TI 2512/11, Construction Inspection Program: flew Initiatives, effective-February 21, 1984 to March 1, 1986: The TI provided quidance for j implementing new initie'ivos included in the FY84 bucget. The guidance 1 included increasing the inspection sample sizes for vcrious hardware f items; as-built inspections, and craftsman qualification interviews. (These requirements are tied to various inspection procedures implemented during tne effective period of the TI and have been incorporated into the current program). i
- 5. TI 2512/14, Second Resident Inspector for Construction Sites, effective
/pril d.1985 to April 4,1986: The TI provided quidance to the regions j for utilization of second construction resident inspectors included in FY85 budget. The suggestions included a more indepth routina inspection program concentrating on hardware installation, and a more indepth review cf craft and incpector qualification and trainino. (These requirements l 1 were to be implemented at the perogative of regional nanagement and have been incorporated into the current program). ]
- 6. IE Bulletins, Confirmatory Action Letters and Generic Letters are issued j
l by the f.'RC to licensees requiring them to take specific actions. The regions are required in most cases to review the actions taken and verify licensee performance in accordance with IP-92703.
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8 9 s.q : . ENCLOSURE 2 . l INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP RG IE 02
- 1. The responsibilities of regional inspectors, and supervisors and managers, with regard to inspection performance and reporting are discussed.in IE 1 i
Manual Chapters 2512. " Light Water Reactor Inspection Program - Construc-tion Phase," 0400, " Enforcement Program," and 0610 " Inspection Reports." Regions may develop their own procedures which amplify the IE and NRC l manuals and which provide additional region-specific requirements. MC 2512 provides the detailed requirements for performance of specific i inspections. Each inspector's job description and performance elements provide more detailed descriptions of the individual's responsibilities and authority. The position description, in particular, discusses ~ the responsibility of the inspector to " recommend" actions, and the level of supervision required. In accordance with MC 0400, the inspectors " identify violations of regula-tory requirements and recommend enforcement action." They also document 3 findings and enforcement actions and "recomend'tn appropriate regional management the severity level...." The inspectors also review responses to violations for adeouacy, and prepare evaluations of responses to civil penalties "for submittal to regional management." Regional supervisors and managers review the inspectors' findings and recommendations to detennine whether enforcement action should be taken, approve and sign non-escalated enforcement actions, and recomend escalated enforcement actions to the Regional Administrator. l ________--__j
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n = It is clear, both from the written requirements and from the practices- ) which have been followed in the regions .that the inspector's job is to _ gather information and'to identify safety concerns and potentia,1 viola-tions. Once his activities and findings are documented in a draft report, the material should receive a knowledgeable technical review, either by the supervisor or by an assigned reviewer. The cover page of the final version is then signed by the inspector and the supervisor. The. report is q then issued'by a letter which is signed by an individual who is at a sufficiently high management level to speak for the Regional Administra- ! l tor. Thereby, each report which is issued represents a collective or { institutional judgement; it represents not only the inspector's ,iedgement, l but also the judgement and conclusions of the agency.- There is no specific language in the IE Manual or, to the best of our knowledge, in the NRC Manual, which defines the meaning of signatures and concurrences on inspection reports. Present and past practice indicates that the inspector's signature shows his agreement that the report adequately represents his activities, findings and. concerns. Where more than one inspector is involved, each inspector's signature logically
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applies only to his own activities, findings and concerns. As noted l above, the supervisor's signature on the report cover page indicates that the report has received a knowledgeable technical review and that the i supervisor agrees with the content of the report. The management level signature on the letter which transmits the report to the licensee indi-cates that the report represents the collective or agency judgement relative to the inspection findings.
e , m i r 2. Differences of opinion between an inspector and his supervision can occur j l because of differences in value judgments, technical knowledge, work i
.1 experience, or interpretation of NRC policies and regulations. The j requirements for inspection performance are specified by regional supervi-J sion, the inspector's job description and performance elements and, for ]
i specific inspections, the inspection procedures contained in IE NC 2512. l The individual inspection procedures do provide leeway.with regard to implementation of specific inspection requirements. In particular, the independent inspection effort allows a relatively free choice of areas to be inspected. However, nothing in the IE manual permits an inspector to override his supervisor's directions with regard to the type, extent or ; depth of inspections to be performed. Differences between an inspector and his supervisor with regard to inspec-tion findings or report content should ideally be resolved based on ;
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informal discussions of the technical merits of the proposed findings and the technical and compositional qualities of the draft report. If those discussions fail to develop an agreement, the discussions should be elevated to sequentially higher management levels until.an agreement is reached or a management decision is made to proceed with a particular approach or characterization of the proposed findings. A manager at any level (Section Chief, Branch Chief, etc.) may choose to make such a l decision, thus ending the review process. Although the IE manual does not require documentation of such actions, good management practice dictates that supervisors should keep higher management informed of decisions which may be controversial. If the report is modified after it has been signed ' by the inspector, his supervisor, or any other participant, the signer l l
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( so-. should be given the' opportunity to reconsider his agreement with or 7c concurrence in the contents of the report. If an inspector should decide-not to sign the report, present NRC management practices provide for ! issuance of the report without the signature of the inspector. Although the present manual does not contain direction on the subject.-IE'
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presently has under development a manual chapter which addresses this issue. A copy will be provided to the review group when available. If the inspector continues to disagree with the approach or characterize-tion. decided upon by management, he may submit, in a written statement to his immediate supervisor, an expression of professional judgment which' differs from management's judgment. NRC Manual Chapter 4125." Differing l Professional Opinions," contains detailed procedures and requirements.for the expression and resolution of differing professional opinions concern-ing matters related to the agency's mission. 9 l 1
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'3 . Inspection findings or conclusions are classified as violations,
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deviations, or unresolved items. A violation is a failure by the licensee to comply with a specific NRC requirement such.as a rule, order, license condition, or technical specification. A deviation is a failure by the. licensee to satisfy a written commitment or to conform to an applicable ! code,~ standard or accepted industry practice, other than as required by licensing conditions. An unresolved item is an inspection concern about which additional information is required to determine whether or not it is a violation. In some cases this is because the licensee was not able j to provide sufficient information; in other cases the inspector may not have fully developed the facts. In addition, other types of designations,
. such as "open items," " deficiencies," or " inspector follow up items" are used by some regions, or by some HQ personnel, to provide a meails for follow up and closecut of concerns which do not fall in the above cate-gories.
t Regulatory requirements have varying degrees of safety significance.. In addition, violations of the requirements may be of varying importance and extent. Consequently, violations are categorized in terms of five levels of severity within the various activity areas, which include Facility Construction as one area. The severity levels are defined by example for the Facility Construction area in Supplement II of Appendix C to 10 CFR Port 2. Severity Level I and II violations are of very significant j regulatory concern. In general, violations that are included in these severity categories involve actual or high potential impact on the public. Severity Level III violations are cause for significant i concern. Severity Level IV violaticns are less serious but are of more 1 i __--_-_-___-______O
s than minor concern; i.e., if left uncorrected, they could lead to a more _ serious concern. Severity Level V violations are of minor safety or environmental concern. The great majority of violations are cited at Severity Levels IV and V.
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Normal-practice has been to classify most procedural or " paperwork" deficiencies in the Facility Construction area as Level V, unless the deficiency 'is of such an extent as to bring into serious question the quality of. installed equipment or structures. Isolated or relatively-minor " hardware" deficiencies are also normally classified as Level V. More serious or widespread " hardware" deficiencies which do not . warrant escalated enforcement action are classified as Level IV. It should be noted that the classification of a violation as Level IV or V is somewhat subjective and may vary between individual inspectors, supervision and regions. Each violation is characterized at the level best suited to the signifi-cance of the circumstances surrounding the violation. In detemining the significance of a violation., the following factors are normally con-sidered: a.. Did the violation actually or potentially increase the risk to the public health and safety? A violation that involves no actual threat but which had the potential to increase the risk to the public health and safety may be very significant, depending upon the degree of potential threat, its likelihood, and the possible consequences involved.
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- b. What was the root cause of the violation? Was it caused by training ;
i 1 deficiencies or inadequate procedures? Such violations may have 1 significance greater than the actual safety effect of the particular ! item involved in the violation.
- c. Is the violation an isolated incident or does it indicate programma-l tic breakdown? Programmatic breakdowns should be evaluated at higher severity levels than isolated incidents.
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- d. Was management aware of or involved in the violation and to what extent? Violations in which management was directly involved are more significant than those of which management was unaware.
- e. Did the violation involve willfulness and, if so, to what extent?
i Reporting violations may result from a licensee's not filing a required report, filing an incomplete or incorrect report, or filing a late report. A violation may be cited for a reporting failure if a licensee was aware ' of information which it was required to report but did not. A violation i will not usually be cited for a reporting failure if a licensee did not have the information that it was required to report, even if it should have had the information. However, if the licensee's failure to have the information was itself a violation of an NRC requirement then that requirement should be used as the basis for a violation. For example, if a licensee was required to conduct audits that would have produced the information and the licensee failed to conduct those audits, issuance of a violation for the latter failure would be appropriate. I l
. - i LWith regard to record-keeping violations, when a licensee is required to ;
perform a given task and to keep a record of having done so, but cannot produce that report, a violation should be cited for failure to keep the record. Failure to keep a required record may be considered supporting evidence that'a licensee did not perform a required task. However, without additional evidence that the task was not performed, the absence of the record is insufficient to support an violation for failure to perform the task. I A violation is not normally cited for a Level IV or V deficiency which is identified by the licensee; which is reported, if required; which has been or will be corrected within a reasonable time; and which is not a violation that should have been prevented by the licensee's corrective action for a previous violation. In addition, licensees are not ordinarily cited for violations resulting from matters not within their control, such as equipment failures that are not avoidable. l l 1 l
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'~ l 4 For units under construction, regional procedures require the tracking and j closeout of. all identified violations, deviations and unresolved items prior to specified. times related to licensing of the plant for operation. i
'Open items for Construction Facilities are not normally ranked in order of safety significance to determine the order of closecut. Instead, the f tems are categorized into groups which require closecut prior to a particular milestone, such as fuel load, initial criticality, .5% power or full power operation. The great majority of open items must be closed, in writing and normally in an inspection report,~ prior to issuance of the l operating license.
The regional office is responsible for the evaluation of licensee responses to enforcement actions, the preparation of any required answers to the responses, the status tracking of all open items, and the follow up i and closecut of the identified violations, deviations and unresolved I t items. IE Manual Chapter 0610 requires that inspection reports describe any significant licensee or vendor action on previously identified inspection findings, including a description of the findings and a statement as to whether each item remains "open" or is " closed." MC 0610 does not require l all open items to be tracked in an inspection report, only those items examined during the inspection. Similarly, Inspection Procedure 943008, ( (
" Operating License Issuance," of PC 2512 requires the review of required )
inspections at specified intervals prior to issuance of an operating license, the identification of all outstanding inspection areas and the l reasons fcr incompletion, identification of all uncorrected items of noncompliance and their status, and identification of all unresolved items
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, t. ..s and their status. Reports n accordance with IP 943008 are made by the ,
region.to'HQ at 90 day, 60 day, and 30 day intervals prior to initial operation.- In addition, IE performs-inspection program reviews for NT0L plants to verify that the inspection requirements of the applicable IE
, manual chapters have been completed prior to operation. The'results.of the NT0L reviews are factored into the periodic IE assessments of regional performance.
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- 5. A copy of each of the following applicable documents is attached for you l information and use-
)
i
- a. IE Manaual Chapter 2512; " Light Water Reactor Inspection Program -
Construction Phase." ! I
- b. IE Manual Chapter 0610; " Inspection Repo-ts."
- c. IE Manual Chapter 0400; " Enforcement Program."
- d. 10 CFR Part 2; " General Statement of Policy and Procedure for Enforcement."
- e. NRC Manual Chapter 4125; " Differing Professional Opinions."
- f. IE Manual Chapter 1245; " Inspector Qualifications."
9 Inspection Procedure 94300B; "0L Issuance." r i i
)
l l _ _ - - -
r, .
! 1, .m ,
-i ;-- 6. A copy.of each headquarters directed inspection is attached for your -j i
information: -j l i-I
- a. Inspection Report 50-445/03-10, 50-446/83-12; " Construction .
Appraisal Inspection." , , l l l
- b. Inspection Report 50-445/85-17, 50-446/85-14; " Inspection of Comanche Peak Design Adequacy Program Scope Validation Process and )
Review Checklist Development." 1 l 1
- c. Inspection Report 50-445/86-18, 50-446/86-15; " Inspection of j
.i l Comanche Peak Design Adequacy Program (DAP), Implementation of
]i l
Discipline Specific Action Plan (DSAP) X, Mechanical Systems and i l C0mponents."
- d. Inspection Report 50-445/86-17, 50-446/86-14; " Inspection of TERA's QA Program for the Comanche Peak Design Adequacy Program."
- e. Inspection Report 50-445/86/19, 50-446/86-16;~" Inspection of Comanche Peak Design Adequacy Program Implementation of Discipline Specific Action Plans VIII, IX and XI."
I
- i. 19 ( C Tbb ~ U J-a v JAN 8 387 1 Dk / ENCLOSURE 2 l
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP RG IE 02
-l1 l
- 1. The responsibilities of regional inspectors, and supervisors and managers,
]
with regard to inspection performance and reporting are discussed in IE Manual Chapters 2512, " Light Water Reactor Inspection Program - Construc-tion Phase." 0400, " Enforcement Program," and 0610 " Inspection Reports." Regions may develop their own procedures which amplify the IE and NRC manuals and which provide additional region-specific requirements. MC 2512 provides the detailed requirements for performance of specific inspections. Ecch inspector's job description and performance elements provide more detailed descriptions of the individual's responsibilities and authority. The position description, in particular, discusses the , responsibility of the inspector to " recommend" actions, and the level of supervision required. In accordance with MC 0400, the inspectors " identify violations of regula-tory requirements and recommend enforcement action," They also document findings and enforcement actions and " recommend to appropriate regional maragement the severity level .. . ." The inspectors also review responses to violations for adeouacy, and prepare evaluations of responses to civil penalties "for submittal to regional management." Regional supervisors and managers review the inspectors' findings and recommendations to determine whether enforcement action should be taken, approve and sign non-escalated enforcement actions, and recommend escalated enforcement actions to the Regional Administrator. 1
3 It is' clear, both from the written requirements and from the practices which have been followed in the regions, that the inspector's job is to gather information and to identify safety. concerns and potential viola-tions. Once his activities and findings are documented in a draft report, the material should receive a knowledgeable technical review, either by the supervisor or by an assigned reviewer. The cover page of the final version is then signed by the inspector and the supervisor. The report is then issued by a letter which is signed by an individual who is at a sufficiently high management level to speak for the Regional Administra- ' tor. Thereby, each report which is issued represents a collective or institutional judgement; it represents not only the inspector's judgement, but also the judgement and conclusions of the agency. There is no specific language in the IE Manual or, to the best of our , knowledoe, in the NRC Manual, which defines the meaning of signatures and concurrences on inspection reports. Present and past practice indicates that the inspector's signature shows his agreement that the report adequately represents his activities, findings and concerns. Where more than one inspector is involved, each inspector's signature logically applies only to his own activities, findings and concerns. As noted above, the supervisor's signature on the report cover page indicates that the report has received a knowledgeable technical review and that the supervisor agrees with the content of the report. The management level signature on the letter which transmits the report to the licensee indi-cates that the report represents the collective or agency judgement relative to the inspection findings.
Differences of opinion between an inspector and his supervision can occur 2. because of< differences in value judgments, technical knowledge, work experience, or interpretation of NRC policies and regulations. The requirements'for inspection performance are specified by regional supervi-sion, the inspector's job description and performance elements and, for specific inspections,'the inspection procedures. contained in IE MC 2512. The individual inspection ~ procedures do provide leeway with regard to implementation of specific inspection requirements. In particular, the independent inspection effort allows a relatively free choice of areas to be inspected. However, nothing in the IE manual permits an inspector to override his supervisor's directions with regard to the type, extent or depth of inspections to be performed. ; Differences between an inspector and his supervisor with regard to inspec-tion findings or report content should ideally be resolved based on informal discussions of the technical merits of the proposed findings and the technical and compositional qualities of the draft report. If those discussions fail te develop an agreement, the discussions should be elevated to sequentially higher management. levels until an agreement is reached or a management decision is made to proceed with a particular approach or characterization of the proposed findings. A manager at any level (Section Chief. Branch Chief, etc.) may choose to make such a decision, thus ending the review process. Although the IE manual does not require documentation of such actions, good management practice dictates that supervisors should keep higher management informed of decisions which may be controversial. If the report is modified after it has been signed by the inspector, his supervisor, or any other participant, the signer _ ___-___--_______-___a
- e. : !
1 l l should be given the opportunity to reconsider his agreement with or i concurrence in the contents of the rerort. If an inspector should decide' j not to sign the report, present NRC management practices provide for issuance of the report without the signature of the inspector. Although i the present manual does not contain direction on the subject, IE i presently has under development a manual chapter which addresses this
. issue. A copy will be provided to the review group when available.
l If the inspector continues to disagree with the approach or characterize-tion decided upon by management, he may submit, in a written statement to l his'immediate supervisor, an expression of professional judgment which differs from management's judgment. NRC Manual Chapter 4125 " Differing Professierf.1 Opinions," contains detailed procedures and requirements for the expression and resolution of differing professional opinions concern-ing matters related to the agency's mission. i
Hi y .- O I $' 3. Inspection findings or conclusions are classified as violations, g deviations, or unresolved items. A violation is a failure by the licensee [ to comply with a specific NRC requirement such as a rule, order, license condition, or .techni' cal specification. A deviation is a. failure by the licensee to satisfy a written commitment or to conform to an applicable , i code, standard or accepted industry practice, other than as required by { licensing conditions. An unresolved item is an inspection concern about
'which additional information is required to determine whether or not it is a violation. In some cases this is because the liter;see was not able to provide sufficient information; in other cases the inspector may not have fully developed the facts. In addition, other types of designations, such as '"open items," " deficiencies," or " inspector follow up items" are used by some regions, or by some H0 personnel, to provide a means for y follow up and closecut of concerns which do not fall in the above cate-gories.
t Regulatory requirements have varying' degrees of safety significance. In addition, violations of the requirements may be of varying importance and extent. Consequently, violations are categorized in terms of five levels of severity within the various activity areas, which include Facility Construction as one area. The severity levels are defined by example for the Facility Construction area in Supplement II of Appendix C to 10 CFR Part 2. Severity Level I and II violations are of very significant regulatory. concern. In general, violations that are included in these severity categories involve actual or high potential impact on the public. Severity Level III violations are cause for significant concern. Severity Level IV violations are less serious but are of more i l _ ------ ------_--- -- _ j
w .. . I
' than minor concern; i.e., if left uncorrected, they could lead to a more serious concern. Severity Leve? V violations are of minor safety or environmental concern. The great majority of violations are cited at Severity Levels IV and V.
1 Normal practice has been to classify most procedural or " paperwork" l deficiencies in the Facility Construction area as Level V unless the 4 deficiency is of such an extent as to bring into serious question the cuality of installed equipment or structures. Isolated or relatively minor "har4 rare" deficiencies are also normally classified as hvel V. More serious or widespread " hardware" deficiencies which do not warrant escalated enforcement action are classified as Level IV. It should be noted that the classification of a violation as level IV or V is somewhat subjective and may vary between individual inspectors, supervision and regions. Each'violat' ion is characterized at the level best suited to the signifi-cance of the circumstances surrounding the violation. In determining the significance of a violation, the following factors are normally con-sidered:
- a. Did the violation actually or potentially increase the risk to the public health and safety? A violation that involves no actual threat but which had the potential to increase the risk to the public health and safety may be very significant, depending upon the degree of potential threat, its likelihood, and the possible consequences involved.
i i
1 1-l" b. What was the root cause'of the violation? Was it caused by training l l deficiencies or inadequate procedures? Such violations may have l significance ' greater than the actual safety effect of the particular
~
. item involved in the violation.
- c. Is the violation an isolated incident or does it indicate programma-tir breakdown? ' Programmatic breakdowns should be evaluated at higher severity levels than isolated incidents.
)
- d. Was management aware of or involved in the violation and to what extent? Violations in which management was directly involved are more significant than those of which management was unaware.
- e. Did the violation involve willfviness and, if so, to what extent?
Reporting violations may result from a licensee's not filing a required report, filing an incomplete or incorrect report, or filing a late report. A violation may be cited for a reporting failure if a licensee was aware cf information which it was required to report but did not. A violation will not usually be cited for a reporting failure if a licensee did not have the information that it was required to report, even if it should have had the information. However, if the licensee's failure to have
>;he information was itself a violation of an NRC requirement then that q requirement should be used as the basis for a violation. For example, if a licensee was required to conduct audits that would have produced the
'information and the licensee failed to conduct those audits, issuance of ,
1 a violation for the latter failure would be appropriate.
.With regard to record-keeping violations, when a licensee is required to perform a'given task-and to keep a record of having done so, but cannot p_rodt'ce that report, a violation'should be cited for failure to keep the record. Failure to keep a required record may be considered' supporting evidence that a licensee did not perform a requ.i'ed task. However,
.without additional evidence'that the task was not performed, the absence of the record is insufficient to' support an violation for failure to perform the task.
A violation is not normally cited for a Level IV or V deficiency which ia identified by the licensee; which is reported, if required; which has_ been or will be corrected within a reasonable time; and which is not a violatinn that should have been prevented by the licensee's corrective action for a previous violation. In addition, licensees are not ordinarily cited for violations resulting from matters not within their control, such as equipment failures that are not avoidable. I i 1 1 _ ________-___________________ - D
4 For units under construction regional procedures require the tracking and closecut of all identified violations, deviations and unresolved items prior'to specified times related to licensing of.the plant for' operation. i Open items for Construction Facilities are not_normally ranked-in order of safety significance to determine the order of closecut. Instead, the items are categorized _into groups which require closecut prior to a particular. milestone, such as fuel load, initial criticality, 5%_ power or full power operation. The great majority of open items must be closed, in writing and normally in an inspection report, prior to issuance of the operating license. The regional office'is responsible for the evaluation of licensee responses to enforcement actions, the preparation of any required answers l to the responses, the status tracking of all open items, and the follow'up and closecut of the identified violations, deviations and unresolved i items. l l IE Manual Chapter 0610 requires that inspection reports describe any significant licensee or vendor action on previously identified inspection findings, including a description of the findings and a statement as to whether each item remtins "open" or is " closed." MC 0610 does not require all open items to be tracked in an inspection report, only those items 1 i examined during the inspection. Similarly, Inspection Procedure 94300B, l
" Operating License Issuance," of MC 2512 requires the review of required inspections at specified intervals prior to issuance of an operating license, the identification of all outstanding inspection areas and the reasons for incompletion, identification of all uncorrected items of noncompliance and their status, and identificczion of all unresolved items
and their status. Reports in accordance with IP 943008 are made'by the. region..to HQ at 90 day, 60 day, and 30 day intervals prior to initial
- operation. . In addition, IE performs inspection program reviews for NTOL
. plants to verify that the inspection requirements of the. applicable IE manual' chapters have been completed prior to operation. The results of the NT0L ' reviews are factored into the periodic IE assessments of regional
. performance. ) ;
i i i k i 1 _ _ _ _ _ _ = _ - - - _ _
/ ,
l
A copy of each of the following applicable' documents is attached for your 5.
information and use:
- a. IE Manaual Chapter 2512; " Light Water Reactor Inspection Program -
Construction Phase." l
- b. IE Manual Chapter 0610; Inspection Reports."
- c. IE Manual Chapter 0400; " Enforcement Program."
- d. 10 CFR Part 2; " General Statement of Policy and Procedure for Enforcement."
- e. NRC Manual Chapter 4125; " Differing Professional Opinions."
- f. IE Manual Chapter 1245; " Inspector Qualifications."
9 Inspection Procedure 94300B; "0L Issuance." l 1 1 l l _ _ _ - - - - - - _ _ _. _ l
^
- y
- 6. . A copy of each headquarters directed inspection is attached for your information:
- a. Inspection Report 50-445/83-10, 50-446/83-12; " Construction
, Appraisal Inspection."
- b. Inspection Report 50-445/85-17,'0-446/85-14; 5 "Inspectio'n of Comanche Peak Design Adequacy Program Scope Validation Process'and Review Checklist Development."
- c. Inspection Report 50-445/86-18, 50-446/86-15; " Inspection of Comanche Peak Design Adequacy Program (DAP), Implementation of -
Discipline Specific Action Plan-(DSAP) X, Mechanical Systems and C0mponents." l , d. Inspection Report 50-445/86-17, 50-446/86-14; " Inspection of TERA's QA Program for the Cnmanche Peak Design Adequacy Program." e
- e. Inspection Report 50-445/86/19, 50-446/86-16; " Inspection of Comanche Peak Design Adequacy Program Implementation of Discipline l Specific Action Plans VIII, IX and XI."
l 1 1 i
);
a C_ V_ bQr - 9 ( .
, JAN 3 iso 7 ENCLOSURE 2
'NFORMATIrN c0R COMANCHE PEAV OTA PEPORT 86-10 PEVIEW GROUP FG IE 02
- 1. The responsibilities of regional inspectors, and supervisors and managers, with regard to inspection performance and reporting are discussed in IE Manual Chapters 2E12, "Lignt Water Reactor Inspection Program - Construc-tien phase," 04C0, " Enforcement Program," and 0610 " Inspection Reports."
Pegions maj develop their own procedures which amplify the IE and NRC manuals and which provide additional region-specific requirements. PC 2512 provides the detailed requirements for per#ormance o'~ specific inspections. Each insnector's job descriptier and performance elements provide Fore detailed descriptions of the individual's responsibilities aac authority. The position cescriptien, in particular, discusses the responsibility of the inspector to " recommend" ections, and the level of supervisier recuired.
;n accordarce with PC C400, the inspectors " identify violations of regula-
*ory requirements end recommend en#crcement action." The" aise document firr'incs and enforcement nctions ar<' " recommend te appropriate regiona' meragement tne severity level...." Ice inspectort also review responsee to violations for adecuacy, and prepare evaluations of responses te civil i i
penalties "'or subtritta' to recirral management." Pegioral supervisors a::d ,nanaget review the inspectors' firdirgs ar.c recommendPtics.3 'o determine whether enforcement action should be taken, acerove and sign nen-escalated enforcement actions, ard reconmend escalat.ec en#0rcerent actierr *c -he Regionr1 Adminis+rator.
'It 'is clear, both'from the written requirements and from the practices which.have been followed in the. regions, that.the inspector's job is to gather information and to identify safety concerns and potential viola-tions. Once his activities and findings are documented ir a draft report,.
the material should receive a knowledgeable technical review, either by the supervisor or.by an assigned reviewer. The cover page of the final version is then signed by the inspector and the supervisor. .The report is o then issued by a-letter which is signed b'y an individual who is at 6 sufficiently bich . management level to speak for the Fegional Administra-tor. Thereby, each report which is issued represents a collective or institutional judgement; -it represents rot only the inspector's judgement, L tut also the judgement'and conclusions of the agency.. There is no specific languace in the IE Manual or, to theLbest of our inewledge, ir +he NRC Manual, which defines the meaning of sianatures and concurrences on inspection reports. Present and past practice indicates that the inseector's signature shows.his agreement that the report
-aceauately reeresents his activities, firdings and concerns. Where more than one inspector 3 involved, each instector's signature logically 4
a:clies only to his own activities, #indings and corcerns. As noted above, tha sucerviscr's signature on the report cover page indicates that the report has received a kncwledaeable technical review and that the supervisor agrees uith the content of the report. The manacement level sigrature on the letter which transmits the report to the licensee indi-cates that the report represents the collective or agency judgement relatdve to the irspection findings. _________E._.___ _ - . _ . - _ . - - - - _ --
1 f ;.: .
- 2. ' Differences'of opinicn between an inspector and his supervision can occur because of differences' in value judgments, technical knwledge, werk y
experierce, or. interpretation of TRC policies and regulations. The requirements for inspection performance are specified by regional supervi-sion .the inspector's job description and performance elements and, for specific inspections, the inspection procedures contained in IE MC 2512. l: The indiviouel inspection procedures do provide leeway with regard to implementation of specific inspection requirements.-In particular, the independent inspection effort allows a relatively free choice of areas to be inspected. Hcwever, nothing in the IE manual permits an inspector to override his supervisor's directions with renard to the type, extent or depth of inspections to be performed. Differences between an inspector and his supervisor with regard to inspec-tion findings or report centent should ideally be resolved based on informal discussions of the technical merits cf the proposeo findings and the technical and compositional qualities of the draft report. If those discussions fail te develop an agreement, the discussions shoulc he elevated to sequer;tially bicher management levels entil an agreement is reached cr a management decisic.n is made tc proceed with a particular approach or characterization of the prcposed firdings. A manager at any level (Section Chief. Branch Chief, etc.3 may choose to make such a decision, thus ending the rc iew process. Althnugh the IE manual does net
.rocuire documentattnn cf such actions, goed nanagement practice dictetes tFat supervisors should keep hicher management irFormed of cecisions which Irny be controversial. If the report is modified after it has been sioned by the inspecter, nis supervisor cr any other participant, the signer
1 1 l should be given the opportunity to reconsider his agreement with or concurrence in the contents of the report. If an inspector should decide not to sign the report, present NRC manacement practices provide for issuance of the report without the signature of the inspector. Although the present manual does not contain direction on the subject, IF l nresently has unde" development a manual chapter which addresses this issue. A copy will be previded to the review group when available. If the inspector contir.ues to disagree with the approach or characterize-t'en decided upon by manecement, be may submit, in a written statement to his immediate supervisor, an expression of professional juogment which differs from management's judgment. NRC Manual Chapter 4125 " Differing Professieral Cpinions," contairs detailed procedures and requirements for the expression and resolution of differing professional opinions concern-ing matters related to the agency's mission. l j 1
l L.' q 1
- 3. Inspection findings or conclusions are classified as violations, i deviations, or unresolved items. A violation is a failure by the licensee to comply with a specific NRC reycirement such as a rule, crder, license condition, or technical specification. A deviation is a failure by the licensee to satisfy a written ccmmitment c' to conforn to an applicable code, standard er accepted industry practice, other than as required by licensing conditions. An unresolved item is a? inspection concern about which additional information is required to cetermine whether or not it is a violation. In some cases this is because the licensee was not able to provide sufficient information; in other case- the inspector may not have fully developed the facts. In addition, other types of designations, such as "open items," " deficiencies," or "insoector follow up items" ara used by some regions, er by some PO personnel, to provide a means for follow up and closecut of concerrs which de not fall in the above cate-gories. -
Regulatcry requirements have varying decrees of safe.j significance. In addition, "iolations o' the reovirements may be of varyinc importance end extent. Consacuently, violations are categorized in terms of five levels ct severity within the varicus activi+y areas, which include Facility Construction as one area. The severity levels are defined by example fer
;he Facility fnnstruction area in Supplement II of Appendix C to *0 CFR Part ?. Severity level I and II violations are of very significant i regule+0'y concern. In caneral, violations that are ircluded in these 1
s n erity categcries irAcive actual er hioh potential impact en the rublic. Severity Level III violations are cavre for significant concern. Severity Level TV violaticns are less serious but ere of more l l f
1 I l 1 than minor concern; i.e., if lef t uncorrected, they could lead to a more l serious ~ concern. Severity Level V v401ations are of minor safety or I l enviror. mental concern. The great majority of violations are cited at ; Severity Levels IV and V.
)
l Normal practice has been to classify most procedural or "p.aperwork" deficiencies 4n the Facility Construction area as Level V, unless the deficiency is of such an extent as te bring into serious question the cuality of installec equipment or structures. Tsolated or relatively minor " hardware" deficiencies are also normally classified as level V. More serious or widespread " hardware" deficiencies which de not warrant escalated enfo cement action are classified as Leuci it. It should be noted that the classification of a viciation as i.evel IV or V is somewhat subjective and may vary between individual inspectors, supervision and regions. Each violation is characterized' at the level best suited to the signifi-cance of the circumstances surrouncina the violation 4 In determining the siprificance o# a violatier, the followirp factors are normally con-sicered:
- a. Did tFe violatier actually or potentially increase the risk to the pet'ic health and safety? A violation that involves no actual f j
i threat but which hac tha cotential to increase the rist t the l l public health and safety may be very significant, dependinr upon the I l cegree c# po+ential threat, its 14kelihood, anc the possible consequences involved. t
]
1 l 1 l l 1 I
- b. What was the root cause of the violation? Was it caused by training deficiencies or inadequate procedures? Such violations may have significance greater than the actual safety effect of the particular item involveo in the violation.
- c. Is the violation an isolated incident or does it indicate programna-tic breakdown? Programmatic breakdowns should be evaluated at higher severity levels than isolated incidents.
- d. Was ranagement aware of or involved in the violation and to whe+
extent? Violaticr.s in which nanagement was directly involved are more significant than these of which management was unaware.
- e. Did the violation involve willfulness and, if so, to what extent?
Ceporting violations may result from a licensee's not filing a reouirec repert, #iling an incorplete or incorrect repcrt, or filing a late repor+.
'4 "iolation may be cited for a reporting failure if a licensee was aware of information which it was recuired to report but did not. A violaticn sill not usually be citcd for a repcrting #ailtre if a licensee did not hFre the information that it was recuired to recort, even if it should nave had the inferration. However, if the licensee's failure to Fave the information was itsel# a violation of an NRC requirement then that requirement shcuid be used cs the basis for a violation. For example, if a litersee was recuired to conduct audits that would have producec tne information and the licensee feiled to ccctuct those audits, issuance of a violatien #or the latter failure would be appropr ate.d l
I l l l i
With regard to reccrd-keeping violations, when a licensee is required to , perform a given task and to keep a record of having dere sc, but cannot produce that report, a violation should be cited for failure to keep the ! record. Failure to keep a required record may be considered supporting evidence that a licensee did not perform a required task. However, without additional evidence that the task was not performed, the absence of the record is insufficient to support an violation for failure to perform the task. A violatdcr is not normally citec for a Level IV or V deficiency which is identified by the licensee; which is reported, if required; which has been or will te co'rected within a reasonable tiree; and which is not a violatirn that should have been prevented by the licensee's corrective action for a previous violation. In addition, licensees are net ordinarily cited for violations resulting from matters not within 'their I cnntrol, such as equipment failures that cre not avoidable. ' l I
t l, S L"
- d. : For units under construction, regional procedures require the tracking and s closeout.cf all identified violations, deviations and unresolved items n
. prior to.specified times releted .to licensing of the plant for operation.
Open items. for Construction Facilities are not normally ranked in order of safety significance to determine the order of closecut. Instead, the items are categorized into groups which require closecut prier to a carticular milestone, such as 'Lel load, initial criticality, 5% power or 1 full power operation. The great. majority of open items must be closed, in writino and normally in en inspection report, prior to. issuance of the L cperating license. The~' regional office is responsible- for the evaluation of licensee resernses to enforcement actions, the preparation o# any . required answers to the responses, the status tracking of all open items, and the follow up and clesecut of the identified violations, deviations and unresolved i dtees.
!E Manual' Chapter 0610 requires that inspection reports describe any significant licensee or vendor ection en creviously identified inspection findings, including a description of the findings and a statement as to wnether each item remains "open" or is " closed." MC 0610 does not reouire all open items to be tracked in an inspection report, oni,v those iters
~
examined during the insoection. Similarly, Inspection Procedure 04:006, "Coerat4ng License Isstance," nf MC 2512 reouiras the review of required f rspections at specified intervals prior to isruance of an operatinc l license, the identification of all outstanding inscec+ien areas and the reasons' for incenpletion, identification of all encSrrested items of ncnccmpliance anc their s*.atus, ano identification cf all unresolved items
. i l
1 and their status. Reports in accordance with IP 94300R are made by the j region to HQ at 90 day, 60 day, and 30 day intervals prior to initial operation. In addition, IE performs inspection program reviews for NTOL 1 plants to verify that the inspection requirerrents of the applicable TE i manual chapters have been completed prior to operation. The results of I the NTOL reviews are factored into the periodic IE assessments of regienal performance. i l i i
)
i i l i i i i l l l
- 5. A copy of each cf the follcring applicable documents is attached for your information and use:
- 6. IE Manaual Chapter 2512: " Light Water Reactor Inspection Program -
, Construction Phase."
- b. IE Marual Chapter 0610; "!rspection Peports."
- c. 'E Manual Chapter 0400; " Enforcement Prograrr."
- d. 10 CFR Part 2; " General Statement of Policy ard Procedure for Enforcement."
- e. 4FC Mariual Chapter 4125; " Differing Professional Opinions."
- f. TE Manual Chapter 1:45; " Inspector Qualifications."
- . Inspection Procedure 943009; "0L issuance."
1 l
)
l ( i l 1 l
I
. a 1
1
- 6. A copy of each headquarters directed inspection is attached for your I information:
l l t
- a. Inspection Report 50-445/83-10, 50-446/83-12; " Construction 1 Appraisal Inspection."
- b. Inspection Report 50-445/85-17, 50-446/85-14; " Inspection of Comanche Peak Design Adequacy Program Secre Validation Process and Review Checklist Development."
- c. !nspection Peport 50 445/86-18, 50-446/86-15; " Inspection of Comanche Peak Design Aceouacy Program (DAP}, Implementation of
?iscipline Srecific Action Plan (DSAP) X, Mechanical Systems and C0mponents."
- d. Inspection Repcrt 50-445/86-17, 50-446/86-14; ~" Inspection of TERA's OA Progran #nr the Comanche Peak Cesign Adecuacy Program."
I
- e. Irspection Peport 50 /ZE/86/19, 50-446/86-16; " Inspection of Comanche Peak Pesign Adequacy Progran Implementation of Discipline Specific Actinn Plans VIII, IX and XI."
O 1S87 {. , ,.. _ - 4 - y i, s , .g - . ENCLOSURE 2 INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP RG IE 02
- 1. The responsibilities of regional inspectors, and supervisors and managers, with regard to inspection performance and reporting are discussed in IE Manual Chapters 2512. " Light Water Reactor Inspection Prcgram - Construc-tion Phase," 0400, " Enforcement Program," and 0610 " Inspection Reports." '
Regions may develop their own procedures which amplify the IE and NRC manuals and which provi u additional region-specific requirements. MC 2512 provides the detailed requirements for performance of specific inspections. Each inspector's job description and performance elements provide more detailed descriptions of the individual's responsibilities and authority. The position description, in particular, discusses the responsibility of the inspector to " recommend" actions, and the level of supervision req,uired. In accordance with MC 0400, the inspectors " identify violations of regula-tory requirements and recommend enforcement action." They also document findings and enforcement actions and "recomend tn appropriate regional management the severity level...." The inspectors also review responses to violations for adequacy, and prepare evaluations of responses to civil penalties "for submittal to regional management." Regional supervisors and managers review the inspectors' findings and recommendations to determine whether enforcement action should be taken, approve and sign non-escalated enforcement actions, and recommend escalated enforcement actions to the Regional Administrator.
l 1 l 1 I It is clear, both from the written requirements and from the practices l which have been followed in the regions, that the inspector's job is to 1 gather information and to identify safety concerns and potential viola- ) tions. Once his activities and findings are documented in a draft report, the material should receive a knowledgeable-technical review, either by
'the supervisor or by an assigned reviewer. The cover page of the final version is then signed by the inspector and the supervisor. The report is then issued by a letter which is signed by an individual who is at a sufficiently high management level to speak for the Regional Administra-tor. Thereby, each report which is issued represents a collective or institutional judgement; it represents not only the inspector's judgement, but also the judgem nt and conclusions of the agency.
There is no specific language in the IE Manual or, to the best of our knowledge, in the NRC Manual, which defines the meaning of signatures and concurrences on inspection reports. Present and past practice indicates that the inspector's signature shows his agreement that the report adequately represents his activities, findings and concerns. Where more than one inspector is involved, each inspector's signature logically applies only to his own activities, findings and concerns. As noted above, the supervisor's signature on the report cover page indicates that the report has received a knowledgeable technical review and that the supervisor agrees with the content of the report. The management level ! signature on the letter which transmits the report to the licensee indi- l cates that the report represents the collective or agency judgement relative to the inspection findings.
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- 2. Differences o opinion between an inspector and his supervision can occur L _
because of differences in value judgments, technical knowledge, work experience, or interpretation of.NRC policies and regulations. The requirements for' inspection performance are specified by regional supervi-sion, the inspector's job description and performance elements and, for specific-inspections, the inspection procedures contained in IE MC 2512. The individual inspection procedures do provide leeway with regard to implementation of specific inspection requirements. In particular, the independent inspection effort allows a relatively free choice of areas to ! be inspected. However, nothing in the IE manual permits an inspector to override his supervisor's directions with regard to the type, extent or l depth of inspections to be performed. l Differences between an inspector and his supervisor with regard to inspec-tion findings or report content should ideally be resolved based on informal discussions of the technical merits of the proposed findings and i the technical and compositional qualities of the draft report. If those discussions fail to develop an agreement, the discussions should be elevated to sequentially higher management levels until an agreement is 1 reached or a management decision is made to proceed with a particular approach or characterization of the proposed findings. A manager at any level (Section Chief, Branch Chief, etc.) may choose to make such a decision, thus ending the review process. Although the IE manual does not require documentation of such actions, good management practice dictates that supervisors should keep higher management informed of decisions which may be controversial. If the report is modified after it has been signed by the inspector, his supervisor, or any other participant, the signer i
C should be given the opportunity to reconsider his agreement with or ; concurrence in the lontents of the report. If an inspector should decide ~ not to sign the report, present NRC management practices provide for issuance of the report without the signature of the inspector. Although the-present manual does not contain direction on the subject, IE presently has under development a manual chapter which addresses this issue. -A copy will be provided to the review group when available. If the inspector continues to disagree with the approach or characterize-tion decided upon by management, he'may submit, in a written statement to his immediate supervisor, an expression of. professional judgment which differs from management's judgment. NRC Manual Chapter 4125 "Dvffering Professional Opinions," contains-detailed procedures and requirements for th'e expression and resolution of differing professional opinions concern-ing matters related.to the agency's mission. g l i l i
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- 3. - Insp ction findings or conclusions are classified as violat' ions,
' deviations, or unresolved 'iiems. A violation is a failure by the licensee to comply with a specific' NRC requirement such as a rule, order, license condition, or technical specification. A deviation is a failure by the licensee to satisfy a written commitment or to conform to an appliceble code, standard or accepted industry practice, other than as required by licensing conditions. An unresolved item is an inspection concern about which additional information is required to detennire whether or rot it is a violation. In some cases this is because the licensee was not able to provide sufficient information; in other cases the inspector may not have fully developed the facts. In addition, other types of designations, such as "open items," " deficiencies," or " inspector follow up iten:s" .are used by some regions, or by some HQ personnel, to provide a means for !
follow up and closeout of concerns which do not fall in the above cate-gories. Regulatory requirements have varying degrees of safety significance. In i addition, violations of the requirements may be of varying importance and extent. Consequently, violations are categorized in terms of five levels of severity within the various activity areas, which incluc'e Facility Construction as one area. The severity levels are defined by example for I the Fa::111ty Construction area in Supplement II of Appendix C to 10 CFR i Part 2. Severity Level I and II violations are of very significant regulatory concern. In general, violations that are includec in these severity categories involve actual or high potential impact on the public. Severity Level III violations are cause for significant concern. Severity Level IV violations are less serious but at e of more
^
1 i ! than' minor concern; i.e., if left uncorrected, they could lead to a more c serious concern. Severity Level V violations are of minor safety or i environmental concern. The great majority of violations are cited at Severity Levels IV and V. Normal practice has been to classify most procedural or " paperwork" deficiencies in the Facility Construction area as Level V, unless the deficiency is of such an extent as to bring into se:1ous question the quality cf installed equipment or structures. Isolated or relatively minor " hardware" deficiencies are also normally classified as Levei V. More serious or widespread " hardware" deficiencies which do not warrant escalated enforcement action are classified as Level IV. It should be noted that the classification of a violation as Level IV or V is somewhat subjective and may vary between individual inspectors, supervision and
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regions. Each violation is characterized at the level best suited to the signifi-cance of the circumstances surrounding the violation. In determining the significance of a violation, the following factors are normally con-sidered:
- a. Did the violation actually or potentially increase the risk to the public health and safety? A violation that involves no actual threat but which had the potential to increare the risk to the public health and safety may be very significant, depending upon the degree of potential threat, its likelihood, and the possible consequences involved. j l \
\ \ I _ __ ___ _ __ _______ b
(, 19 , - N
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6 Lg c b. What was the root cause of the violation? Was it caused by training p - deficiencies or inacaquate procedure 3? Such violations may have
' significance greater than the actual safety effect of the particular item involved in the violation.
- c. Is. the violation an isolated incident cr does it indicate programa-c tic breakdown? ' Programmatic breakdowos should be evaluated at higiier severity levels than isolated incide'ats.
- d. Was management aware of or involved in '.he violation and to what extent? Violations in which management was directly involved are more significant than those of which management was unaware.
- e. Did the violation involve willfulness and, if so, to what extent?
Reporting violations may result from a licensee's not filing a required report, filing an incomplete or incorrect report, or filing a late report. A violation may be cited for a reporting failure if a licensee was aware of information which it was required to report but did not. A violation will not usually be cited for a reporting failure if a licensee did not have the information that it was required to report, even if it should have had the information. However, if the licensee's failure to have the information was itself a violation of an NRC requirement then that requirement should be used as the basis for a violation. For example, if a licensee was required to conduct audits that would have produced the information and the licensee failed to conduct those audits, issuance of ' a violation for the latter failure would be appropriate. J__ _ _ _ .
' L C' With regard'to record-keeping violations, when a licensee.is required to perform a.given' task and to keep a' record of having done so, but'cannot produce that report, a violation should be cited for failure to keep the record. Failure to keep a required record may be considered supporting evidence that a licensee did not perform a required task. However, without additional evidence that the' task was not performed, the absence of the record is insufficient to support an violation for failure to perform the task. A violation is not normally cited for a Level IV or V deficiency which is identified by the licensee; which is reported, if required; which has been or will be corrected within a reasonable time; and which is not a violation that should have been prevented by the licensee's corrective action for a previous violation. In addition, licensees are not ordinarily cited for violations resulting from matters not within their control, such as equipment failures that are not avoidable, j i l
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. For, units under construction . regional procedures require the tracking and ..
closeout 5f all identified violations,' deviations and unresolved items prior to specified times related to licensing of the plant for operation.
-Open items for Construction Facilities are not normally ranked in order of safety significance to determine the order'of closecut.- Instead, the items are categorized into groups which require closeout prior to a particular milestone, such as fuel load, initial criticality, 5% power'or full power operation. The great majority of open items must be closed, in l
' writing and normally in an inspection report, prior to issuance of the operating license.
The regional office is responsible for the evaluation of licensee 1 responses to enforcement actions, the preparation of any required answers to the responses, the status tracking of all open items, and the follow up I
~ and closecut of the identified violations, deviations and unresolved items.
IE Manual Chapter 0610 requires that inspection reports describe any significant licensee or vendor action on previously identified inspection findings, including a description of the findings and a statement as to whether each item remains "open" or is " closed." MC 0610 does not require all open items to be tracked in an inspection report, only those items examined during the inspection. Similarly, Inspection Frocedure 943008,
" Operating License Issuance," of MC 2512 requires the review of required inspections at specified intervals prior to issuance of an operating license, the identification of all outstanding inspection areas and the reasons for incompletion, identification of all uncorrected items of noncompliance and their status, and identification of all unresolved items
and their status. Reports in accordance with IP 94300B are made by the region to HQ at 90 day, 60 day, and 30 day intervals prick to initial operation. In addition IE perfonns inspection program reviews .for NTOL l plants to verify that the inspection requirements of the applicable IE I I manual chapters have been completed prior to operation. The results of j the NT0L reviews are factored into the periodic IE assessments of regional l perfonnance. 1 j i i L_____-_ _
- 5. A copy of each of the following applicable documents is attached for your information and use:
- a. IE Manaual Chapter 2512; " Light Water Reactor Inspection Program -
Construction Phase."
- b. IE Manual Chapter 0610; " Inspection Reports."
- c. IE Manual Chapter 0400; " Enforcement Program."
- d. 10 CFR Part 2; " General Statement of Policy and Procedure for Enforcement."
- e. NRC Manual Chapter 4125; " Differing Professional Opinions."
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- f. IE Manual Chapter 1245; " Inspector Qualifications."
- g. Inspection Procedure 94300B; "0L Issuance."
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,;- 6. A copy of each headquarters directed inspection is attached for your
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information: -
- a. Inspection Report 50-445/83-10, 50-446/83-12; " Construction I Appraisal Inspection,"
- b. Inspection Report 50-445/85-17, 50-446/85-14; " Inspection of Comanche Peak Design Adequacy Program Scope Validation Process and Review Checklist Development."
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- c. Inspection Report 50-445/86-18, 50-446/86-15; " Inspection of Comanche Peak Design Adequacy Program (DAP), Implementation of Discipline Specific Action Plan (DSAP) X, Mechanical Systems and C0mponents."
- d. Inspection Report 50-445/86-17, 50-446/86-14; " Inspection of TERA's QA Program for the Comanche Peak Design Adequacy Program."
- e. Inspection Report 50-445/86/19, 50-446/86-15; " Inspection of Comanche Peak Design Adequacy Program Implementation of Discipline Specific Action Plans VIII, IX and XI."
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Append.a >2_:. --- :- -., g - - Appenda. y"p _ t~ --- x 7fp3g5-REMARKS: 7n's issuan:e p"cvides all ??? em;1 yees with the recently Comission-app"oved revisicr :: rapter '::.0 r_25, Differing Professional Opinions (DFO). Du."ing the process cf revisien, both the Comissicn and the DD reaffimed thei" cortinued fu 1 suppcrt for the LPO Policy and Process. Ir. additi:n, th:-y stressed the needrfcr ?30 ranagement to act objectively
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Tr.is revisi:n refle s the eva.uation and report of the Special Review Panel as we'l as requests fro- :20 ranagemer.t and recommendations of the Office Of Inspector and Audit:r, ard includes:
- 1. more er.phasis or. the establishment of timely procedures for the resciut en cf differing pr:Tess10nal opinions (DPD's).
- 2. recui"ement fcr Office Ci"e:ters and Regional Administrators to provide for maintenance of w"itten reccrds to p" ovide accountability fcr acti:ns taken to resc1ve DPO's ard to place ccmpleted cases $n centrally located office files.
3 statements cf responsibilities for Regional / administrators and for the Office of Eesource Fanagement concernir6 the processing and resciutier. cf statements cf differing professional opinions. L. prcvisior for the Office of Eescurce Ma"Agement to submit to the Omr.insion a . a".nual, rather thar. a caarterly, report on DPC's and actions taken tc achieve their resclution.
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- 2 .-
5 statement indicatirs that P;4 maintains a file of all initial ard !
- firal DPC's hardled by !EC; and requirement that the Directer, EM, I will notify the EDO of any DPO's that are not beirg resolved within
.the prescribed schedule.
- 6. statement that manapers advisir6 employees to file DPC's will inform the empicyees' marage.ent of that action.
- 7. addition of a su=ary and schedule of the DP0 resolution process.
- 8. requirement for Office Di~ectcrs ard Regional Administrators to '
obtain a control numbe" for each LPO from Pld. 9 highlighting of methods to address alleged retaliation fcr havi*.g filed a EFO.
- 10. requirement for the Director, Office of Ad:r.inistraticn, to provide an overview cf the DP0 pregam 1 crientatien of r.e4 employees.
i 4
4 U.S. NUCLEAR REGULATORY COMMISSION NRC MANUAL l Volume: 4000 Personnel Part - 4100 Federal RM CHAPTER 4125 DIFFERING PROFESSIONAL OPINIONS 4125-01 COVERAGE This chapter and appendix comprise NRC policy , objectives , procedures, responsibilities and other basic requirements and definitions established to provide for the expression and resolution of differing professional opinions concerning matters related to the agency's mission. 4125-02 POLICY AND OBJECTIVES 021 Policy It is the policy of the Nuclear Regulatory Commission, and the responsibility of all NRC supervisory and managerial personnel, to maintain a working environment that encourages employees to make known their best professional judgments even though they may differ from a prevailing staff view , disagree with a management decision or policy position, or take issue with proposed or established agency practices . Each differing professional opinion of an NRC employee will be evaluated on its own merat. Further, each i differing professional opinion will be pursued to resolution and the employee's j statement of differMg professional opinion, together with the agency's final i response, will be made available to the public to ensure the openness of NRC j decisions that may affect the'public. l l It is not only the right but the duty of all NRC employees to make known ] their best professional judgments on any matter relating to the mission of the ; agency Moreover, both the general public and the Nuclear Regulatory Com-mission benefit when the agency seriously considers NRC employees' differing j professional opinions that concern matters related to the agency's mission. This policy is intended to assure all employees the opportunity to express differing professional opinions in good faith, to have these opinions heard and considered by NRC management, and to be protected against retaliation in any l ferm . l 022 Objectives . I
- a. To define differing professional opinions.
L. To distinguish between differing professional opinions and the differences of views and opinions routinely raised and resch'ed among staff members in the ordinary conduct of agency business. Approved : July 23, 1985
,l NRC-4125-03 DIFFERING PROFESSIONAL OPINIONS
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- c. To provide a primary channel for submitting differing professional opinions .
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- d. To specify the recommended content of a statement of differing i professional opinions. I
- e. To provide reasonable time and reasonable administrative assistance to help employees develop and document their differing professional opinions .
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- f. To provide for acknowledgment of receipt of statements of differing professional opinion and for advising originators of planned actions for their resolution.
- g. To provide accountability oy requiring a written record of all actions taken on differing professional opinions. .
- h. To provide for resolution within the agency of differing professional opinions, if at all possible.
- i. To provide alternative channels for expressing a differing professional opinion either on the record or anonymously.
- j. To provide disciplinary sanctions against employees who take retaliatory actions that affect the originators of, or employees who support, differing professional opinions,
- k. To prevent intentional misuse of these procedures.
- 1. To provide for periodic assessment to ensure that implementation of these procedures accomplishes the stated objectives and to recom-mend appropriate changes
- m. To provide recognition to the originators of differing professional opinions if their opinions contribute significantly to achieving the agency's mission.
4125-03 RESPONSIBILITIES AND AUTHORITIES 031 The Executive Director for Operations (EDO):
- a. assures that a written record is maintained to provide accountability for all subsequent actions taken to resolve the differing professional opinions .
- b. ensures that differing professional opinions which are not resolved within four calendar months after their submission are resolved by the responsible office director as promptly as is practicable.
- c. annually appoints a Special Review Panel to evaluate and report on the functioning of the differing professional opinion procedures .
Approved: July 23,1985
[ 4 DIFFERING PROFESSIONAL OPINIONS NR C-4125-032 032 Directors of Offices and Regional Administrators:
- a. determine actions to be taken on statements of differing professional opinion OPC).
- b. obtain a unique control number from RM to place on the original DPO and all subsequent correspondence and documentation on that DPO.
- c. within 10 days of its submission, forward the differing professional opinion either to the appropriate manager within his or her own office or to the director of the office with basic responsibility for the issues raised in the differing professional opinion with copies to the EDO and Director, Office of Resource Management.
- d. convene an impartial peer review group to address the substance of the issues raised either when requested by the originator or when he determines that the complexity of the issues raised justifies such a review.
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- e. inform the Atomic Safety and Licensing Board Panel and the Atcmic Safety and Licensing Appeal Panel of any differing professional opin-ion that relates to issues pending before them or scheduled for their consideration.
- f. assure that every effort is made to expedite the resolution of differ-ing professional opinions within the time frame specified in Appendix 4125, Section G.2.a.
- g. provide the originator with a copy of the peer review group's report.
- h. inform the EDO of reasons for delay and submit, for EDO approval, a proposed plan for resolution of DPO's not resolved within four calendar months after submission.
- i. provide the originator with written notification of the resolution of his differing professional opinion with a copy to the Director, Office ~
of Resource Management, and the EDO, and access to all documents generated in connection with its resolution.
- j. after the issue is resolved and the case closed, complete files on the DPO will be maintained centrally by the cognizant office.
- k. provide the Office of Resource Management with an annual Differing Professional Opinion Status Report . (See Appendix 4125, 3
Section G.4. ) Approved: July 23,1985
e NRC-4125-033
% DIFFERING PROFESSIONAL OPINIONS ,
033 The Director, Office of Resource Management (RM): a, provides the Commission with an annual report identifying all differing professional opinions submitted and specifying the actions that have been taken to achieve their resolution.
- b. assigns a unique control number to each DPO at the time the offices initially provide documentation to RM on the origination of a specific DPO.
- c. maintains a file of all initial and final DPO's handled by NRC.
- d. advises the immediate supervisors of originators of DPO's of the requirements to maintain a written record to provide accountability for all subsequent actions taken to resolve the differing professional opinions . (See 4125-036 h. )
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- e. notifies the EDO of any DPO's currently under review that are not anticipated to be resolved within 30 days after initial submission.
034 The Director, Office of Administration (ADM), requires all of the Headquarters and Regional personnel offices to include an overview of the DPO program in the orientation for new employees. 035 The Advisory Committee on Reactor Safeguards:
- a. appends comments to all referred statements of differing professional opinion and forwards them for resolution to the appropriate office director, if the differing professional opinion relates to a potential safety issue within their purview.
b, responds to appeals by an originator if the differing professional opinion concerns matters of public health or safety. 036 Immediate Supervisors:
- a. advise and assist employees in administratively preparing adequate written statements of differing professional opinion and aid 'them in identifying related information, j l
- b. in consultation with their managers, determine the amount of the ori-ginator's work time and administrative support to be provided in response to the originator's request for assistance.
- c. receive signed statements of differing professional opinion from the originator .
- d. within five working days of receipt acknowledge receipt of statements of differing professional opinion by memoranda to the originators. A copy of the acknowledgment memo and the DPO statement is forwarded to the EDO and the Director, Office of Resource Management.
Approved : July 03. 1985 l
1 DlFFERING PROFESSIONAL OPlNIONS NRC-4125-037
- e. return to the originator any statement excluded from the definition of a differing professional opinion together with a memorandum citing the specific exclusion with a copy to the EDO and Director, Office of Resource Management.
- f. forward statements of differing professional opinion, via their chain-of-comman d , to his or her office director for action with a copy to the EDO and Director, Office of Resource Management,
- g. assure that statements of differing professional opinion are incorpo-rated into the receiving organization's normal work tracking system.
h .. maintain a written record to provide accountability for all subsequent actions taken to resolve the differing professiol:al opinion while the DPO is active.
- i. when the DPO is completed or withdrawn, forwards the complete file to the office director's office, where it will be centrally maintained.
037 All Employees:
- a. make known their best professional judgments on any matter relating to the mission of the agency by submitting to their immediate supervisor a signed statement of differing professional opinion when appropriate. '
- b. before submitting a sta tement of differing professional opinion ,
should consult with their immediate supervisor who will aid them in identifying related information and assist them, if requested, in clar-ifying the issues.
- c. may request an Open Door meeting with any manager to discuss their views .
- d. may request that their differing professional opinion be presented to an impartial peer review group for review, evaluation, and comment.
- e. may communicate a differing professional opinion concerhing a poten-tial safety issue directly to the chairman or any member of the
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ACRS. l
- f. may appeal the resolution of their differing professional opinion to a j higher level of NRC management.
4125-04 DEFINITIONS 041 Differing Professional Opinion. A conscientious expression of pro-fessional judgment as contained in a written, signed statement submitted to one's immediate supervisor, or submission of an unsigned anonymous statement Approved: July 23,1985 i I
l NRC-4125-042 DIFFERING PROFESSIONAL OPINIONS , (see NRC Appendix 4125, Section H.1) which, on any matter relating to NRC's mission or organizational activities , differs from the prevailing staff view , within' an organization , disagrees with a management decision or policy l l position , or takes issue with a proposed or an established agency practice. Differing professional opinions may involve technical, management, legal, or policy issues and are not limited to the originator's area of expertise. Matters ; that are subject to employee grievance in accordance with Chapter NRC-4157 l and matters covered by the negotiated grievance procedure do not qualify as l differing professional opinions,
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042 Manager. 1 An employee who directs the work of an organization, is 4 held accountable for specific line or staff programs or activities, and whose primary duties are managerial. 043 Peer Group. A group of NRC staff with expertise in the area enecmpassed by a given DPO, convened for the purpose of addressing the substance of the issues raised by the DPO.
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4125-05 B ASIC REQUIREMENTS 051 Applicability . These procedures for the expression and resolution of differing professional opinions are for the use of all NRC employees including supervisors and managers. The procedures supplement other stated rights, i du ties , and safeguards applicable to all Federal employees who make their i views known either within or outside their agencies, including: 4
- a. the independent right of free speech provided by the First Amend-ment to the U.S. Constitution.
- b. the right of government employees to petition the Congress (5 USC 7102).
- c. the rights of employees to communicate directly with the Congress as outlined in the Code of Ethics for Government Service (10 CFR 0.735
- Annex A).
- d. provisions of the 1978 Civil Service Reform Act dealing with pro-hibited personnel practices and the regulations of the Merit System Protection Board.
052 Appendix 4125. This appendix provides procedures for the expres- I sion rnd resolution of differing professional opinions. 1 l
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Approved: July 23.1985 l l
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l i DIFFERING PROFESSIONAL OPINIONS' - NRC Appendix 4125 l. l 1 i i CONTENTS Page A. Normal Dif f ering Views vs. Dif fering ' Professional Opinions. . . . . . . . . 1 B. Primary: Channel for Expressing Differing Professional Opinions . . . . . 1
'C. C'ontent of a Written Statement of Differing Professional Opinion... 2 D. . Resources to Assist-Originators'of Differing Professional Opinions. 2-
'E. Ac knowl edgment of. Di f f eri ng Prof es s ional 0pi nions. . . . . . . . . . . . .. . . . . . 2 F. Written Record of Actions on Differing Professional Opinions....... 3.
G. Resolution of Differing Professional 0 pinions....................... 3 l
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, 1. Definition of Resolution ........................ .............. 3 j
- 2. Resolution Process ............................................. 4' ;
3.: Appeal ...... .................................................. 6 l
- 4. Reports to the Commission .................... ................. 7 H. Alternate Channels for Expressing Differing Professional........... .
Opinions...... ..........................................,......... 7 l 1
- 1. Open Door Policy................................................ 8 * '!
- 2. The'ACRS........................................................ 9 I. Prevention of Retaliation Against Individuals who Express or~
Support Differing Professional 0 pinions............................ l 9 J. Prevent Intentional Misuse of Procedures for Differing Professional Opinions.. ........................................... 10 K. Special Review Panel for Follow-up on Functioning of Differing ; Professional Opinion Procedures.................................... 10 L. Recognition of Originators of Significant Differing Professional 0 pinions........................................................... 11 l i Approved: July 23,1985 m___________________________ _ _ _ _ _ . _ _ _ _ _ _ !
DIFFERING PROFESSIONAL OPINIONS NRC Appendix 4125
,i PROCEDURES FOR THE EXPRESSION AND RES'OLUTION i
- OF DIFFERING PROFESSIONAL OPINIONS .
A. Normal Differing Views vs. Differing Professional Opinions A' normal differing view, developed in -the free and open discussion of work matters , becomes a . differing professional opinion only. when the originator brings it- to NRC management attention in accordance with these procedures, i In the free .and open discussion of work matters, professional differences of opinion are common. Employees may. also develop critical views con-cerning matters other than their personal work assignments, such as is-sues under consideration in another part of NRC or relating to an agency practice or position that is neither currently under review nor in the j agency's decisionmaking process. In both these instances employees normally try, and should be encour.- aged, to resolve their concerns through discussions with their co-workers and immediate supervisors. In some cases, such discussions may lead to , the submission of a suggestion as part of the NRC suggestion program .! (Chapter NRC-4154) However,- these informal discuschne my not resolve the matter and an i' employee may be convinced that the agency and the public would be bet-ter served if another opinion prevailed. To further pursue such con-cerns using these procedures, an employee should submit a written statement of. differing professional opinion in accordance with . these procedures, With the submission of this statement, the employee's dif-fering view becomes a differing professional opinion. An employee may not use these procedures for differing professional opinions without submitting a written statement. The employee may, how-ever. express any' concerns orally or in writing to the ACRS and may also- discuss these concerns with any NRC manager as provided in the Open Door Policy. (See Section H). B. Primary Channel for Expressing Differing Professional Opinions These procedures are invoked when employees submit to their immediate supervisor a written statement of differing professional opinion . As indicated in the statemt of policy, it is not only the right but the duty of all NRC employees to make known their best professional judgments on any matter relating to the mission of the agency Before submittin the statement, employees should consult with their im-mediate supervisor who will aid them in identifying related information and ' assist them, if requested , in clarifying the issues . Originators of 4 differing professional opinions may request agency resources for prepar- l ing adequate written statements of differing professional opinion and such I requests shall include estimates of the resources required. l 1 1 1 Approved: July 23,1985 1
NRC Appendix 4125 DIFFERING PROFESSIONAL OPINIONS
- i After registering a DPO, an individual should be prepared to describe his background as it relates to the issue raised, since the initial credibility given his opinion may rest, i.. part, on that background.
C. Content of a Written Statement of Differing Professional Opinion
' A written statement of differing professional opinion, while being brief, should in all cases include the following:
- 1. a summary of the originator's perception of the prevailing staff view, i existing management decision or stated position, or the proposed or established agency practice. 3
- 2. a description of the originator's opinions and how they differ from any items discussed in 1. above.
- 3. a statement of the originator's assessment of the resulting conse-quences if the differing professional opinion is not adopted by the agency.
D. Resources to Assist Originators of Differing Professional Opinions To assist originators in preparing adequate written statements of differing professional opinion. NRC management will allow a reasonable amount of the originator's work time and administrative support. If called to testify before a Licensing Board or an Appeal Board, the employee may receive, upon request, assistance from the staff legal office in preparing testimony or other documents to be filed with the Board, Such assistance will be solely for the purpose of facilitating the filing of the necessary dccuments and will not constitute legal , > presentation of the employee by the legal staff. The originator's immeciate supervisor, in consultation with his or ! her manager, will determine the amount of the originator's work time and administrative support to be provided in response to the originator's request for assistance. ,
)
E. Acknowledgment of Differing Professional Opinions i l The immediate supervisor shall, upon receiving a written statement of differing professional opinion, discuss the statement with the originator if this has not previously been done. In addition, the immediate supervisor j must, within five working days, acknowledge receipt by a memorandum to the originator with a copy to the EDO and a copy to the Director, Office of Resource Management. This memorandum will also indicate the actions that will be taken to resolve the differing professional opinion. Upon receipt , statements of differing professional opinion will be incor- i po"a ted into the receiving organization's normal work tracking system. l This tracking should assure that the status of each differing professional I opinion is regularly reviewed, aid in its prompt resolution, and provide a i systematic basis for keeping the originator informed. ! l l 1 l l ! Approved : July 23. 1985 y
DIFFERING PROFESSIONAL OPINIONS NRC Appendix 4125 F. Written Record of Actions on Differing Professional Opinions Once a differing professional opinion has been submitted, a written record must be maintained by the immediate supervisor while the DPO is active to provide accountability for au subsequent actions taken to resolve that differing professional opinion on its merits. This record will consist of L L signed notations of au supervisory and managerial determinations and actions based upon the differing professional opinion. Changes in the original documentation that are requested by the originator will also be made a part of this written record. Copies of the initial and the final DPO documents win be sent to the Director, Office of Resource Management. and the EDO. AU pertinent documentation will be retained by the supervisor while the DPO is active and centraDy by the office director for a period of ten years after the DPO becomes inactive. G. Resolution of Differing Professional Opinions
- 1. Definition of Resolution j
( A differing professional opinion is considered resolved by the NRC { when: j i'
- a. NRC management adopts the views expressed in the originator's written statement of differing professional opinion; or
- b. NRC management adopts a part of the judgments expressed in i 1
the originator's written statement of differing professional l opinion and informs the originator of the reasons for not l adopting the remainder; or 1 J
- c. The responsible office director determines that evaluation of the differing professional opinion fails to justify modification of a management decision , policy position , or a proposed or an l existing agency practice; or 1
- d. The responsible office director determines that the impact of the potential consequences stated in the differing professional opinion is insufficient to justify a detailed evaluation of the differing professional opinion; or
- e. The differing professional opinion is withdrawn by the originator.1/ l l
1/In such cases. NRC management may elect to pursue the matter further ! based on its merit even though it is no longer considered to be a differing professional opinion. 3 Approved: July 23,1985
W NRC Appendix 4125 DIFFERING PROFESSIONAL OPINIONS . In each of the preceding cases, the resolution process is complete only when the originator has been informed of the decision or action of NRC management an d ,' consistent with security classification policy , both the statement of differing professional opinion and the response of NRC management have been placed in NRC's Public 1 Document Room.
- 2. Resolution Process
- a. Summary and schedule of resolution process:
Originator submits DPO to immediate supervisor; (Within five working days of receipt) immediate supervisor forwards DPO to office director with comments of all others in chain-of-command appended; (Within 10 working days of submission) office director forwards DPO to appropriate manager for action [If transferred to another office, DPO must be assigned to responsible program manager within 15 working days after submission by originator. ] ; (Within 15 days after submission) office director informs ASLBP and ASLAP of any DPO that relates to issues pending before them or scheduled for their consideration; (Within 30 working days after assignment to responsible manager) DPO normally resolved; (Four calendar months after submission) if' DPO not resolved, responsible office director informs the EDO of reasons for delay and submits, for EDO approval, a proposed plan and schedule ; for completing resolution.
- b. When submitting a differing professional opitaon, the originator may request that it be presented to an impartial peer review group for review, evaluation, and comment. If such request is not made by the originator, and if the responsible office director determines that such review is justified by the complexity or the potential significance of the issues raised, he shall convene an impartial peer review group to address the substance of the issues raised in the differing professional opinion . In either case, the responsible office director will assure that members of the peer review groups convened for this purpose are specifically selected for their impartiality and professional competence concerning matters discussed in each differing professional opinion. The responsible office director Approved: July 23,1985 4
1 l
. l DIFFERING PROFESSION AL OPINIONS NRC Appendix 412: 3
]
1 i win carefuDy consider peer review group recommendations in i the resolution of applicable differing professional opinions and 1 will provide the originator with a copy of the peer revier l group's report. l 1
- c. Upon receiving a statement of differing professional opinion from the originator, the immediate supervisor will forward it, via the chain-of-command , to his or her office director for action with copies to the EDO and the Office of Resource !
The immediate supervisor and all others in the Management. chain- of-command shall append their views concerning matters discussed in the differing professional opinion. The differing professional opinion, with comments appended, shall be provided to . the office director within five working days after its submission by the originator. Copies of these comments , i together with cll other documents generated in response to the differing professional opinion, shan be made available to the originator as they are generated. At his option, the originator may submit written comments for the record concerning views . expressed by his immediate supervisor or others in the I chain-of-comman d , or views expressed by intermediate NRC management personnel in the course of resolution of the differing professional opinion.
- d. The office director win obtain a unique DPO control number and will forward the differing professional opinion , within 10 working days of its submission by the originator, either to the appropriate manager within his or her own office or to the director of the office that has basic responsibility for the issues raised in the differing professional opinion,with copies to the EDO and Director, Office of Resource Management . If transferred to another office for resolution, the differing professional opinion must be assigned to the responsible program manager within 15 working days after its submission by the originator. The responsible manager will incorporate the statement of differing professional opinion into the organization's normal work tracking system and, until the differing professional opinion has been resolved, shall provide the originator with brief monthly status reports . Copies of these reports shall also be provided to the responsible office director. The respon:;ible manager will also inform the originator of other differing professional opinions received that are relevant to that submitted by the originator,
- e. The responsible office director will, within 15 working days after its submission by an originator, inform the Atomic Safety and Licensing Board Panel and the Atomic Safety and Licensing Appeal Panel of any differing professional opinion that re-lates to issues pending before them or scheduled for their consideration .
5 Approved: July 23,1985
~
i l 1 NRC Appendix 4125 DIFFERING PROFESSIONAL OPINIONS . e
- f. Every effort shall be made to expedite the resolution of differing professional opinions . Normally , a differing professional opinion should be resolved by the responsible office director within 30 working days after its assignment to the responsible manager. An extension of 15 working days will, however, be automatically granted upon certification by the responsible manager to the originator that: (1) resolution of the differing professional opinion involves especially complex
. is sues , (2) the workload of managerial personnel involved in resolution of the issues is temporarily heavier than normal, or (3) that resolution of the differing professional opinion involves the participation of several levels of NRC management.
Additional extensions of 15 working days each may be granted only upon application to and approval by the responsible office director who will consider comments of both the managerial personnel involved and the originator with regard to the proposed extension.
- g. If a differing professional opinion is not resolved within four calendar months after its submission , the responsible office director shall inform the Executive Director for Operations (EDO) of the reasons for the delay and shall submit, for EDO approval, a proposed plan and schedule for completing its reso-lution . The responsible office director shall provide the orig-inator with a copy of the EDO-approved plan and schedule for resolution . The EDO will ensure that differing professional opinions in this category are resolved by the responsible office director as promptly as is practicable.
- h. The responsible office director shall provide the originator with written notification of the resolution of his differing professional opinion with a copy to the Director , Office of Resource Management, (see Section 4125-03) and the EDO, and access to all documents generated in connection with its resolution. While the DPO is active , the immediate supervisor will maintain the file . When the DPO is complete or inactive, the office director will centrally maintain the file.
- 3. Appeal The originator may appeal the resolution of his differing professional opinion to a higher level of NRC management including ultimately, the Commission . Normally it would be expected that appeals by individuals assigned to Program Offices or to EDO Staff Offices would be submitted to the EDO and that individuals assigned to the Commission or to Commission Staff Offices would submit appeals or to the Commission . Moreover. if a differing professional opinion concerns matters of public health or safety. the appeal may be fcrwarded through the ACRS with a request that the ACRS comment on the potential safety implications of the resolution that is being appealed .
A pproved : July 23,1985 6
DlFFERING PROFESSIONAL OPINIONS NRC Appendix 4125 I These procedures make no provision for further appeal of the reso-lution by NRC management of a differing professional opinion. How-i ever. originators who are dissatisfied with either NRC management's l resolu tion of their differing professional opinion or the results of their appeal of this resolution may further pursue their concerns via { the Open Door policy or the ACRS as appropriate. )
- 4. Reports to the Commission '
l The. Office of Resource Management (RM) shall provide the Commis-i sion with annual reports identifying all differing professional opin-1 ions submitted and specifying the actions that have been taken to achieve their resolution. This information shall be provided by the responsible office directors who shall, within five working days after each calendar year, provide RM with a Differing Professional Opinion Status Report that contains:
- a. A listing and a description of all differing professional opinions received together with a brief status report of all efforts that have been taken to achieve their resolution. Items shall be d reported and summarized in the following three categories : i (1) Differing professional opinions submitted since the last status report.
(2) Differing professional opinions previously received and reported but not yet resolved. (3) Differing professional opinions previously received and reported that were resolved on the following dates.
- b. Information obtained from the originator of each differing pro-fessional opinion resolved during the year which indicates the originator's general reactions to these procedures. As a mini-mum, this information should include the originator's evaluation of the utility of these procedures for handling his or her dif-fering professional opinion, areas in which these procedures inhibited rather than aided the achievement of their objectives, and comments or recommendations for improvement of these procedures.
H. Alternate Channels for Expressing Differing Professional Opinions Two alternate channels are available for employees who prefer not to use the primary channel for expressing their differing professional opinions . Once a differing professional opinion submitted via either of these two channels has been forwarded to the responsible office director, subsequent procedural steps involved in resolution of the differing professional opinion are essentially identical with those prescribed for the primary channel. The basic difference between the primary channel and the two alternatives discussed below is that the alternatives permit the originator to select the individual manager to whom the differing professional opinion will be submitted and, in 7 Approved: July 23, 1985 l l
NRC Appendix 4125 DIFFERING PROFESSIONAL OPINIONS a ddition , they make provision for the submission of anonymous differing professional opinions upon request.
- 1. Open Door Policy The Open Door Policy of NRC provides that NRC employees may, on their own initiative, meet with any manager, including a Commissioner or the Chairman of NRC, to discuss any matter of concern to the employee. Employees may request an Open Door meeting directly with the selected manager's secretary or administrative assistant and there is no req':irement for the ,
approval of requests for such meetings by intermediate j management. l An employee's request for anonymity will be honored by any manager contacted via the Open Door except in two special situations that could occur if the manager contacted is an NRC , Commissioner. Each Commissioner is legally required to inform all other Commissioners of any information which he believes to be related to the responsibility or the function of the l Commission . (This requirement for mandatory information sharing applies only to the Commissioners and does not extend to others within NRC. ) Subject to this constraint , NRC Commissioners will honor an employee's request for anonymity nade in connection with communications via the Open Door. Therefore , when an employee requests anonymity in an Open Door contact with a Commissioner, no Commissioner will disclose to another Commissioner the identity of the employee unless (a) as a practical matter it is impossible to convey the substance of the information without making known the identity of the employee, (b) disclosure of the employee's identity to the other Commissioners is essential for determination of the accuracy and reliability of the information , or (c) the employee's identity is required to be released by law. If Opea Door discussions disclose that an employee's views cons titute a differmg professional opinion , the contacted manager should advise the employee to submit a signed, written statement of differing professional opinion m accordance with these procedures and should inform the employee's management that he has been advised to prepare such a statement. If the employee insists on remaining anonymous but wishes to have his or her views considered as a differing professional opinion, the employee should submit an unsigned statement of differing professional opinion to the manager contacted via the Open Door and that manager will forward the anonymous statement of differing professional opinion to the office director harmg programmatic responsibility for the issues raised in the differmg professional opinion . Resolution of the differing professional opmion will then be completed in accordance with these procedures . To protect the employee's anonymity m such cases, however, it may not be possible to provide the acknowledgment t of receipt of the differing professional opinion Approved : July 23.1985 3
l l l 4 DIFFERING PROFESSIONAL OPINIONS NRC Appendix 4125 i cr the repc*:s en~ resciutien d'. ectly te the crigirater cf the differ-ing pr:fessioral c;ir.icn. In such cases, the rarager crigirally cen-tacted via the Open Docr shal; relty :c the erigiratcr teth the ack-l newled r.er.: cf receipt and al; reptr:s receivei by that nanager cen-l cerni*.E resciutien cf the differi .g prcfessic*al c;inien. Differing opinions not expressed in writing as required by Section C shall be considered to be normal differing views as discussed in l Section B. and may not be pursued further using the procedures for l 1 differing professional opinions. Open Door discussions between employees and . managers may also relate to subjects other than normal differing views and differing professional opinions. In these cases, the managers contacted wiU work to resolve an employee's concerns, to answer any questions, and to honor any request for anonymity Honoring a request for , anonymity may, however, hmit a manager's assistance either to dis-l cussions with the employee or to providing advice and counsel on matters of concern to the employee. Managers should advise employees of the proper channels to be used for the resolution of concerns that may not be resolved using these procedures for differing professional opinions. If the contacted manager believes that others should be notified of issues raised in these Open Door discussions. he should notify offices with program-matic responsibility, and others (e.g. , the Office of Inspector and A u ditor) .
- 2. The ACRS If the differing professional opinion relates to a potential safety issue within the purview of the Advisory -Committee on Reactor Safe-guards, an NRC employee may communicate oraUy or in writing directly with the Chairman or any member of the ACRS. Such com-municat2on may be anonymous. The ACRS win append comments. as appropriate , to au referred statements of differing professional opinion and will forward these statements for resolution to the appropriate NRC office director.
An NRC employee may also appear before the ACRS or an ACRS Subcommittee as deemed appropriate by the Committee. The ACRS will assure that all such statements that do not constitute a differing professional opinion are forwarded to the appropriate NRC office director for information.
- 1. Prevention of Retaliation Against Individuals Who Express or Support Differing Professional Opinions Any NRC employee who retaliates against another employee for submitting or supporting a differing professional opinion is subject to disciphnaiy action in accordance with Chapter NRC-4171 (Disciphne. Adverse Actions and Separations ) . This applies to retaliatory actions described in the 9 Approved: July 23,1985
e NRC Append:x 4125 DIFFERING PROFESSIONAL OPINIONS . foDowmg paragraph and to all prohibited personnel practices specified in Section 2302. Title 5. U.S. Code. as amended by the Civil Service Reform Act of 1978. 1 Retaliation consists of injurious actions taken against the originator of a differmg professional opinion in which a motivating factor for such actions derived from the submission of a differing professional opinion by the I originator. Retaliation may mvolve transfer; detail; ostracism; loss of staff assistance, space, or equipment; physical isolation; the absence of assignments involving substantive work; or the denial of promotion , attendance at professional society meetings, or justified training. , Employees who auege that retaliatory actions have been taken because of I their submission or support of a differmg professional opinion may seek redress through the negotiated grievance procedure or through the grievance procedure described in Chapter NRC-4157 (Employee G rier-ances>. This is the formal route. Employees may also use the "Open Door Polic; as described in Section H.1 of this appendix. . l In a case where an employee files a grievance alleging that he/she has been retaliated agamst for having filed a DPO, the grievance may be reviewed initially by the same managers (usually lower level management) who allegedly have engaged in retaliation . However, the agency grievance procedures provide for review of the auegation by higher level management. In addition , grievants under agency practice and procedures have the right to present the issue to an independent third party from outside the NRC; grievants covered by the negotiated Union
- Agreement may, with the concurrence of the Union proceed to bindmg arbitration before a third party arbitrator from outside the NRC.
J. Prevent Intentional Misuse of Procedures for Differing Professional Opmions No NRC employee sh:uld mientionauy misuse these procedures. Examples of intenti:nal misuse would melude but not be limited to frivolous use. attempts to treat a personnel-grievance type action as a differing protes-sional opm:en . and repeated attempts to use these procedures to obtain a resolution of views that do not satisfy the criteria for differing professional opinions K. Special Review Panel for Fouow-up on Functionmg of Differing Profes-stonal opmion Procedures AnnuaUy the Executive Director for Operations will appoint a Special Review Panel to evaluate and report on the functioning of these differmg professional opinion procedures. Four members of the Special Review Panel will be NRC employees (two managers and two nonmanagers). and the futh member wiu be chosen from outside the NRC. Two of the NRC-employee members will be selected from a list of at least five ( 5) candidates ncmmated by the National Treasury Employees Union (NTEl'). Embership shau not be umited to scientific or engmeermg personnel AL NRC empiyees will receive a copy of the letter appointmg members cf
*he Spenal Reviev Panel The forwardmg memorandum may als sdcit Apprc red : July 5 . 1955 10 i
)
r NRC Appendix 4125
, DIFFERING PROFESSION AL OPINIONS employee comments on these procedures to be considered by the Special Review Panel. Employee recommendations for membership of subsequent Special Review Panels win also be solicited.
The Special Review Panel wiD study NRC's experience in handling differing professional opinions, evaluate the functioning of these differing professional opinion procedures by assessing the degree to which the objectives are accomplished , and make appropriate recommendations for change. The Special Review Panel may recommend decreasing the I frequency of ' these reviews when evaluations indicate that the NRC l procedures for differing professional opinions are functioning effectively The findings and recommendations of the Special Review Panel win be distributed simultaneously to the Commission. EDO, NRC employees and the public when the panel's deliberations are complete and before any revisions to Chapter NRC-4125 are initiated. L. Recognition of Originators of Significant Differing Professional Opinions in addition, the Special Review Panel described in Section K, above, wiD annually review all differing professional opinions submitted during the prior year to identify employees whose differing professional opinions I made significant contributions to the agency or to public safety but who had not been recognized by his or her supervisor for this contribution, 11 is anticipated that employees who provide significant contributions to the agency or to public health and safety wiB be recommended for appro-priate awards by their immediate supervisors . Where award recommendations have not been made, they may be made by this Panel in accordance with provisions of NRC's incentive Awards Program (Chapter NR C-4154 ) . Copies of su:h recommendations for award will be included in the Special Review Panel's written report to the EDO and the Commissioners . l l 11 Approved: July 23,1985
, r /{ , . ..; #~*e ! =
1 ,, . . 3 Federal Register / Vcl. es. N3. 4F / Thured:y. herch s tess / Rules and Regulations 3583 j l 4
..; l
. IsWCLEAR RESUL.AT0ny , Commissian duested the staff to prepare t 00tletiSS80es a coagwebensive statement of
- enfermement pehey.This staN effort was i le CpR Parti gives added wgency by the enactment of pub. I. St-as (eipied June an. seso). '
Sonoral Stettiment of Pear;and est. among seer thmen. amended Presseum fc.' Enfersement Assens Section 334 of the Atomic Energy Act to aesace: Nuclear Regulatory ' mise the maelsum eini penalty the Commisson. WRCeseimpose hem ga ono to gico.noo l aevises Revised generet stationant of per vsoletisa per der and ehminated the q pobeI* provisies lomiting to toisi sivil penalties for any as der pened to numasaer.N NRCis pubhshing minw - Sas.amL Os September 4. teso.the revisions to its enfersement pokey (47 Commission oppveved a proposed FR seer (March e. Sant)) based upon its psneral sestement of poissy en empenence to date is implemented the enforcement. Coeuseets were solicited pobey. The pohey statement is intended en the potcy and a series of pubhc to inform licensees and the pubhc of the meetap was held. De March 9.1s82. bases for talung vaneus safercament the Coeusission pubnah.J e f r ! . actions.The policy is codified as wereien of the pobey (47 FR ges l. Appendia C to part 2 et Titis 30 of the The policy has now been in effect for Code of Federal Regulations.N about two yease.The Conenission Comuniesion has also directed thet a dimeted the staN to evoluste the policy study of the enforcement preyman be and recomunend changes if any were performed by a small sommittee of necessary.The staff met with groups of individuals froen outside the agency to utility representeuves and pubim be selected by the Commassion. As a interest youps and sensuhed the NRC result of this study,additionalchanges Regional Administrator and Office to the policy may be proposed. , pir,cto,e soliciting somments on - Comments on these revisions are whether any ch to the policy 1 solicited and will be considered in the should be made. Comenselon has - 1 in depth study of the enforcement determined that, pending further stedy. program. no major changes should be made to the p GPF5Cfret Daft:This revised statement - policy at this time.N Commission bas of policy is effectJve March 8,1984 whole determined, however, that certain minor comments en the pokey are being revisions should be made now. receivei Submit comunents on or before The Commission bse also directed lune 1.leN. Comments received after that an is. depth study of the this date will be considered ifit is . enforcement proyan be performed by a proetical to do so. but assurance of small committw of indivuluals from consideration cannot be given sacept as outside the agency te be selected by the to comments received as or before this Commission. This stedy will begin tius date. spnns. As a result of this study, anoatssam Send osaments and additional changes to the pobey may be suggntions to: Seceetary of the proposed. Commission. UA Nuclear Regulatory The Cosamission is soliciting Commission. Washington. D.C. ant 6L comments on the minor revisions Attentiotu Docketing and Service described below.These somments wd1 Branch. Copies of comunents may be be considered in the in<lepth study of examined in the US Nuclear Regulatory the entercament preyam. In addition. Commission Public Document Room. the Comeussion is particularly 1717 H Sweet. NW Washington, D C. laterested in comuments en the issue of pon rustrMas espomas/reces coerracr. material false statements. In the VEPCO lane A. Amelted.Cusetor. Enforcement decisionla 1g70 Yuguus Electnc Power Staff. Office ofInspection and Corepany (North Anne power Station. Enforcement. U1 Nuclear Regulatory Units 1 and 2) CL3-76-32. 4 NRC 480, Commission. Washington. D.C. 20E5 affirmed. Vuyinio Escinc & Arwer Co. I (301-492-4009). r.#AC Aff r ad 13EB (4th Car. ser8). the gusetaesserrasrv espoossations Commission defined the term **mstenal false statement" as a statement that is ~ Beckymed false by emineios er commission and W enterte used by the r %==naa has the espebility to influence e to conduct its enfororisent scentsee reasonable andKey supert.The were first pubhebed or, October 17. ter2 Commission's staff has been applying (37 FR 21en2).These est tens were stus definition and has taken subsequently modified on jonnery 3. enforcement accons in several cases for 1975 (40 FR 420) and on December 3. eiolations involving matenal false 1979 (44 FR 77138). la late 1s7s the stateinents.
gsM ~ Tadiral Registe-[Vdl.' 49.' No.'4t / Thursday, Staref 8. 3964 / Rule's and Reg!alations . . ne Commission la interested in regulations implementing those comments on the agency's pohey on la lacorporating the substance of provisions. section IV.B. two changes were made. matenal falu statements. Specifically. has :he Commission's emphasis on IE.My of VWade ne Comminion has noted that material false statements had a enforcement conferences val normally effect en the quahty of commun+ 1. A few minor editorial changes were be closed to the public. in aJdition. the cationspositive made. In addition, change 6 were made existing policy pewided that a civil with the NRC or has it haC a chilhng to refleet that a new Supplement. effect on such communications? Should penalty would not be knposed for a Supplement Vill, was added.This Severtty level N violation unlese a the definition of material false statement Supplement la discussed in more deta!! be changed to apply only to written licensee had been cited previously for a under Supplement V11L statemente, submitted under oath? similar violation for which an L language has been added to reflect Should materishty be contingent upon enforcement conference had been held the practice that has been adopted of and for which corrective action had the safety significance of the underlying evaluating some violations in the proved ineffective. nr Commission has. information? Should " materiality" he dependent upon actually influencing an aggregate and assigning a single severity en occasion, wanted to impose a civil level for a group of violadons.ne penalty for a Severity levelIV nols tion agency reviewer as opposed to havmg the capabihty ofinfluencmg a existing p4 hey provided that to focus on similar to e previous violation but for the underlying cause of a violation. the reasonable agency reviewerf What which an enforcement conferen" W would the expected effect of such cumulative total civil penalty for all not been held.The policy has been changes be? As discuswi above. these violations that contributed to or were changed to delete the reference to a unavoidable consequences of that comments will be considered in the in* previous similar Severity leveIIV problem would be based on the amount depth study of the enforcement program violstion for which an enforcement shown in the civil penalty tables. Since and may result in further changes to the conference had been held. Instead. the policy. the amount in the tables is based upon policy states ttat the NRC may elect to in the following paragraphs, the the neverity level of a violation, the Commission has found it necessary in bold an enbreement confance for nvisions to the pohc which are bem.g Seventy levelIV violaticas which. if medenow are desen d. Only the some cases to aggregate the violations repeated. could lead to escalated sections to which changes were made for the assignment of a severity level.in enforcement action.ne pohey also addshon. this change la being made to are discussed here. The numbenna of escognize that individual violations, states that civil penalties may be the sections tracks the section numbers imposed for previous similar Severity in the pob:y. when viewed collectively, may have a 1,velIV violations for which corrective greater significance than when L 1stroducun and Pwpoes action has proved ineffective in considered separately. By aggregating achieving compliance.ne NRC will
- 1. The word " noncompliance" was the violations to evaluate the severity normally bold an enforcement changed to "nola tion" wherever it level, the Commission hopes to focus conference before proposing a civil appears in the pohey to more precisely attention on the underlying problem or ra penalty for a Seventy 1AvelIV violation, desenbe the focus of the enforcement stic deficiencies where
,,p The phrase "noncon.phance should 3 The existing policy indicates that a be more expensive than compliance" licensee will be cated for a failure to A. Notice of Violation has been changed to " sanctions should report a condiuon or event if it was A few minor editorial changes were be designed to ensure that a licensee aware of the condition or event or if made sunilar to those made in the does not dehberately profit from enough information existed that the previous sections. For example. the velations of NRC requirements." nis licensee should have been aware of the word " licensee was changed to change was made to clanfy the ongmal condition or event.The policy has been " recipient" where appropnate to reflect intent that beensees committmg clanfied to indicate that a licensee will that under the recent change to 10 CFR dehberate nolations should rece:ve not normally be cited for failure to L200 and L201. non. licensees may now h2gher sanctions to remove any benefit report a condition or event unieu the be the recipients of Notices of Violanon.
attnbutable to the violation. lf this licensee was actually aware of the provision were reed literally, sanctions condition or event that it failed to g, gjyjf p,3,j,y for some inadvertent wolauons of nPort. 1.The provisions of the policy technical specificebons would be in the 4. A clarifying example has been providing that generally. civil pensities milhon. dollar range bd would not likely added to the section on willfulness to are imposed for Severity 14vell and 11 prevent future nolations.The indicate that inadvertent clerical errors wolations and are considered and Commission has concluded that the in a document submitted to the NRC is usually imposed for Seventy 14 vel 111 purpose of the enforcement policy to an example of an act that does not rise violauons have been changed. First. the deter future noncomphance would be to the level of canless disregard. policy has been changed to indicate that better served by reservmg auch mitigation factors may be apphed to sanctions for deliberate nolations of IV. Enforcessot Conferumons
. Seventy Isvel II violations. The purpose NRC requirements. -
A new section has been added to the of this char:ge la to prvvide additions! II. Statutory Authority and Procedural policy contaimng a desenption of the incentives to hconsees to identify. Framework circumstances under which enforcement report. and correct violations. The conferences will be held and the existing policy that mitigation will not The statutory authonty section has information that should be discussed at be allowed for Severity 14vell been rensed to note that sectiona 84 and such conferences. The nferences in vio!ations has not been changed. 147 of the Atomic Energy Act. in sections IV.B and IV.E to saforcement Second. the policy has been changed to addiuon to the sections already conferences have beet deleted and the delete the words "usually imposed" for entxersted. authonte the imposition of substance of these provisions has been Seventy 14 vel !!! viola tions. Ins te a d, cw.1 pensities for noletions of included to the new section. civil penalbes will be considered for i
Fed:rst Regist:r / Vcl. 49. Ns. 47 / Thursday. March a.1s64 / Ritles end Regulations 8385
, these violations.nis is cocaistent with this chang. fewer small penalties will licensed activities to prevent violations other changes to the policy that are be issued. particularly for toectors. of regulatory requirements. lf I being made to ehminate the many In considering prior performance, amaller penalties that have been laaued management causes or condones )
prior enforcement history including violations of regulatory requirements. j to reector licensees for violations of previous Seventy TV and V noistions in as actions wGl be appropriately lener safety significance. the area of concern, and escalated l m..nlated.
- 2. Several changes were made to the . enfortemert acnons will be considend.
factors considered for mitigation or Third. the language on escalation of a For reactor licensen the Systemahe escalation of a penali~y. penalty far duration and the use of daily Assessment ofIJeensee Performance
- a. Prompt identificetic.n and (SALP) retinge will also be considered in dvil penalties has been clanfied.ne reponint-N reference in this factor, determining whether mitigation or policy did not explidtly allow for and in the introductory matenal, to self. escalation is appropnate. escalation for duration other than d selosing incidents has been deleted. thmud daHy dW penslun. In some d.PriorNotice ofSimilar Evente-This provision has been difficult to ne only change to this factor was to casea. it is desirable to escalate a dvil implement. and the Commission has increase the percentage allowable for penaly fw duration without auns:ng a determmed that self-identification and escalation from 25% to 305 for the daDy dvil penalty.The language has reporting should be encoursged to the ressons desenbed above. been changed to provide for this.
r.9s umum extent practicable. Wrefore, e. Multiple Occurrences-The 4. h language mgarding Commisen". credit of up to 50% will be considered for percentage for escalation in this factor approval of nasuance of proposed any violation promptly identified. was changed from 25% to 50%.1n penalties in excess of 3.75 times the l reported and corrected by a licensee. addition. the qualificadon on when this maximum civil penalty for a single The amount of credit to be gwen will be factor may be und (when NRC Seventy IsvalI violation has been l based upon the esse with which it was identifies the violation or for violations moved to the section on Raponsibilibes identified. Thus. leu cred t w U be given suociated with self disclosing * (Section VII). for self disdasing incidents (such as incidents) has been deleted.ne 5.h language regarding focusing on acute overexposure that show up on Commission believes that escalation of film badges) than for violations the fundamental problems has been a penalty may be appropriate where clanfied as described in Section Ill discoscred dunng a licensee audit or multiple examplu of a violation are .have, surveillance program. but some credit identfled, regardless of who identifies may be given if appropnate. g. A number of changes were made to them. However. escala don under this
- b. Corrective ocoon to prevent factor may be offset by mitigation for the dvil penalty tables: ,
recurrence-The pohcy has been prompt identification and reportma of a a.Sofsponfe-Tabla 1A was revised changed to allow for escalabon by as violation. to establiaS the same base penalty much as 50% (metesd of the previous 3. Three other changes regarding amount fw safeguards vMations fw 2.%)if corrective action is not prompt or escaisuon of penalt:es have been made. reactorlicensees regardless of the if the corrective action is only minimelly First. amaistent with the ad6 bon of the estegory of matenal. This was done acceptable. Mitigauori of up to 50% will factor on past performance, the policy becauw the orig:nal daignation by be allowed for unusueuy prompt and 1AEA of categones of matertal was not now states that in cases involving extensive correctae actions. Previously, willfulness, flagrant NRC-identfied intended to refer to reacter facihties. the pohey contained four escalatmg violations, repeated poor performance in De upper limit for the base penalty wse factors. each allowmg for 25% en area of concern, or senous selected because the safety escalation. and two mitiasteg factors. breakdown in manage'nent controla, the consequences of reactor sabotage are each al!awmg for 50% mitigsuon. NRC intends to apply its fuD conaldered equal to the safety Howeser, emce the Commission is enforcement authonty where such consequences of then of material from a adding a factor for performance that action is warranted. Second, a statement Category 1 fuel facility. allows for up to 100% mitigation or has been added to clartfy that escalauen, neither the escalanon factors management involvement in a violation b. Materials Lievnsees-De bue nor the mit:gstion factors will add up to penslues have been adjusted for some may result in a higher sanction but the categories of licensees. and base 100% instead. the amount of possib!e lack of such involvement does not penalties have been added which apply escalation wiu be equal to the amount of mitigate a penalty.This change is being possible mir'6auon for each factor, to uranium mills and conversion made as a result of the decisions in facthties.These changes were made es e
- c. Enforcement history-This factor Consolidated Roy Semce Corp, ,,,,g, og ,,p,7;,,,, y,5,,g g, ,,7g,,,,,
has been revised to provide for up to ASLBpW ~107.17 NRC 603 (Apn! 100% mitigat on of the base ervtl penalty 28.19c3) and Atlance Atacerch ALAB * 'P fur pnor good performance m the , ',*g,
'9p " ,' gg SN.11 NRC N1 (1980) in which an general area of concern.The pobey also Admirustrative Law judge and att vanous licensees with thetr health and irovides for up to 100% escalation Appeal Board, respectively, decided to safety signdicance.
(increased from 255) for poor Jnitigste two evil penalties because Table 1A was revised to increase the performance in the general area of management was not direcily involved bene civil penalty to St00.000 for concern. Under this provision, a ovil in the violations. ne Commission has Seventy 14vell violabons by power penalty can be fully mitigated for a first determined that mitigation for lack of reactor limnaees, except for those offense in so ares of concern or for an snanagement tavolvement could involving transportation, because the offenu m an ares in which no previous encourage lack of management maiumum civil penalty is generally offense had occurred for a penod of at tavolvement in licensed activities and appropnate for such vsolauons urdess lesst two years However, a evil might result in a decrease in protection mitigating circumstances are present. penalty can be doubled if a similar of the pubhc health and safety. The nia wiu also result in an increau of tl a violanen occurs withm a two year Cornmission expecta management to be basa evil penalurt for other seventy pened it ts espected that as a result of closely involved in the control of levela.
[ SSS6 ' Feders! Register / Vtd. 49. No. 47 / Thursday. March a.1964 / Rules and Regulations C Kacletion a/Kaforsesiant Sonssions - the examples prwided in the policy are was made to one e : ample of a Severity Table 2 has been changed to indicate confusing h include 75 LCO Isvell!J Holahon to bring the example that a civil penalty might not be imposed Malations inv nas a loss of function as into cJoser soolormonae with the for the Arst Severity LevelIU violation examples of both Severity laval11 and relative alpificance d similar examples in en area of concern or for en offenu in Seventy 14ve1111 violauona. ander other severtty levels for this ' en area in which no previous offense Funbenom. Sen example for supplement. had occurred for a panod of at least two Severity !* vel HI includes a -deyaded a.Septement F-44:nor changes > yeare Dis change is consistent with the condiuon and sufficient halormation were made to thh supplement to ensure change to the factors ellowing comp!ete existed to alert the licensee that he was that a graduated approat.h to violations snitigation for good performance in e s an och stalemaet condshon" which was adequately dancribed in the
,,,,g,,,,,, does not take into account the factor examples. i that la most oftea considered in f.S,p/,arant VI.- M nor changes D. Ae/ofedAdrrinretretire Actione determining the severity level of a TS were made to this supplement.
%e refersaces to enforcement %deum se saky sipihcanoe af the g. Supplement Vll.
conferences have been deleted and their system invdud in se ndauon.& L Examples were added to this omrn is clardying &m examples supplemene to addrew se Cn-man . subs'ence has been covered in section IV. Eeme a inor edatorial changes have by dekting te reimaces to loss of function and degraded condition and b Y increasing cencem with violations cleo been made. involving falsification of records.The prending more expbcit examples based YL Raspuesikslieses upon the safety alpinesace of the Commission views falaincation of Md86E D8 ***mpl# prodded, two records which the NRC requires be kept
%is section has been changed to affect the penent responsibihties of the to Severity 14 vel El and two in Seventy to be a serious concem. De records are Regional Administrators and to seflect I#I.IV, were chosen as fairly obvious required to be kept to enable a licensee to adequately control the safety of its ex;stmg Commission guidance regarding asamples of signife. ant and Is" keenud acWun. in Mditon, when Comminion consultanon is signmcan mlabona.
required. la sddition to the *
" * " ' deliberate falsification of records of significant Laformation by management circumstances previously enumerated in de e am Se h! pomanelis obmesh a unous the policy. Comminion consultation is EL Supplement I because the Con minion Wvu est dmh d violation. Accordingly. violabons .
now required before issuance of any involving deliberate falsification of propond enforcement action that d **If
,'g n. "8 '" "8 significant records by or with the involves a Seventy levelI violation or a material false statement. Commission 1%e words "when the reported I"'*I'd8' # """*8'"*"' ""
matter does not constf tute a violation- considered Severity Level I violations. consultation was required before have beeo deleted from Supplement 1. Eieer de%mte falsincaum or issuance of a crvil penalty invoinns times the Seventy invel I values shown 375 Seventy kulIV, because em words falsification by or with the knowledge of are unnecessary. management, of signincent records is in Table 1A. Now Commission b. 5 p desenbed as an example of a Seventy consuhetion is required pnor to No han/ementIl luuance of a cini penalty involving 3 ges were made to Supplement 14wl D vidaba Any othw fals&cahon H. of significant records is desenbed as an times the Seventy Levell values shewn c. Supp/, ment III. exampk of a Sewe Iswlut m!stin in Table 1 A. For reactor opera tions, this ne safeguerCs espplement was t h examples for violabons emount will be $300.000. revised in three ways. Invoinns disenmination against an ygt g $uPPgM8 1.ne present examples wer, employee in violation of Section 210 of The supplements have been changed clarifitd te indicate that it is the loss of the ERA beve been clarified. Viola tions one or more of the elements of access by senior corporate management have in severe! respects. As desenbed below. control ht determines the seventy . been categonzed as Seventy Isvell a new supplement invoMng emerpncy level of a v6olation. violations. Violations by plant plarmmg has been added. In addauan. 2. New examples were added to the introductory language to each of the management abo"e Arst.line supervision distinguish violations relating to the beve been categorized as Seventy Level seventy levels in sach of the tection of safeguards inbrmation of 11 violabona, and wolauons by first.line Supplaidents has been changed to er signincance from those that superneion have been catesonsed as clanfy that the examples are only involve information which would Severi+y Isvel III violations. examples and that the examples aigmficantly assist an individualin an
- 3 & examples regardmg part 21 themsehes Illustrate the significance of act of radiological sabotage or theft of vulations of that type. For saample. violations have been made consistent special nuclear amatenal. with statutory authonty.
ender the old policy, the introductory 3. N failure to perform a proper language for Seventy Level 1 violations h. Supplement Vlll--4mergency heparedness. search at an accsas control point that unter Supplement I contatned the words resuJta in the introduenon of contreband h existtag Enforcement policy did "Very significant notebons irrvolvtng " to the site was added as a Seventy not contein any exarapies of emergency
%e rensed pobey will state "Violeuena Level !!! violabon. Some violabons of preparedness violations in any of the . invsiving for example." N examples search requiremasta aney be consided supplements. However, the Commission provided are examples of violstions that minor. However, the neardi procedure is has been taking estbroement actons the Comminion considere to be very expected to unaever attempts to tigmficant ander the amergency preparedness rules introduce contreband to the site and, and guidance is necessary reeardmg
- c. Supplement 1. when this fatture la demonstrated by the what enforcement actions are i N pohey now inchades vec:abons acsual introduction of contreband.18 la appropriate. Accordingly,the of technical specification hmiting clearly a magnihaant vtolanon. Commission has developed a new condicons for operebon (TS 140s) es d. Supplamarrt /V- Minor changes Seventy level 111 nolations. However, Supplement V'll on Emergency were maale to this supplement. A change Preparedness contairung sxamples of
Fed:ral Register / Val. 49. NA 47 / %roday Marefi 8.1984 / Ruhe crid'Rejula'Uoni $$D emergency preparedness violations of East) sec. EDL M Stat.1940 (42 USC spek R. Statutory Ao6ertry and pseendwal -
, varying seventy.The examples are Secs. Laoo-Laos also isseed ender pub. l Psenswerk beaed upon the planning elandards in 10 wr-411 es Stat sort (42 UAC. Mast Secs. 4, g,, ag,,,,7 !
CFR 50.47(b). Since the planning Leon also temd ende sec.10L puh.1. standards on speesment and 81 180 as Stat. asa as amended (u UAC
- NR s e com 4332) Sece, L?cos.1ste slee leewd ender 8 6n g, l notification are considered to be the l most significant. violations of more than UAC SH See L794. LNE L7m elao sessed en meended Ast of 1974,and es Eawgy Reorganiu9m as amended, j one of these stendards is considered a ender 6 USC 587. 8 LNo alas leoned ende Secess tot af the Atomic georgy Act l Seventy lavel !! violation. No esamples sec in a Stat.ma se amended (42 USC sothennes NRC se sendect taspecuans and of Seventy 1Avel! violations of planning 3133) and S USC as2. Seas. 3.ao0 and IJoe tomhgascas and a leem adm m nuv be standards are provided because the also issued ede WAC sat Esc 1an also escenary e dee6rable to pmmote the law unde MC 363 and esc at puh I exames deinse and ascenry a to protect
- Commission dad not believe that molations of these standards should be a646a. 71 Seet. 575. as amended (42 UAC health w to elahas danger to his or ame). Appendia A also lessed ender sec. e. Secues las sothertsee NRC to constdered as significant as a failure to pd I.91400, se Suus73 (42 UKC nasl.
classify. notify. or respond to an event in soyoke o e@ owum secuaWances
- 3. Appendix C to Part 21s revised to (a4 orf matenal false statements. in a general emergency, the example ,espame w amadances set wedd have provided of a Seventy 14 veli nolation, read as follows:
- warraeud refusal of a beense se as ensmal i The other examples are based upon apphcats,in, k a hes=ani fah te M r Appada f*J" .! Statement of failure to promptly classify. notify, or -
operate a facility is socordaans with the respond to an event. and are -F888 dun I8F taas of ee permit er license, and for chstinguished by the emergency action Enforcement Actions nolecen of a NRC regu!40 eel. Secuon 234 level that best descnbes the event. By De fouewtas statement of poneral pobey authortase NRC to impose civil penslues not
" correctly cleosify." the Commission end procedure explains the enforce:asnt 8','j[
means classify at a sufficiently high pohey and premdures of the UA Nucjear g P"[" Pd'd*7 one of the Act. rules. orders. and proteettve aeuon level. Enforcement Refu!8 tor 7Commaseoa and he etaffin ,,,, i,pi,,,,,,, g, ,,,,g, ,,,,, action will not normally be taken for trutiaung enforcement octons. and of and fw wklebens for which te can W oserclasstfymg an event. pres # ding omcers, the Atosuc Safety and revoked la eddanes to the enumerated ucunsing Appeala Board and the prendons k esches 334. escoons to and 147 List of Subjects in le CMt Part 2 Commaseon in revwwing thm actions Tbs mothmse the imposition of civd penslan for Administrative practice and statement is appbcable to enforcement in violenses of regulanens leiplemeonne those
- procedure. Antitrust. Byproduct surters involving the pubhc bulth and provisiana. $senso 232 authonses NRC to material. Classified irtformston. safety, the coounos defense and secunty, and seek taluscovo er other equitable rebei for Environmental protection. Nuclear ee unr i nels M royhwy requiremata.
secoon me M b Eawsy Rowenismbou q matena!s. Nuclear power plants and I. lasreducales and pwpon* Act authertsee NRC to impose ani penalces reactors. Penalty. Sea discrimination, ne purpose of & NRC enforcement ' for knoutes and conscious fadwee to prende Source matenal. Special nuclear program is to promote and protect the eartam safety laiesmaeon to the NAC matenal. Waste tresrment and disposal. re6ological hulth and ufety of the pubbc, Cbspter 18 of the Atomic Emergy Act loclu&ng unployne' heale and safey b M n k mytag M h d Pursuant to the Atomic EneII Act of comunce defense and secunty, and b ~ penalnes M. mestary Ram and 1954. ea amended. the Energy Imprisonment for willful vtolanons of the Reorganization Act of 19"4. e amended
- ennrona m by. Act and reguleboas or ordere laeued under
- Ensurms compliance with NRC and Section 552 of Title 5 of the United d""""""*"**. Seceans ess 181(b).1810). or 181(o) of the Act.
States Code the fallowing etatement of secnon 223 prendes that anmusal pena!ces pohey is published as Appendix C to 10 Y'"**"'*
"g A '"88 W8""*"
- g may be impowd on certain indmduals CR Part 2 se a document subject to employed try Arins soestruenne or supplyms
- Deterring futum noiebona: and benac componente of any enhaenon fecabty if cod:fication io be effective immediately. . Eamuraging improvement of licen*" the indmdual knowtagly and willfully performanos. and by example. that of nelates NRC requirements such that a basic PART 2--MULES OF PRACT)CE FOR industry,incjueng the prompt identification component could be sientBeantly unpaired OOWESTIC UCENSING PROCEEDINGS and reporung of potencel ufery problem. Secoon 33g prendes ht crtmunal penalen
- 1. The authority citation for Part 2 conswim wie the pwpose of this my be impaud on pomons who interfue continues to ryed as follows'. pmgmn. prnpt and nporous enforcement with inoppetors.
ecuon wiU be taken when dealans with Secton 238 prov6 des thet ana!nal psaltaes Avtberity Sece. 101.181. 88 Stat. 94& 953. heensees who do not scharve the necepery may be lmposed as persons who attempt to es amended (42 U.S C 2201. 2231), sec.1pt. es owtaculous attennon to detail and h high or cause esbotage at e nuclear facthey or to amended Pub L s7-415. 76 Stat. 4ce (42 standard of compbance wtuch the NRC suclear fuel. ADeged or suspected cruninal U.S C 2241); sec. 2Dt. se Stat.1M2. as violanons of the Atomic Emergy Act are espects of its hcenases. It la the amencied (42 US C 5641). 5 UAC Set %,gs intent bt eencnons should be aformd to the Deparament of lussar for Sec.1101 eleo issued under secs 51 et 63' designed to ensure that a bconese does not apywtm acnee.
' 8 '
337 md 2 S 3 dehborstely profit from violanons of NRC 3. hacodure/Mussened 3CWL 2003. M11. 2133 nM. n36) sec.101 mqviments. Each enbrome scan is dependent on the circumstances of the ca" to Gli part 1. Subpart 1, of NRC's Pub L pt-teo. so Stat. a&3. as amended (42 regulattees sets forth the procedures se NRC US C. 4332); eec. 301, as Stat.1244 (42 U S C. and mquame the ewem of dasenton ah" sees a esercases its e.soriament authority. tril Seca. 1102,11GL 2.10s.1105. 2.?n also ansadention of thm pobcaos and to CFR 3Jpl ese furth alw procedures for issued under seca 101. 103.104.106.183. 180. Procedume in no case. bowever, wtX tesuing asesse of vulanost - es Sta t p3h 337. 534. afA. 955. as amended 142 hcarmose who cannot schwve and saatat41a The preesdies to be need in eseessing c!*tl U S C n32. n33. n34. n35.1233.1230) Sec. odeqwte Levels of protecton be permutted to penaltes le est forth to 10 CFR Laus Tbs 1105 also issued under Pub. L 57-415. m emoduct bconsed ecovitsea regulehoe provides that the appropnete NRC Stat. 20*3 (42 U.S C 22301. Seca. 2Juh2 208 Ofbce Director tesnates the avd penalfy also issued under secs 186. 234, to Stat. 365. ' Aactreet enfortsment manere wdl be Josh ettb Process by issuing e nohor of Motscon and 43 Stat 444 as amended (42 USC 2236. se e cose in <ase bass 1eroposed unposinoe of a civd penalty The I
35a8 Fed:ral Register / Yd 49. No. s7 / hrsday. March s.19s4 / Rdes and Regulations bcenne le provided en opportunity to conteet particular type of violation of NRC apportentty to espista to the NRC what in wntme the proposed imposition of a civil requiressents Each of b enamples in the corrective schane (if anyl were taken or wul penalty. Aher evaluation of the bornese's espplements to prosbcated on a violation of a be taken fouowing d anovery of b potential response, the Duecaor may autsats, resut, or reguletory requineuettt. Molauon IJeanases artu be told when e de= pons the civil penalty. An opportunity is in each cess the sever'y of a violation wtD meeting la an enforcement emnference. provided for a beartag 6f a dv0 penalty la k choreciertsed at the lewl best oWted to Enforcement eenferenese erW mct oormaH) imposed the eWeemme s' *h . particular eteinhoes in be spes to the pebbe, ne procede for leaulns an order to show some asset. viobtions may be evaluated a When anoded to prenect the public health eeuse wh> e beense should not tue mo&fied the agrepen wid e engie severtry isval and safety or commas defense and securny, suspended or mvoked or why such other magned for e group of vloistioso. oscalated enforcement actm such u W eeben e%ould not be taken le set forth in to The severHy leesi of a noleuen sesy be teouance of en teamediesely eGectiw order 072.202 m mecheniesi for modifytng a mothfytmg --_ 5 or revokmg a heense. bcense by order is set forth in to CPR 1JDt. ticroned af the chumstances serrman&as the metter involve carelew &aregard of will be taken prior to'the enforcement These sections of part 2 provide en ,equirementa, deception er other in&cauona ensferones. In such coese. an enforcement opportentty for a beartne to the effected of wiUfulness N term *wmfulnen" as esed snaference may be held eher the secalated hornaee. However,the NRC to authertsed to here embraces e spectrum of violadona enforcement act6an to taken. make ordere imme&stely effectswe if the renpng from 4ehborow latant 2 weiau or public beelth safety or totervet so regetr" falsdy to and includmg carelses sherogard for E Enfaament Anne e . to the case of an order to show canoe. tf requimmente. Willfulness dem not include his section describes the enforcement the sueged noteboo is wGlful. acts whach do est rtu to the levd d cepeneen 'eanctaans evallable to NRC and specifies & El. Severity of Vimiedemo disregard eg. Inadvertent clonel errore in a condibone unde whid each may be used Regdatory requirements 8 beve earying document submitted to the NRC. in ne busc sanctione are notices of violanon. . desma of nefery, esfsguaeds. m g,g,.sunmg h spechc wvey W1 of a dvd peuk ud wdm of vene we etalation involving wilitans. annedwetten Ad&bonaUy.coisted admisestrabw ennronmenul significance. newfore. the wW be 31vu 2 M facere as b paina of
' " " be mW- M u Memd in tl e the person envolved in the noisuos (et, confu' ustory acnoe letters are esed to n Aret Erst hne espernear er senaer manageri. the supplement the enforcement program. In Consequently, violacons are categorized in s W ea any ytas noteum es selectang Se enfortuneet sancuona 2 be terms of Ave Irvels of seventy to show their latent of the stator (A seghgence not appbed NRC wtU sensider enfort.ement renouve importana wtthin each of the amounung to enreleas daarogard carelau accons taken by other Federal or State fouowing eosht actmty ames:
daemgard or denneunmal and er mgulatwy biedses banas concumt Reector Operanons. Fadhty paastreedon: econonus advantage. If any, samed as a ke&eum such as in transponation Safeguerds. Health Pbyelos. Tre.nspetanon; muh d se Woum N nlaun wngM manen We wry hmned excepum. Fuel CycJe end bestanata Operations. pven to each of taese lectors in arnvmg at whenever e otolation of NRC requirements is g ,c,g n g gi, a d gm ,,,,ncy the appropnata severity level will be identined enforussment sceen is taken The Preparedneu dependent on the circumstances of the nature and extent of the saforcement acuan lacanud actmt es not directly coeured by mlatin to intended to mflect she eenousons of W ene of the above Beted areas, e4. expon The NRC espects bceasses to provide fuu, stolataan anvolved For the vast majonty el bcense activmes. will be piecod in the esteplete. tunely. and accureto informenon noisbona, action by an NRC reponal ofhce cetmty area most sunable in light of the and reports Accorthngly, urJess otherwtae le appropnete in b form of a Nouce of perucular wolacon invoived %than each cowgodsed in the Supplemets. the severtry Violation requirtne a formal teoponse from seunty area. Sevent) Imil has been level of a violanon involving the failure to the rectpient desenbang sta correcove acuens cos; sped te noiations that are the moet make e regelred report to the NRC will be h relatively smaU oumber of cases ngrJcant and Seventy 1snl V nelatsees based upon the eisruficanoe of and the invoinns eleveled enforcement ecuen are b last stenificant. Seventy level I and arcumstances namndag the matter that rewives substanhal attenuon by the pubhc.
!! notaboos are of erry standicant regulatory should have been reported. A bcensee will and may have significant impact on the noncars In general, nolauans that am not normaBy be sted for a failure to report a hannee's operahn nese eleisted included to these seventy catesones savolve con &uon or event utdess the beenese was enfoament acuens include cml penalt.es.
ectual or tugh potennel unpect on the pubbc. actually aware of the condsuas or event orders anodifymg suspentbne of reiokms Sevenry 14 vel m nolabons are cause for whie it faded to report. However. the boer.ses. or orders to cesse and desist horrt magniLeant concers Seventy Level N seventy level of an unumely report. in designated actviues. molauona an 6eos senous but are of more contreet to no report. toay be reduced j, g,g,, ,f g,j,,,,,, than sunor coomes t.a. ifleft uncorrected depen &ng ce the arcumstances surroun&ng they could lud to a more eenous concern. Se matter. A moboe of Molshon is a wntten notice Seventy Lsvel V nolations are of ounor es ng f nh one or som nelabons of a N Enf8"*" Conf"" legaDy btadmg requirement.The not ce esfety or ennronmental ouncarn. Campansons of sigefunce between Whenever the NRC has learned of the normally requaru the recipient to prende a ecenty areas are mappropnata. For example, andatence of a potennel violacon for wiuch a wntien statement descrNng-(1) corrective the unmedisey of any hasard to the pubbc C"1 enalty P or other escalated enfoament steps wluch have been taken and the results casociated with Severtry bevell volauons in action may be warrented the NRC wiu echieved (2) Correcuve steps which siill be Ructor Opersoons is not darvetly normally hold se enforcement conference taken to prevent recurrence and (3) the date coopersbie to that associated enth Severtry with the bonneee pner to taking saforcement when full comphance wG be achieved NRC te el I noistnne in Reector Constnacnon. acetoa. he NRC may also elect to bold an may require responses to aonces of While examples ero provided in enfoament omnferwoos for other nelanona. molations to be ender settL Normany. Supplements I through Vu! for determinmg et. Severity Isvei IV violaboe wtuch, if reponaee under oath wG be mquired only in the appropnete seventy level for nolabone is foPeeted could lead to enanlated sonnectaan with ctvu penalbes and orders and of the etsht econry areas, the naamples enforcement nedon, h purpene of b NRC uses the met 6cs of nolaton as the tre neither echausuve mot oostrolhng. enforcement scalarense as in-(1)Ihecuse the standard method ler fartmalians the Noe esemples do not create new violauana. their espuLcanas and cauess and emissence of a nelsharL A mouce of violat on requirements Each as designed no illustrate the b-wa careenve acuena,it) is normally the only* enforcement scuon the stgrdc.ance which the NRC places en a determine whether there are any esgrevettag taken. except la cases where the entens for er mittseting circumstancma. and (31 obtain civil penalt es and orden. as set forth in
. g % .,,,,,,,,,,, m ,, g 4 other informabon wtuch wG help determise Sectaans N.B and N.C. roeper Jvely, an met omane e neper bad.au rweessi esca es a the appropnate enforcement acton in euch cases the notace of Molet on will be em neces,a wense sawsum enormal la addthon, dunne the enforcement lessed na smopunctaen with the eleveted sowhear. er weer anaference. the hoenase wt2 be even an acbons.
I Federal Register / Vol. 49. No. 47 / Nrsday. March S. tese ( R ales and Raguhtitma 3389 I l*
' secouse the NRC =ents to sweeurege and mqulmment hadading theme at ear erumsty homossue. Ahor - - " ' . dl relevant support heenen 6netieues for wo- lenL serw-m atestemme to these valoas
identificzens end arracuss of pebiusa. NRC tmposes di5erent 1seuls of penables may be anede gar the fecepre drecribed below: NRC wd! not generally issue a nouce el for different anerity inal Weissens and 1 Amupt Idassifnascas amufArporfirg. noteboe ler a vinte&aae thed meets all of the diffement cisnese of baseamet Tobine SA and Reductasm af up to spE af tbs base civu fonowung tests: 13 show the been chwel pensitsee garearlems paneby mer be g>sua urbse a hcsasse (t)It was identified by the licensee; reasser, fuel cycle. and matertels progroans- identmas es Wetates and promptly reporte !' (211t fits in Seventy Idval TV or Ve The erusters of these tables genemby tekee te vwisten h es NRh Wghing mie (3)It was reportedJ required: less eemment the grevity of the useistas es a facaur.esmeldersese we be gpven to, among
- (4)It was or will be correctet hidedMg ynmary amenduretame and the obehry to pay ,g ,, g g , 4 g g ,g ,, gen,n meesures to prevent tweerrence, untun e sa e semmthary esasederness. General}p. esksed W W %.tlw opWW roe pensWe time: and aparations ineelvsag greater euelear meterial available to dienaver the Weistion, the sese (51It was oas a venetme that asund taverunnes and pressar posseteal masonably be aspected a have bene eew to tlw pubbc and basemos af peamrF _amd du preemptuoso and prevented by the beroese's casrectm action eenployees roomin hgher dvd penalues. -- --- - "I*F'*4*I" O " P'
- ammsiderston wCI be pwm m this lector if for a prenous noletaos. Reg the encondary damer of abihty of Ucensees am not enimarily ated for ennous aan of hosesses as pay the evil the Rosasse dose met teko immothan action nolations resulting from mattm not wittun pasenes it is est the NRC's intestpon thM to amend she problem spee discovery.
their control. such as equipment fattures that the scenoense impect of a elvu penalty be & Cormative Actfes de hetent Asevrrerms wen not avo-deble by mason)bie bcensee such that a puis a bceanse est of basenne Recopalsing Giet sorreceve action le alwaya quality eseuronor meneurn or siemagement [ orders, rather than avd penaltima, ese used requimd to and mguhtoey ay--* ' controls Generally, however. bceneses are when the Latent is to termaste besased proumptasas and entent to ubich the beensee beld responsible for the acts of theer actmhesl er adversely aHects a bounase's takes normctive acuse, hcludmg acnons to ampicyees Accordang!y. this pebey should abdity to safely conduct h==ad actmties. prevent racermacs, may be considemd in not be construed to escuse personnel eners- The deterrent effect af ovu penaluso is best modifytes the dv0 penalty is be aseeeeed Enforummere asoons arvolymg tndwiduals. surved when the amounts of such penelues UoveueDy prompt and extensin correctfve incJuding Ecarmed operstars, wd! be take into account a bonnese s *abdity to action may reemit in reductag the proposed determmed on a esee-by-case bests and must pay? In determining the amounts of avi! civG posairy as much as 80s of the bene be approved by the Director of the penalues for heensen for whom the tables valus shown in Table t On the other hand. moponsibla program OfMce.e do not reDect the obtuty to pay. NRC wi!!
- die cMl penalty may be tacreased as much asesider as asosemary an increams or as nos of the bene value if injuanan of
# CrdArndry decrease on a case-by case bass. earreenve action is est prompt or if the A ovif penalty is a monetary penalty that NRC attaches prest importance to sometive action is only mimnully may be imposed fee notanon of (a) Certa a comprei.ensive Lcenace programs for acceptable. la weighing this factor, specified Lcensing pronsions of the Atorruc deWm. mm ad mporW d W be p E e mo g oth e Energy Act or supplementary NRC rules or probleras that may construta. or lead to, tidags, the timehoses of the serrecttn senon.
orders (ty any rewaremses for which a beenee may be eriokad. er (cl reporung nokumsf reguhm sghW is emphasised by smns credit for efectrve
@ d h m m ud
~,eness of the omrreeve octaae -
mqmments under Seenon f the W bcenese secht programs when hoenaeve find- such as whether the actuam is focused somet and npon probleets espeditionalY marrowly to the specille vielenos er broedly d s gned7o e phaa t e need ting
**d doctvelyJo **#ur*8e LC8ne" seU to the general ama of osacers.
remed.al action and to deter futum violatona. W*"I'b**'"* **d **"*"38' N *** 3Aef Arr#ormance. Redochon by es much GeneraDy. cm1 penetues am imposed for and to avoid potential concealment of as not d the base ded penalty abwn in Seventy Lased I nolauens are ireposed problems of safety sts:uficanos, appheation absent mmgetmg circumstances for Seventy Table 1 may be geen for pner god Lent Il nolanona. are considered for of the adjustment factors set forth belew mey pedormance in the general area of concert mouh in no avd penalty being senseaet L On Iba ether hand, the bene avd peaky msy Seventy Lsvel III notamona, and sr.sy be nolations winch are idennfied reponed (if imposed for Seventy IsvelIV notations that be incruesd as much as 100% for pnor poor are sinulst
- to pronous nolatsors lor whach mquimil, and ebetnly cometed h as performance is the generet eres of concers hmnase. In weighing this facter, eensiderenon wdl the hmnase d.d nce take effecove correcun Ce the othe band, kneben hans" acnon. he given ta, ameeg other tharga. the In applying this guidance for Severity 1sval Programs for problem idenuncation or e6ecovesess of prenees correcove acten for concuam an unacceptable. la esses gnBar problems oveell pedormance such IV nolanons NRC normaUy considm ent penalnes ortly for simMar Sennty Lsvel IV nag wdl. Dogmat NRNuned as Systematic Ateemasset of!)censee nahtons. mputed pow pwfwmana 6a as performanas (SALP) ovaluauons for pown nolstions that occur efter the date of the last inspection of enthin two years. winchever asse of concern. er eenous breakdows is m W p enforcemeM histor'y management controle. NRC latends to apply tecludlag Severtty 1.svol !Y and V nolations penod is g teter. .
its fuu enforcammet authortty where such On! penalbes ws!! aormally be ammed accon to warranted, includag issuing . h b m M - N mk. fauure to for knowmg and conscious nolabons of the kaplement pronces somente accon for reporung requirements of Sectaon 20e of the appropnate weders and eseessing cin! pnor similar problema may result in en Enevy Reorgarasauon Act and for any penslues for coottaumg notations on a per wd1M notauon of any Cosamtsaion esy be ta to the e a u t 4. pr,or Norm of&]arIryri The bese management invcivement. direct er todirect. evd penalty may be lacreceed as much as a W ma of te Asame gewsr Am ove h 305 for cases where the heemase had pnar is e nolanon seey lead to an increase la the C**"*'"'** *" ** "*",,',*'".l"j* '" anI penalty, the lack of such involvement kanowledge of a ph as a resuh of a beansee sedit, er spesenc NRC or edustry b . "see.$ tUma.Ar.A is eachwe may act be need to auttgste a eted penalty. Allowance of mihgernos could enco lack aetncatism. and had faded to take effect" eie e e varwe, .Iweammanom and any seervesmauves er eeeets. Tbs swa the of management involvement la h pM4BIhe shops-Ceaumasian evthenry se tapene cett! peutume se acevtun and e decreses is protechos of the 3EuAtgWe Omarrones The base cin!
.mpiones enormose er se orperow enm"* pubhc bealth and safety. p***!'r may be teoreased as ont as 50%
e naisuas af s i=muremoni erecoy onpased " NRC mvwwe sech propeaed det! penalty where multiple naampin of a partcular
********"" case se its own merits and adjesta the bene stelat6am ase 6 demented daring the anspectu
- T%e owd *eimdarf as used in this pahey, refers M pomby epward w hward perted.
appopneWy. Tebnee 1A and 13 6denefy the The above lessere ese addsure Howevw.
'* N t ra $ ts he been krmsev e aervacun ecnas nor me prevsees ad by the base civu penalty values for different la as testance wd! a certi penalry for s.sg ow umm seventy levens acevtry atuaa. and ciasese of vtalauen sansed tscuno per day.
- l 3590 Fedeyel Register / Vd. 49. Na,47 / Thursday. Maych s.1s64 / Ruhs cad kegulatirns The duretion of a violation may elee he violation may be losessed to mfiset the (a) When a boensee le osable er unwithng eensidered in assessing a civ0 penalty. A edded significant seemlung Imm the 9 to esoply with NRC requwamente. g yeeter civD penetry may be imposed if a duretce of the vtalebon- -
vtolause emanause for more thaa e day. For (b) When a homesse solusse is earrect e De Tobies and the mitigaties factors ,6elausa. ' emaseple- dowmine the utvH p.s!bw whid any be (c) When a hoseses' dose est respond to a (t)1f a beenese ne awere of the salatense of eseessed for each vnolation. However, to f a sondluon which results in an esgotes focus en h fundamental underiytes seesee mouce of wklause where a e nu i vtalaban and fails to inicale earrective of a problem for which enforcement achen "9"I g
- I acuse. eed day the emedauen enested may appears to be warrested, the moeulaties had (d) When a besc me pufsees to gy a fee ,
he sensedered as e separate violation and as for au violeuene which contributed to er sulaamd by 10 M Perm er each. embrect to e separete addataceal cevil were onevo6deble eenseguences of that (e) For any other reasse for which penalry. problem may be beoed so the amoest abowe sevocation to sotherteed seder Eschon ses of , (2) N e 16a===== le unawere of a sendjtjen to the table for a problem of that Severtty the Atende Energy Act (eg., any esadiuon i pseultans h e asetaauias violabors but clearly Isvel as edrusted if an evalastaas of such which would warrent Wesel of a bcomes on abould have been awere of the condiuos or meluple vtoletione shows that score thaa see no artsmal appleceoon). ' had en opportunity to eermet the asedinae fundamental problem is involved. eed of but failed to do so, e separete violaties and (4) Cease and Denist Orders am typically eehich,if viewed ledependently esund need to esed 2 emp as meseewted scuery ht hu saendant cfvil penalty may be seasidend for envil penalty acuse by itself. thee esperste meetinued after estificaties by NRC ht such l sec3 day that the Loensee clearly should eivU penalues may be asesosed for each and l nave been awere of the condition er had an fundamental problem. in eddition, the fatture ecMy le enseewmed opgertunity to correct the senditaon, but to make e requwed report of an event Orks am mode deem samdieusy. laUed to do so. requiring such sportmg is manandered a Weout prior opponeelty forbeenas. , (3) Alterneuvely whether er not a bcensee seperste problem and will normouy be whenever it is deterauend ht the pubhc ) is awere er should have been awere of e enesesed e esperate ev0 penalty. tf the health. interest, er eefety so requires, or when violauon ht conunues for more than one bceasse to aware of the matter that should the order is roependag to e v6eleton day, the avd penalty imposed for one have been reported. levolving willfulness. Otherwies. e pnor opportunity for a hearing se the order la Tehle 1 A--Raat Chu. Pennass afforded. For cases to wluch the NRC beheves a basis could reasonably exut for g e-
====wam' met taking the action as proposed, the enessme e=s= owi vas a beenese will ordinar0y be afforded en
'"".* 7"" *
.N. .T. epportunsry to show ceues wby the order abauld not be leeued is the proposed menner.
$Y as - e -
"saE a- "saE.o o seE.
o 'I,.E A E="an ofE.nforummens $saccons a e, we a uno eeenseo s6eno NRC considm violeness of Seventy seen a nasi no ww.mi a====- ==.= icano asen esen levels L R. er ID to be sortoes. If eenoue 8y""'*,,*,*,",=,",*
"_8,',c, g g,_violetaone me or*,e occar. NRC wi!L. wh.ere
.o.,u.coes .,o seensery. ;
.eco. - - e_
a .o
,s a- ,- ,.o e - hte _,sem a we w-$a== n c. ,,, i n; r Y[ "Ue h o,*w**"=="== aw.uE " "s is. esm.e
,,, NR mivf ic cem rumou unrems oss ampumus se namen, , the circumetences of each case in selectmg ders
"",",",,C,","d"""** " ,, ' ,'" ,-, , " * " ' " ' " ' ".w and applying the uncuan(e) appropnele to a t>= ese== m a-ww= - eum er sous,see m,,,,,, ,,,,
uss eu, sese-. s esmeri ay e ow een the case in ecoordance with the cntene described in Sectione V.B and V.C. above. Tam.E 18--SAsa Crvu. Pumaaits (e) To resseve e threat to the pubhc inealth F.nemples of enforarment scuona that re cais eu or anam,io and safr*y. commes defense and escunty, or ereld be taken for e6milar Seventy level L It the envirveunent: er El v6olations are set forth in Ta ble 1 The seenra er (b) To stop facihty construction when: (1) ectual progreceios to be tseed in a particu'at am a rta o
- Perther work could preclude er significantly esse wd! depend en time cwcumstatices.
S a= hinder the 6dentificeboe or correctice of an Howeve enforcement eencoces will
, , improperty constnacted esfety.related system nerinab, ancelete for recumns etnular
, ,3 er cornponent er (ii) the bconsee's quahty vtalauone.
e ao easurance program implementauon se not NormaDy the progression of enforcement
's adequete to prov6de confidence that E e actione for similar violatloos wul be beeed en
! eenstruchon sceMues m being pmperly violetaone ender a single hornee. When erore sa than see facihty le covered by a omgle c O,*,e - m eermo ,rogree- -u a-d ed. ,ue,el,es ,$e,en,o,se,s . ,a ,, _ -
As order to a written NRC direcove to (d) When the boensee laterferos with h , se similar violations et as tedmdual facihty mo6fy. maopend er revoke a bonnec to eseee enoductpf an inspectan or invastagenon; or , and not on sunder violetacas ender the earne and desist imes a yven practice er ocevtry: (e) For any seesce not mentaoned above forn hcanee. hm. H abould be _ed cei er to take such othrt seuen se mesy be proper wiuch heense revocatban le legally ender som cismastaname es, whm thm (aev to Olt 2.XC and 2JDs). Ordere mey be eetherised. is common sentrol over some fecet of facihty toeued as set farth below. Ordere may else be ! t asey apply to aD er part of the *Peretiene, sinuar violetnese may be charged tesued te laen of. er la edshban to ctv0 hamnaed eeurity Ortbaaruy. a leasemed even though the seenhuon occrred ei penaltin, as appropneie. eestytty 6e not suspended (nor le a suspeenson a different fadhty er ender a different (1) Leanee Modfcataan Orders are issued prisonged) for failure to comply with license. For saample e physical secunty when ecow change in bconese eewposet, seguirements where such fauure 6e not willful v6elatsee et Unit 3 et a dual emit plant that procedures. or ensnarement centrole as and adequate correctrve eetaan has been popesto an earber violetaan at Unit 1 aught be e*tenaary. takes. eennedered mellar. (2) Suspecanoe Ordere may be seed. (s) Revocettae Ordere may be used.
i?edarsi Register / Vd. 49. No. 4f / liiuroday. March a.1964 / Rules and Regulations asM ,
~
Tasta 2. -Exaamus or pocostesaaon w Es- prus releeoes are not normaDy leased fee 3. A systen' designed to pment er c4Latto Euroacciarut ActoNs POR Sme- NoOCes Of VloiadoD. saitlpte 0 eenous sefety eveWt Dot be$ng eO ( lam vsotAtmas as THE Sag Actwrry Ansa yg g to pedone its latended nefety foncton ' when l UwotatwtS usLcauss actealty emned span to work ( The Directae.Omos ofInspecusa and s. An anddeotal enticahtyt or l ence. . u Enforcement, se the pnncipal enforcement & Raleses of redroecevtry eftstte greater eMoer of the NRC. has been delegated the than tee (10) Bees the Technical
**"**""""* Q,",,"."o,,,T.w,,s se ac
*."",,",' authority to inaue notices of sklanona, ervil Specif6 cations halt.'
ig- ,,, e,e penalbes. and orden.' Regional & Severtty 5-Vlolauses involving for Adnunistratore may also toeve mouces of amample-e.a.a_ 1. A syetes demsned to prevent er mangata a ee a v6olence for Seventy levele IV and V e e e+t e+e+a vialuono and eney sign moucos af violation foe serious esfety penta mot bems able to Semity level Ill violations with no poposed petform lie intended safety function. or a che e.w, civil penalty and proposed cfvil penalty g. Rehenae af mdioecenty ofkla grosser
- 0 actone with the concurrence of Ow Director. than Sve (s) timme the Techsucal
.==,",,,4f.e.*.,Z. se 7d.'*."m "a"m,0% m E in recogniuon that b regulation of Specificanone had
*!T,,"*,,",,",""""' " "f"d"**Tg", nuclear activitin la siany cassa dose not C. Severitt S-Vlotasons involms for 3
=== m as-== lend Itn!f to a mechanie'.ic trutment b ""*"?"
*'"'*""'"" Duector. IE or the Regional Administrator 1. A signifirst eloletion of a Ted.secal asuet esercise judgmeot und discnnon in Spencatun bting Cerubnon for E Mo88ef Adeuniscotire Accons determining the severtty levels of b Opersuae where the appropnate Action in additan to the fonnal enforcernant nolatione and b appropnate enforcement StateM was av sensned wh 6e nme eiecherusms of notaces of nolanors cml sanctions, includmg the deosion to impose a aUoned n We Acton Stawenent, sud u penalnes. and orders. NRC also uses s. h pre.surtsed wewe meets,in se cm! penalty and tbs amount of such penalty, m e modnAaving one Spmum Gmirustreeve circulers. Informacon notices. genenc letters, mecharusma, such as bulletma. after considerms the pneral petnaples as of this afety injection pump inoperable for e peno sentement of pobey and b technical notices of densnon and connnnatory acton I" ****** " ** *I * * * "
etsrufscance of the nolanone and b statement or letters to supplement its erJorcement surroundace circuenstarm k n e boWas wetw meetc% one pnmary program NRC espects boensees to adhere to no Comaussion wiU be provided wnttaa
- e the ow ce fm se racessa not hes a to ,, ,,,,; ,,
e make sum Rat Comnuasaoo will be consulted prior to taking
'Hye
, 8p{pna e g. A erstem designed to prevent or mitgete
- PC*Not 8Ctio818 I Ilowin8 8dru8 bon 8 e eartons safety event not bems able to (11 Butienne. Orculars. Informe6bn Nonces (unless the arsenicy of the atuacon d ciates and Genene Letters are wntten notficauens pe, form its tatended function ander certarn I"" ** *#"'"I cond2tions leo safety eystem not operable to groups of beensen tdennfymg specific (1) As action affecting a heensee.s unissa oEsite powerle available matenals or problems and recomrnendmg spectfic actona.
opnacon ht requirre balancmg the pubbc components not environmentaUy quahfied) 121 Notices of Drnanon am wntten nonces descrfbmg a bcensn's or a vendor's failure to beslth and safety or commoo defsnee and s. Dershence of defy on the part of nusty a commitment mbers the comnutment secunty impbcanons of not operstmg with personnel involved in beensed settrities involved has net been nr.ade a nego!!y btadmg b owenal P radiological er other hasards & Oangn in mector parametm which requirement. A nonas of devianon requests a ***oC284d with conunu8d oPersBon, cause unanWed reduccons in marg 2ns of bcensee or vendor to provide a wntten (2) Proposals to impo e cri! penalties in safem explansnon or statement descnbmg amounts 3 ester than 3 tunn the Seventy L Release of radioacuvity offsite 3 seter correcave steps taken (or plarmed). the LevelI vahzes abown in lable 1A; than the Tech:ucal SpeciBestions bmit or results schieved. and the data when (3) Anf proposed enforcement actice that & FaGure to meet the requirements of to correctrve acnon w1U be completed, tevehree a Seventy LevelI nolation CFR E54 such that a mqmnd bcense (3) Con $rmatory Acton 14ners are letters (4) Ariy enforwinent accon that tavolves e amendtoent was not sought, confirmms e bcensee's ag eement to take findmg of a material false statemeeg D. Seventy IV-Wolenons invoinns for certain accons to remove s:g uficant (5) Any acean the Of5cm Director bebeves example-concerns about health and safety, safeguarda, warrants Contniss}on tavolvement or L A lesa sWeant hon of a or the enytronment. (6) Aary proposed enforcement action on Technacal Spec 2 canon hung Condition foe OPersbon wbers the oppropnete Acton F. Referrels to Deparunent of/usace which m t-- uka to be consulud. Statement was not setiaSed mthin the tme Alleged or suspected enannal notabons of M b&stsetty Categne6se aDoned by the Acton Statement each as: the Atomic Laergy Act (and of other relevent a. In a pressunted weter reactor, a 5% Federal laws) are referred to the Department #**# D" deSoeney la the required volume of b of lusuca for mvestasacon. Re ferral to the A. Severity WViolations tavolving for enndensats storage tank or Depar*Jnent of lushce does not preclude the example: b6 la e botbag water fonctor. oco NRC frorn takmg other enforcement action 1. A Safety Umft es defined in 10 Olt oubeystem of the two independent MS!V under th2s General Stateenent of Policy. 60.36 and the Techrucal Specificanona. beu:g leakare control subeystems inoperable. However. euch actaons mE be coordinated sisonedad; mth the Department of jusuce to the extent ea5yress" es emed en esse sweptemesh trdades practicable. e h Danem of the ohne d Nedest Amectae assun.susnes and meneemnaJ esseen eysteins as Eersistama and Nachsar his wnal Salery and wed as potreneal erstmas g g p , % ,,,gggg ,,,,,,,,g g ,,, Safeguents have anse beam delegated sender Metended safe 4 hecuse" means the total in accordance setth 10 CFR L*g0, all sotheney has it is sapseted that sermal mas of this endet fumeten and is sus truewd towasd a hvee of enfartement actions end hcensees responses authenty by NRJt and Nbts$ eri!! he senaamd to sedendamey. Per ==taa smaandenerj e SWR 4 hien are pubhcly availeble for inepectaon. La ecoers escoesary to the inw,ast d ph W pressem M espehu@ to Meems mien rusun skistson. press reieanes are generally issued med anW m Dneterm W Admumannen, en se Waldenen of bee W and W
%- _. A lume eiens enheysten dose met for evil penstbes and endera. la the came of has been de6ee,ntodf--the se. tbanry se lames eribres ordere end eml penalbes reisred to
% 3,,,,,,
h W the esweidad safeet h a W a* neup,yi,,,e h fees a is % w eener euherome h e,wm noistens at Severity 1svels L IL or IIL pr,ea n.e ,. sew,et,em of emme w au d thans eThe Tecamenal SomeAestes haut u emHI h thus reise ve are issued at the tune of the ordar ce eachent.e en uw Answustretam af the NRC Smepesemas fhemen M E2 and C.sl does not apply tre proposed unposthoe of the crvtl penalty. Rag > anal Ohne ever the sert several years to tas smetastameeus ressess bann 6
8892 rednal Regist:r / W1. 49 No. 47 / Thuredty. March 8,1984 / Rules and Regulations L Feuure to meet the r,quarements of to L Aoualemtry of as enauthertsed & Fe3ere to implement to DR pens 25 and CFR to se ht does not result in a Severtry in&vweal into e vital same er metenal accese 95 and informatism addressed ender Section Level L Il er 111 violeum: area bem outside the pretected area (La, 142 of the Act, and the NRC approved
- 8. Failure tr meet mguletary requireasota penetreuse d boe benuM ht wm not es**t'y plan relevant to sbase parta; that bewe mes than auner asfety or g,gog .: g g , g ,,,ry., ,, & Fellwe to sentrol aeswee to a vital me environment.! sagruficance: or ** *n*3 **"*' *"" I"*" I"* "N
- 4 Fadum to Me a aqM h 8. Failure to promptly report knowledge of as actual or enempted theft er diverrue of protected ame w laum m eenW scceu to Event Report. the protscsed ares la that one of the three E Severtry Lavel V-Viols: ions ht have W w an act of m&oWool sebmage. elemente er noosee eastrelis inadequate-miner safety or environsurntal signiLcance. B. Severity B-Violet 6ene involvmg for t FaDute to properly secure er protect mample: elassined er other sonettive esieguente S'9'P I '"'I NT c - .- -
L Actaal theft, less se diversies telspecial hformouse which would est significantly
" Auf m-#ecihty Construction anclear material (SNM) d moderste st'otepc assist as indiv6dealin as act of re&ological A. ge,artry bViolations levolving a sign Acance:u esbotage er tbdt of spemalanclear matmt etructure er system that to cosipleted
- In L Failure to sentrol aosses see that all er such a meener that it would not have three elements of ecomes sentrol(borner. L Other violatieas, eneb es feuere to foUow seuefted its intented esfery related pwpose. manhorink and responee) et the protected an approved securtry plan, that have more B Severtry B-Vaolauens irrvoinna for ares er vital ares are taedequate er em of thee minar safeguanie signincance, esemple- three elemente are inadequate is both h E 5 event) V-Vieletce t** h** *
- 1. A breakdown in the quahey assurance protecwd and vital ama; enfeguanie eigiuhannon.
program se enemphned by deficiosoes la 8. Fadure to implement approved sopps ery __,e- ~ _ eoostruenon QA mleted to more than one aa=p=aaatory amwee when se oestral work scuvity (e.g structurel piping- and secoMary alare suboas are inopembk: Neold Mysine'N CFR Aert m 88 clectncal foundatmash Euch ,denciecaw & Failure to estabhab er maintain A. Severtry bViolettene levolving for normaUy levelve h heensee e failure to ,,,,pg. sonduct adequate au&ts or to take prompt g , pmm w kwd the unauthorized mmoval of L Saagle exposure ein worker in emeess of correctave accon on the basis of such su6ts as rues of re&eben 2 se whok body.150 and norntau) 6nvolve muluple examples of a formuis quantity of SNM from areas of roms to the akin of the whole body. or 373 deficaent monaniction or aanstruccan of setbartsed use er storage: or runs to the feet. ankles. bands er forurma. unknown quhry dw to inadequate program & Failure to nas esta'ohobed transportation 1 Annual whole body exposure of a implementauset er escurtry eyetsina destened er used to prevent . member af the public in sesses of 18 reme of
& A structure er system thatle completed the theft,loes, or & version of a formula sedution: .
In such a manner (nat it could beve an gearrtity of SNM re acts of re&ological 8. Release of re§ive material to an adverse effect on the safety of operecons. esbotage. C Seventy ID-Violaboos involvmg f ' semanidd aan 2 easses W un tmies k exampk C Severtry ID-Violations hevolving for knits of toCFR20.10k example: & Dupesel of homosed materialin
- 1. A ciency e a beenen qA L Failure :s osotrol accese each that two of guamaties er concentrations in emos of ten ensurance program for mmstruccon related t the thme elements of semu control at h t6eese the haf ts of to CFR 2.301 or a single work ecuvity (e4 etructural piping- E Empers of a wake in rumed arns electncal or foundauonst Such etsruacant with! ans or proteced ama barner am denoency normally invoh,re the hwnsee's hadequate: d un tame es baits d io CFR 2.1n fadure to conduct adequate su6ts or to take & FaDute to sentrol eenses to a trenoport B Seventy B-Violaname lavolvmg for
,,,,,g.
prompt conectve action on the basis of such vehicle or the SNM being transported that 1.5msle exposure of a worker in emens of au6ta. and normaUy mvolves eduple does not annatitute a Severtry I of D violatacc: a ree. d re&ation to the whole body. 30 examples of deficient construccon or 8. Failm to estabbsb or maintain reme to the akaa of the whole body. or 75 construccon of anknown quhty due to ufsguards systema designd w md to rems u h IM ankles, bands or forurms. inadequate peogma tmplementahon. prevent er detect the uneutbonsed removal of & Annual whole body exposure of a
& Faum to conba the desagn safey member of the pubhc in smoons of CJ rems of ENM of modorete e*rategic signincamos from mquirements of a structure er system as a result of inadequate preoperetaonal teet wue MM u er e re& ebon:
& Fauure m impkmat approwd 8. Release of radioactive material to an ,
.a to nIe e re,on.
uired to CFR compensatory measures when the sentral (or escowary) aw emo- k mopersbk; ] . ,,,o,, CFR E108
,o ma,e a, ,mme&,,,
D. Seventy IV-Violations tavolving failure L Teilun a conduct a proper search at the acomes control potat that swults in Mcaba u ad b to CFR to meet regulatory requirements includmg ene er more Quahry Assurance Crttena not introductice to the alte of Arearms. 261) eM 10 CFR 2612
& Disposal of bceased matenal m stoounung to Seventy lavel L D or m violacons that have more than minor safety emplosivoa, tenen&ary devume, er scher items queantaes or concentrations in excess of fn e i which could be used for inducinal esbotage; tunn the baits M10 CFR 304 or w ennronssental signncance. l er L Exposure of a workerla metncted aren j L Severity V-Violaeons that beve minor 8, Failure to property secure or protect !n emoons of five times the haits of to CML eafey or envimnmental engrunesace. elassined or other sensitive safeguards 30.1E l
i n.ypi _ er' w , e- . ; informauce which would sagrufkantly easiet C. Severity ID-Violations involving for i an individual to as oct of re&ological amample: 1 safeyuarde 1. &msk exposum of a worker in eacess el esbotage or theft of special nuclear esatonal A. Severity WViolations involving far D. Severity IV-Violabene inve&ving for 8 was of m&auen a the whole body. 7.5 esample: - mampk. eene le the akta of the whole body, or SL75
- 1. As act of re&olog ca! embetage or actual rene to the feel ankles, bands or forearms; thefL loss, or & version of a formula enanuty LFailee asembhab a maisum
* ***d # L A fediaties lenl in an enreatncted area of atratepc special nuclear materialu **I'888"I8 'F"'8 d**'8" such that es ladividual could receive grester (ssNM), ymvent w dewet the usutbarmed nmoval of than 100 milhree in a one bour pened or 300 SNM of leer otraterc 7"- 88 freen milhren is any seven sensecueve dsyo.
' *Compaeted" means sempiendes of '"
bdwese remw and sampianas to es a pweenal ecer seesswee and annecmed earwmeuse QA ereensasuen " See to CPR foJ!sk genietessa, terwres sorweg a We esnoe offort mil r* See 1e CPR Pt.gMk " Gas to CFR 754k .be easted en a esse +renas beam. 1 _ _ _ _ _ _ _ _ _ _ _ Q
Fedird Regiat:r / Vd. 49. Ns. 47 / hrsday Mhh a.1964 ? Rides and R'egitletion's W3
- 3. Failure to make a 24. hour notacauon as 1. Breach of packap latepity resulting to & Conduct oflicensed activities by e
. required by to CyR 20 403(b) or en immediate surface contaminshon or external re&stxe technically anquahfied person; notificauon required by to CFR 20 402ia); lenla in exceu of NRC requirements. & Radiados levels, contamination levels. or e Substanual potential for an exposure or 1 Surface contamination or exte*nal roleasee that enseed the halts specified in l reluu m excese of to CTR 20 whother or not re&ehoe levels in excess of Eve times NRC the bcones; or .
I such exposure or releau oe:urs (e4. entry hmita that did not rnuh imas e bnsach of e. Medkal thereprotic misadministn uona. mto bish red abon areis. e ch as under pachap integnty ar D. Sewertry IV-Veolabone invoinns for reactor vessels or in the vic.nity of exposed 3. Faslure to make required initial summple: red ographic sources arithout having motificationa eseaciated with Seventy Levell 1.Fallare to unsintain pecents hoopttalized prformed an edequate survey, opereuon of a or D violataons. who have opbalben cessa.137. or iridium. reestion facihty with a nonfunctioning C. Severity ID-Vioistions of NRC 182 implanta or to conduct required leshage interlock systern); transportabon requirements involving for or coetenlaation testa, or to see pmperly 5 Release of re&oectre material to an example' sabbreted equipment unrestncted area in escsaa of the hasta of to 1. Breach of packap integrity: 1 Other nolabone that have more than CFR 2010L & Surface contammabon or external minor safety or osvirnamental sagnMeance:
& 1mproper disposal of bcansed matenal re& ebon levels in excess of. but less than a or not covered in Seventy Levels I or IL factor of Sve above NRC requiremenia. that & Failure to report medical diagnostic
- 7. Exposure of a worker in restncted areas ed not ruult Imm a bruch of packap suandministrettons.
in excne of the bmits of to CTR 20.101 intes ity: E Sevenry V-Violabons that beve minor l 8 Release for unrestneted use of 3. Any teoncomphance withlabalhns. eefety or environmental nrem - contaminated or rs&oactive matenal or placarding. shgpmg paper, packanng. m , . , m equipment which poses a rechsuc potenuai loadans. or other requirements that could -- ~" I fer splicant exposure to members of the reasonably result la the followmg M,acellaneous Mottere j pubbc. or which reflects e programmetac a. Improper idanuncahon of the type * (rather than isolated) weakness to the quanury, or fonn of matertal; A Seven'I WViolations involvW for red stion control program; b. Fadure of the carner or recipient to **** P
& Cumuleuve worker exposun above exercee adequate concola. or t A Matenal False Statemet A i. in regulatory hrruts when such eumulanve which the statement made was dehberstely
- c. Substanual potenna! for personnel esposure reCects a programmacc. rutbar then oposum w conemos or impmper I*I'*
an isolated weaknen m re&auon protecuen; & Falsificauon of records which NRC hnsfer d maanat or mq be W d signakant inkmabon b to Conduct r,f heensee actmties by e ( Failure to make required inlual techrucally unquahfied person. or wbch the records were deliberately falsified it. 5,gnacant fadure to control bcensed mottficauon not uoe, anociated with Seventy kvel UI by or with *be knowledge of manspment maienst D. Seventy IV-Violacons of NRC &A : intuud fadun to D. Seventy TV-Violabons invoinns for Pronde the noter required by Part 21: or transp^rta uen requirements invoinns for & Action by senaor corporate rnanagement example:
- 1. F.sposures in excess of the hauta of to examd'.t t eksp selectice or preparehon I" "* N * '8 CTR 20101 not consuruttag Seventy Level L requirements which do not result in a bruch an employn.
IL or UI violauona. d packap integ ity or s'aface co namination E 0***Y U~Yi'I h*U"' I"** **8 f"' 1 A re6ation levelin an unrestneed ans or external red;suon levels in axceu of NRC ***
- P I*'
such that en mdmdual could receive gruter 1. A MTS or a reportmg failure, involving requuements; w than 2 milbrem in a one bout penod or 100 informanon wbch. had it been available to L Other violanons that have more than mdhrem tn any seven consecutive days; minor safety at enytmnmental signdcance. the NRC and accurete at the time the ) 3 Failure to make a 30 day notScation E Seventy V-Wolauens that have manor informauan should have been submitte . required by 10 CDt 20 605, would have rwulted in regulatory action or safety or environmental atsnacance. 4 Failun to make a followuo wntten report u ould hkely have resulted in NRC seekir:3 ) as required by to CT1L 20 4c2(bl. 20.40& and SuPPl emnist VW6evarity Categories further irtformanon; I 20** * ' ^ * * "N'h h I*I" * * * *"' " " Fuel Cycle and Materwis Opemtions made enth canlus 63 regard 5 Any other matter that has more than 1 minor ufety or ermronmental s:gnacance. A. Seventy b%ol8tio38 involvin8 for S. Deliberste falsscauon of records which ; E Seventy V-%olauens that have etnot example: NRC reqmros be kept myolnns sof; cant
- 1. Ra diation levela, conteminston levela, or idormauen. )(
ufety or envirorunental spficance. releases that exceed ten ames the hmts 4. Acthen by plant management above first. l Satppiament V-Sevenry Caterch specied in tbs bcense; line superv.sion m nolation of section 210 of Tmnsportationu L A system designed to pntvent or mitigste the ERA asemst an employee. or a eenous asfety event not bett:4 operable E A fatlure to prende the notice required A. Seventy W%olauons of NRC when actually requ: red to perform its desigrt by Part 21. transportation requaternents involyms for funcuan; or nampk c %9 pygm w% (w
- 3. A nuclear cnucahty accident.
- 1. Annual whole body rs6auon exposure B. Seventy 0-%olauona tavoinns for YAh;.uot amountag to a Seventy level of a member of the pubhc sn esceu of 0.5 ,x,, p i,:
nms of rs&suon, or I D Mm I t Rad atten levela. contamination levela. or
- 2. Breoch of packste integnty resulting in releases that exceed 8ve times the hmits .
surface corWamananon or enternal radiation "I*'""" "*
- I a fled in the bcense: or * '"
nevels in excess of ten times the NRC hauta. system designed to prevent or rtuttgete
,",, p an tw
& Seventy U-hoist ons of NRC a unous ufety nent bems inoperable, ,oo, . m n % . wemining me siwnLc transportauor; requirements involyms for C. Seventy ID-Viciatons tavolvmg for sevenry levei et a vie &enen mvolvmg memnal fase esample: es. ample; statemasta er faiaassue of reords sensdemun
- 1. Failure to control access to bcessed wdl tw span is sus lectri n as posii.a of un
%ee transperistian requireewete en epoW matenals for re& anon purposes as speeded Pwoon anewd as es maties too Ami kne se e,e then one Lcensee savos ed te aw aann by NRC requirements *- "'"""'****8"k*8" '**
actm'y sucA se a shippe tio CR r1Jol and a
"'""lemause the a avessed, and Ge tsune of a"s g pg.,,"'" " ****["^**ggggg,g came tic cnt rcJoeI when e veauce of ed a wetaier 0.e. sogleme sea samatme to camina r,qwnmen eccure entenemeni act>ae my to equipment w matenals in the conduct of 4,,,o, ,4 ,,,,3e., g,.,voent, e eehtenieeessi girmaed asamst uw respewt>w beanese weicA heenau activities which degrades safety. na ,,tanve weight g ven to each d sees feeters m
.nec the c2rwnesaces of me casa. may tw one er 3. Use of ru6oacuve matenal on bam" amvus et h appropeute seventy brvvi mL to me of ine bceneae evoked. where such useja not authorned; depenaent en me circumeiseese of m no sues av
I
=
SSN Federal Resistcr / Vol. 49. No. 49 / Thursday. March a.1984 / Rules and Re'gulatio'ns ,a . 1 Delibemie faleincetion, er felesheetsosi by or witti the knowledge of management of pe,ed et Weekington. D.C., abis and dey of I tienh.1see. eteerde which the NRC requires be kept that dad not anvelve eagninnoni talennehen. For the Nucleet Regulatory Commission. E Actson by firei.hne superviesen as wyg . i veoletion of secben 210 el the ERA spennet er MM8N N"* e mployee; w P8 O'8 8688'8 Ed88 Md8 88 8"!
- 4. Inadequate review or failure le review enase case reasse**
. sesch that. 6f an apprennete review bed been ___._..
anade as required, o Part 31 report would beve been made. D. Seventy IV-%eleuene involves for enemple:
- 3. Anedequate review or failure to seview J under Part 21 er other procedural vio4euens 1 sesociated with Part 21 with more then sunor safety eagasficance:
- 2. A false etstement osased by en imedvertent clencal or easilar errer evolving informauen which, hed it been available to '
NRC and occurate et the tune the information should have been submitted. would probebly not heve resulted in regulatory schon or NRC seeking eddahonal anformetaon, or E 5eventy V-Woletaone of minor . precedural requirements of Part 21. Supplesment VIII-Ges erity Categenes E.mersencyAwpanchres l ' A. Seversty 6-%oistaone involving for enemple. In a general emergency. licensee failure to promptly:(1) correctly cleosify the event (2) mehe required nouficeuono to responsible Federal. State, and local agencies, or (3) respond to the event le g., seeems actual or posepuel offeite consequences. acuvete oms -ey response facihtaes. and augment stuft 4
- 3. 5eventy D-Wetebons levolving for example-
- 3. In a site eres sese gency.lscensee failure to promptly:(1) correctly c!asady the evenL (2) make required nouficeuona to responsible Federol. Sie fe. and local agencase or (3) respond to the event (e.g essees actual or potencel offeate consequences. ectivate emergency response facthbee, and supraeot shift etsff). or L Ucensee failure to meet or implement mirre then one ernerveriey planning standard sevolvmg essessment or nottaceuon.
C. Eeventy !!i-Wolebone asvolving for searople;
- 1. In en eiert. boensee failure to preamtjy:
(1) correctly cjessify the event (2) make required netsficeo sne to responsible Federal. State. and local agencaes. er tal respond to the event te 3.. eseess act6el or potenuel effsite consequences. actwote m,a.q scoponse factlatsee, sad segment shaft staff). er i Ucensee fatture to meet er isnplement see emergency planning eiendard navolvies a-aa% er motlaceton. J
. D. Seventy IV-Woletaene devolving lar P enemple Lacensee failure to meet er implement say emergency planning standard er requirement not directly related to eseesoment and notificeuon.
L Seventy V-%clettone that have minor eefety or ennronmental egnJacance.
~ - [j,'j .,.j[ i/[i ) e! ts ~~I*tOFFICE 5 3 UNITED STATES NUCLEAR REGULATORY COMMISSION OF INSPECTION AND ENFORCEMENT i w. ,/ Washington, D.C. 20566 INSPECTION AND ENFORCEMENT MANUAL ES CHAPTFR 0400 ENFORCEMENT PROGRAM TABLE OF CONTENTS Page 0400-01 PURPOSE 1 0400-02 OBJECTIVE 1
~
0400-03 DEFINITIONS 1
.pl Deviation 1
.02 Escalated Enforcement Action 1 ,
.03 Individual 1
.04 Person 1
[ .05 Requirement 1 ( .06 Similar
.07 System 1
1
.08 Violation 1
.09 Wi11 fulness 2 0400-04 RESPONSIBILITIES AND AUTHORITIES 2
.01 Office of Inspection and Enforcement 2
.02 Regional Offices 3
.03 Other Offices 5
.04 Commission Consultation 6 0400-05 THE ENFORCEMENT PROCESS 6
.01 Identification of Violations or Deviations 6 l
.02 Documentation of Violation 7
.03 Safety Significance and Severity Level 8
.04 Enforcement Conferences 10
.05 Determining the Appropriate Enforcement Action 11
.06 Assessing Civil Penalty 11
.07 Orders 14
.08 Preparing the Package 15
.09 Coordination and Review 17 U
1205..g. 5 50e 36 35 1 1Mtr v fC of IGN PROGRAMS
- a s- 3e c obl% TJN DC 20555 -
1 Issue Date: 04/24/85
O a e Page , 0400-06 THE SUPPLEMENTS 18
.01 Supplement I
.02 Supplement II
.03 Supplement III
.04 Supplement IV
.05 Suppl.ement V
.06 Supplement VI
.07 Supplement VII
.08 Supplement VIII 0400-07 FORMS 18 O
Issue Date: 04/24/85 ii
ENFORCEMENT PROGRAM 040.0-01 0400-01 PURPOSE This chapter. explains how the regional offices and the Office.of Inspection and Enforcement (IE) are to implement the General Statement of Policy and
. Procedure for NRC Enforcement Actions (Enforcement Policy or Policy),
codified in 10 CFR Part 2, Appendix C, to achieve uniformity and consist-ency of enforcement. 0400-02 OBJECTIVE The Enforcement Policy defines how appropriate sanctions are to be applied, in accordance with uniform procedures, to achieve maximum compliance with Commission requirements. 0400-03 DEFINITIONS k 03.01 Deviation A licensee's failure to satisfy a written com-mitment or to conform to the provisions of applicable codes, standards, guides, or accepted industry practices when the commitment, code, standard, guide, or practice involved has not been made a legally binding requirement by the Commission, but is expected to be implemented. 03.02 Escalated Enforcement Action A ssnction applied in the form of a civil penalty or an order or a Severity Level I, II, or III citation. 03,03 Individual See " person." 03.04 Person (a) Any individual, corporation, partnership, firm, association, trust, estate, public or private institution,
. group, Government agency other than the Commission, any state or any political subdivision of, or any political entity within a state, any foreign government or nation or any political subdivision of any such government or nation or other entity; and (b) any legal successor, represent-ative, agent, or agency of the foregoing.
03,05 Requirement A legally binding obligation such as a statute, regulation, license condition, technical specification, or order. 03.06 Similar With respect to violations, those which reasonably could have been prevented by a licensee's implementation of corrective action for a previous violation occurring within the past two years. 03.07 System The physical components that comprise a functional unit of an operation, or the administrative and managerial measures used to control the operation. 03.08 Violation The failure of a licensee to comply with a requirement, 1 Issue Date: 04/24/85
0400-03.09 ENFORCEMENT PROGRAM l 03.09 Willfulness An attitude toward compliance with regulations that ranges from the careless disregard for requirements to r ! the deliberate intent to violate or to falsify. Does not include acts which do not rise to the. level of careless dis-
. regard, e.g., inadvertent clerical errors.
l' 0400-04 RESPONSIBILITIES AND AUTHORITIES
)
The regional offices and the Office of Inspection and Enforcement have sep- 1
'arate authorities and responsibilities under.the Policy. )
04.01 Office of Inspection and Enforcement Responsible for the , establishment and implementation of the NRC's enforcement- i program. Authorizes the regions to issue Notices of ! Violation for Severity Level IV or V violations without IE concurrence and Notices of Violation and/or proposed civil penalties for Severity Level I, II, or III violations with IE concurrence. Issues orders to show cause or to suspend, modify or, revoke a license in accordance with procedures specified in 10 CFR Part 2, Subpart B,. Sections 2.202 and 2.204, and orders imposing civil penalties. On occasion, initiates enforcement actions, conducts enforcement conferences, and issues. proposed civil penalties.
- a. Enforcement Staff (IE/ES)
- 1. Reviews proposed enforcement actions submitted by the regions to ensure technical adequacy and con- ( '.
formance to established policy, guidance and precedents. The review should include: -
- a. Review of the facts contained in the inspec-tion report to ensure that they support the f l
findings and proposed action of the regional ' office and that there has been a violation of a regulatory requirement.
- b. Review to ensure that the regional recommen-I dation is appropriate and in accordance with ,
the policy, guidance, and precedents, consis- ! tent with actions taken by other regions, and ! that the sanction level chosen is commensu-rate with the significance of the violation.
- 2. Recommends to the Director, IE, whether to authorize the Regional Administrator to issue the i proposed action.
1 hsee Date: 04/24/85 2 ;
. _ _ _ _ _ ________ _ __b
1 e l I 1 ENFORCEMENT PROGRAM 0400-04.01a.3 I l
- j
- 3. Reviews investigation findings and the results of !
IE-directed and team inspections (such as Perform- , ance Appraisal Team, Construction Appraisal Team, l Fire Protection Team and vendor inspections), ! coordinates with the regions to determine the appropriate enforcement action, and initiates enforcement action if appropriate. {
- 4. Ensures that representatives of the Office of the Executive Legal Director (ELD), Division of Regional Operations and Enforcement, and, when the Director, ES, determines it is appropriate, Nuclear Reactor Regulation (NRR), Nuclear Material Safety and Safeguards (NMSS), and other NRC technical staff have an opportunity to comment on the enforcement findings and proposed recom-
' mended action; coordinates comments with the Region; and obtains appropriate concurrences..
- 5. Prepares an Enforcement Notification (EN) for every proposed civil penalty.and order.
- 6. Reviews Regional Administrator's proposed response to licensee's responses. to proposed civil penalties and Orders and p'rovides recommendations to the Director, IE, regarding imposition or mitigation of sanctions.
- b. Director, IE/ES
- 1. Reviews proposed and final escalated enforcement actions and submits the enforcement packages to the Director, IE, with recommendations for appro-priate action.
- 2. Signs letters to licensees acknowledging receipt of payment for civil penalties.
- c. Director, IE Establishes the enforcement policy ,
and provides guidance to the regions on implementation i of the policy. Authorizes issuance by Regional l Administrators of Notices of Violation, and proposed " civil penalties, signs certain proposed civil penalties, signs Orders imposing civil penalties and ; other Orders, and initiates significant enforcement l actions. l l 04.02 Regional Offices The regional offices initiate routine enforcement actions, schedule and conduct enforcement conferences, prepare and issue Notices of Violation (NOVs), l prepare proposed civil penalties and issue them when l authorized to do so and af ter concurrence by the Director, l IE. Evaluate licensees' responses to enforcement actions, I prepare appropriate responses, and track the status of enforcement actions. 3 Issue Date: 04/24/85 a
.. .. . i i
0400-04.02a ENFORCEMENT PROGRAM
- a. Regional Inspectors
- 1. Identify violations of regulatory requirements and recommend enforcement action. Prepare appropriate documentation of findings and !
enforcement action (sectior. 05.08). Recommend to appropriate regional management the severity l level, and provide reasons for mitigation or escalation of a civil penalty, if any. I
- 2. Review responses to Notices of Violation submitted by licensees to determine whether corrective actions are adequate and prepare evaluations of
. licensees' responses to proposed civil penalties and Orders, as appropriate, for submittal to regional management.
- b. Regional Supervisors and Managers
- 1. Review inspection and investigation findings and recommendations of regional inspectors to deter-mine whether enforcement action should be taken.
- 2. Recommend escalated enforcement action to the
. Regional Administrator. The recommendation should include evaluation of the severity level of the e violation, whether a civil penalty should be proposed, and whether mitigation or escalation of the civil penalty is appropriate.
- 3. Evaluate licensees' responses to proposed civil penalties and documentation prepared by regional inspectors and recommend to the Regional Admin-istrator whether a civil penalty should be imposed.
- 4. Approve and sign nonescalated enforcement actions.
- 5. Conduct enforcement conferences when authorized to do so by the Regional Administrator.
- 6. Evaluate licensees' responses to proposed enforce-ment actions and provide recommendations to Regional Administrator regarding imposition or mitigation of sanctions,
- c. Regional Enforcement Coordinators
- 1. Prepare, or review and comment on proposed and final escalated enforcement actions prepared by the regional staff to ensure that they are accompanied by adequate documentation (section 05.08), are in the correct format, and are consistent with the enforcement policy, other guidance, and precedents.
Issue Date: 04/24/85 4
ENFORCEMENT PROGRAM 0400-04.02c.2
- 2. Prepare, or review and comment on Commission papers for escalated. enforcement actions requiring '
Commission consultation (see section 04.04) with the assistance of regional staff.
- 3. Prepare a transmittal memorandum to accompany each proposed and final escalated enforcement action sent to IE for concurrence which contains the rationale for selection of the severity level, civil penalty amount, and proposed mitigation or.
escalation. of a civil penalty, or reasons why no mitigation or escalation is appropriate.
. 4. Track the progress of all escalated enforcement actions to enhance the timeliness of the actions.
- 5. Maintain records and statistics on escalated enforcement actions taken by the Regions.
- 6. Monitor, and assist in if needed, the processing of nonescalated enforcement actions to assure that they are consistent with the enforcement policy, other guidance and precedents,
- d. Regional Administrators -
- 1. Determine whether to initiate proposed escalated enforcement actions and submit recommended actions, accompanied by necessary documentation, to IE for concurrence.
- 2. Recommend to the Director, IE, after consideration of licensees' responses, whether proposed civil penalties should be imposed.
- 3. Conduct enforcement conferences or delegate authority to conduct such conferences to other regional managers.
- 4. Sign proposed escalated enforcement actions when authorized to do so by the Director, IE.
04.03 Other Offices
- a. Office of the Executive Legal Director
- 1. Reviews and provides legal advice on escalated ,
enforcement actions and other enforcement actions ' upon request.
- 2. Represents staff in NRC adjudicatory hearings on enforcement actions.
l 5 Issue Date: 04/24/85
0400-04.03b ENFORCEMENT PROGRAM
.i b, Offices of Nuclear Material Safety end Safeguards and Nuclear Reactor Regulation Review proposed enforce-ment actions if requested to do so by . IE/ES. Issue, as appropriate, orders to show cause or to suspend, modify, or revoke a license in accordance with procedures specified in 10 CFR Part 2, Subpart 8, Sections 2.202 and 2.204.
04.04 Commission Consultation In certain cases, consultation with the Commission is required before enforcement ' action , is taken. In these cases, a Commission paper must be ; prepared (section 05.08). The threshold for Commission consultation is specified in section VII of the Enforcement Policy. 0400-05 THE ENFORCEMENT PROCESS 05.01 Identification of Violations or Deviations. The regional offices initiate appropriate enforcement actions after ~ j identifying violations or deviations. An item of ; noncompliance may be considered a violation or may be treated as an unresolved item. *
- a. Deviations
- 1. Before an applicant obtains a construction permit- '
(CP) or a limited work authorization (LWA), the i usual regulatory requirements (license conditions and technical specifications) do not exist and so cannot be used as the basis for a citation for a violation. Instead, an applicant's failure to adhere to a commitment in a Safety Analysis Report for safety-related work is considered to be a deviation. If an applicant receives an LWA for land clearing or other preparatory construction ) activities before receipt of a CP, failure to meet j the requirements of the LWA constitutes a viola- ! tion rather than a deviation. l
- 2. For individuals other than applicants (e.g.,
architect engineers, vendors, and contractors), a deviation is the standard citation for identifying activities or practices which do not conform to applicable QA programs or to topical reports sub-mitted to, and accepted by, the Commission. How- , ever, where a specific regulatory requirement I applicable to non-licensees exists (e.g., 10 CFR Part 21) a citation for a violation may be issued. {
)
- sue Cate: 04/24/85 6
ENFORCEMENT PROGRAM 0400-05.01b
- b. Violations If a licensee fails to comply with a requirement such .as a rule, Order, license condition, or technical specification, a Notice of Violation should be issued unless the violation is a
. Severity Level IV or V, was identified by the licensee, was reported, if required, was corrected by the licensee, and could not have reasonably been expected to have been prevented by corrective action for a previous violation. (Section 05.05).
- c. Unresolved Items If sufficient information does not exist to deter-mine. if a violation of a requirement occurred, the item may be identified as an unresolved item in an l inspection report.
05.02 Documentation of Violation
- a. Once a violation has been identified, the facts sur-rounding the violation must be assembled. The information documented should address the following points, if applicable:
- 1. What requirement was violated?
- 2. How was the requirement violated?
- 3. When was it violated and for how long?
- 4. By whom was it violated? *
- 5. Who discovered the violation?
- 6. How was it reported and by whom?
- 7. Are there previous violations of a similar nature?
- 8. Are there multiple examples of a particular violation?
- 9. What was the cause of the violation?
- 10. Was there careless disregard of NRC requirements or indications that a requirement was willfully j or knowingly violated? i
- 11. Was management aware or should it have been aware of the violation?
- 12. Is there evidence that management was involved directly or indirectly in the violation and to i what extent?
- 13. Are there circumstances surrounding the violation which increase or decrease its significance?
- 14. How many opportunities did the licensee have to discover that it was in violation?
i 7 Issue Date: 04/24/85
N - t . 0400-05.02b ENFORCEMENT PROGRAM
- b. Documentt. tion should include. specific .information regarding times, dates, titles of persons, and' types '
of equipment- involved in the violation. This documentation could but need not be presented in-an inspection report. (Detailed guidance on prepara-tion of inspection reports is contained in IE MC 0610.) The Severity Level of a violatio'n should not be described in the inspection raport but should be dealt with in the enforcement package. l 05.03 Safety Significance and Severity Level '
- a. Once the circumstances surroundinga violation are-understood and documented, the significance, and the commensurate severity level, must be determined. ..
- b. In determining the significance of a violation, the following factors should be considered: j
- 1. Did the violation actually or potentially increase the risk to the public health and safety? - A vio-lation that involves no actual threat but which had the potential to increase the risk to the public health and safety may be very significant, depending upon the degree of potential threat, its likelihood, and the possible . consequences /" -
involved.
- 2. What was the root cause of the violation? Was it caused by training deficiencies? Inadequate pro-cedures? Such violations may have significance greater than the actual safety effect of the particular system involved in a violation.
- 3. Is the violation an isolated incident or is it indicative of a programmatic breakdown? Pro-grammatic breakdowns should be evaluated at higher severity levels than if they are isolated incidents.
- 4. Was management aware of or involved in the viola-tion and to what extent? Violations in which management was directly involved are more signi fican't than those of which management was unaware. Violations involving upper level management should be considered more significant than those involving first-line supervisors.
Inattentiveness on the part of management should also be considered. 5.( Did the violation involve willfulness and, if so, to what extent? The Office of Investigations (01) and IE/ES should be consulted whenever the violation appears to be deliberate or wrongdoing is involved. Issue Date: 04/24/85 8 i
l l 1.i.. ENFORCEMENT PROGRAM
. 0400-05.03c
- c. The Supplements contained in the Policy provide guid- j ance for the determination of severity levels. If a violation fits an example contained in a Supplement, it should be evaluated at that severity level. If a j region believes a different severity level should be '
l assigned, and the violation fits an example of a l Severity Level III or higher, consultation with IE is i ' required, unless the type of violation is specifically { covered by this Chapter. If a violation does not fit ' an example, it should be assigned a severity level commensurate with its significance, i
- d. A group of violations may be evaluated in the aggregate and assigned a single severity level if all arise from the same underlying cause or programmatic deficiencies.
Similarly, the cumulative civil penalty for all viola- l tions that contributed to or were unavoidable conse- ' quences of that problem would be based on the amount shown in Table 1A of the Enforcement Policy.
- e. If the public health and safety is likely to be endangered by the continuation of the conditions created by the violation, the region should obtain immediate action to correct the condition from the licensee and should consider obtaining an immediately effective Order.
- f. It is irrelevant for purposes of determining the Severity Level of a violation whether the licensee finds and reports a problem.
- g. Reporting Violations
- 1. Reporting violations may result from a licensee's not filing a required report, filing an incomplete or incorrect report, or filing a late report.
- 2. An NOV may be issued for a reporting violation if a licensee was aware of information which it was required to report and did not report it.
- 3. An NOV will not usually be issued for a reporting violation if a licensee did not have the informa-tion' that it was required to report, even if it should have had the information it was required to report. However, if the licensee's failure to j
have the information was itself a violation of an NRC requirement then that requirement should be used as the basis for an NOV. For example, if a licensee was required to conduct audits that would have produced the information and the licensee failed to conduct those audits, issuance of an NOV for the latter failure would be appropriate. l 9 Issue Date: 04/24/85
i 0400-05 03g.4 ENFORCEMENT PROGRAM
- 4. When a reportable event is itself. a violation, a licensee should be cited for both the event and the failure to report the event.
- h. Record-keeping Violations a
- 1. When a licensee is required to perform a given task and to keep a record of having done so, but cannot produce that record, an NOV should be i issued for failure to keep the record. I
- 2. Failure to keep a required record may be con-sidered supporting evidence that .a licensee did not perform a required task. However, without additional evidence that the task was not per-formed, the absence of the record is insufficient to support an NOV for failure to perform the task.
05.04 Enforcement Conferences . The purposes of an enforcement conference are stated- t in sestion IV of the enforcement policy.
- a. An enforcement conference must be held, if one is planned, before issuance of a Notice of Violation and should be held within four weeks after completion. of (~ ,
the inspection or issuance of an investigation report. The licensee must be told that the meeting is an (f ( enforcement conference.
- b. An enforcement conference should be held in each of the following cases:
- 1. Those involving . Severity Levels I, II, and III violations.
- 2. Selected Severity Level IV violations which, if repeated, could lead to escalated enforcement action.
- c. If a decision is made to hold an enforcement con- ,
ference, the level of regional management conducting the conference is determined by the Regional Administrator.
- d. Upon notification of the licensee of an enforcement conference the region will promptly notify IE/ES.
- e. Following an enforcement conference, a report describ-ing the meeting should be prepared which states the licensee's position on the violation, includes any mitigating circumstances and addresses, as appropriate, the information listed in MC 0400-05.02.
- 3ue Date: 04/24/85 10
ENFORCEMENT PROGRAM 0400-05.05 05.05 Determining the Appropriate Enforcement Action
- a. The region or, on occasion, IE, decides initially whether enforcement action is appropriate and, if so, what type of action should be taken.
- b. If a region determines that escalated enforcement action is appropriate, a transmittal letter and an NOV should be prepared (Section 05.08). The enforcement action shculd be sent* to IE for concurrence within six weeks of r.he last date of inspection or date of the investigation report.
- c. IE should concur in the proposed action within two weeks of teceipt.
- d. NRC Form 591 is used for inspections of materials licensees, Inspection Priority II through VII. When properly acknowledged by licensee management, indicat-ing that corrective action will be taken for a 'y violations noted, this form serves as the officiai notification of enforcement action. Its use is limited to inspections which result in Severity Level IV or V '
violations. Some Severity Level IV or V violations are preprinted on the form, and others may be written in by the inspector. -
- e. In certain instances, the NRC may impose enforcement sanctions on employees of licensees or on non-licensees who are subject to NRC requirements (such as 10 CFR Part 21,10 CFR Part 50, Appendix B, or 10 CFR 73.21),
when a violation of a requirement directly imposed on them is committed. Such sanctions are handled on a case-by-case basic with consultation among the involved regional office, IE, and ELD.
- f. Once a licensee's response to a proposed civil penalty is prepared, the regional office should prepare a draft response evaluating the licensee's response and Order Impesing Civil Penalty if appropriate. The draft action should be sent to IE within four weeks of receipt of the licensee's response.
05.06 Assessing A Civil Penalty
- a. A civil penalty should be considered for violations of Severity Level III or higher and may be considered for Severity Level IV violations for which a licensee was cited previously. Even if the region does not intend to recommend a civil penalty action for a Severity Level III violation, concurrence of IE/ES is required.
i { 11 Issue Gate: 04/24/85 1
e
- 0400-05.06b ENFORCEMENT PROGRAM
)
- b. In assessing a civil penalty for a violation, Table 1A of the Policy should be tsed to determine the appro- '
priate base monetary amount. Depending upon the circumstances of a case, Table 1A may be applied in a number of ways: . 1
- 1. Each Severity Level I, II, or III violation of an l NRC requirement may be assessed a separate civil penalty.
s 2. Several violations stemming from the same cause or 1 problem area may be assessed a single civil penalty. These violations will be evaluated in the aggregate and assigned one severity level. (See Section 05.03(d)).
- 3. If more than one cause or problem area is identi-fied, separate civil penalties should be assessed for each.
(a) The determination of whether there is more than one cause or problem area can be made by evaluating whether corrective action for one ' violation would prevent recurrence of the other violation. (b) If corrective action is required in more than (' one area, separate civil penalties should be assessed.
- 4. Separate penalties should be assessed for separate violations stemming from one problem area if the violations were separated over time.
- c. Adjustment Factors Using the five adjustment factors outlined in the Policy, the base civil penalty may be increased (factors 2-5) or decreased (factors 1-3) as described below:
- 1. Licensee Identification and Reporting This factor may be used to decrease a civil penalty for a violation if:
(a) a licensee identifies its occurrence or existence before an NRC employee or other non-licensee employee identifies it to NRC; (b) it has not existed for so long that the licensee should have discovered it earlier; and (c) the licensee reports the violation to the NRC within the time limits established by regu-lation. Issse Date: 04/24/85 12
c . 4 ENFORCEMENT PROGRAM 0400-05.06c.2 i 2. Corrective Action Corrective action that is considered average but acceptable will result in no adjustment to the amount of the civil penalty. However, corrective action that is considered below or above average may: (a) Decrease the amount of a civil penalty if a licensee's action is unusually prompt and extensive. " Unusually prompt" generally means immediately initiating corrective action and/or appropriate compensatory measures upon discovery of a violation. Corrective action should be considered I unusually extensive only if it incorporates programmatic changes and identifies and remedies problems related to, but not necessarily identical to, the cited violation. Note: For some violations, the expected average corrective action may, by the nature of the violation, have to be prompt. For these instances no miti-gation would be considered if it is only prompt, but would be considered if it is extensive. (b) Increase the amount of a civil penalty if the licensee's corrective action is not prompt or provides for incomplete corrective action.
- 3. Past Performance This factor may be used to increase or decrease the amount of a civil penalty. Consideration of past performance should include SALP ratings and similar violations over the past two years.
- 4. Prior Notice of Similar Events This factor may be used to increase the amount of a civil penalty when information about a potential weakness in a system has been made available to a licensee who has not utilized it effectively or not utilized it at all. " Prior notice" includes weaknesses identified in licensee audits; industry notifi-cations; vendor reports of equipment defects or failures; NRC Circulars, Bulletins, or other formal notifications; or any authoritative document or report that should cause a licensee to evaluate possible weaknesses in its program.
i 13 Issue Date. 04/24/85 { 4
0400-05.06c.5 ENFORCEMENT PROGRAM
- 5. Multiple Occurrences This factor may be used to increase civil penalty amounts in cases involving '
more than ane instance of the same violation. The only case involving multiple occurrences in which this factor may not be applied is when the licensee identifies and reports all the instances of the violation.
- 6. Continuing Violations Although not included among the five adjustment factors, the policy allows civil penalties to be computed on a per day basis for continuing violations. The per day civil penalty may not exceed $100,000, but need not be this large. A civil penalty may also be increased by some percentage (not to exceed the statutory maximum of $100 day) if it continues over,000 perperiod a long violation of time per but is not sufficiently significant to justify a daily civil penalty.
(a) If a licensee took compensatory measures for a violation but corrective action was necessarily delayed (e.g. , because equipment had to be procured), the civil penalty would not be computed for each day. If the licensee aid not know the violation existed, but would have known if proper tests were conducted or surveillance procedures were ~b '! followed, a civil penalty could be computed on a per day basis. (b) Use of escalation for duration should be considered if the licensee discovered the violation and failed to correct it or if the violation existed for a long time and the not. did licensee should have discovered it but
- 7. Use of Discretion The Policy stresses the i use of discretion in enforcement actions. Clearly the intent of the Policy is to allow the staff latitude to tailor each sanction to the unique !
situation of each car,e, rather than to prescribe an inflexible procets for determining a civil penalty amount. However, staff should be aware of precedents is applied and attempt to ensure that the policy l uniformly throughout the country. , 1 05.07 Orders The NRC has authority to issue Orders to cease and desist, and Orders to suspend, modify, or revoke licenses. Issue Date: 04/24/85 14
)
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .)
. s ENFORCEMENT PROGRAM 0400-05.07a
- a. Show Cause Orders Such Orders ordinarily are accom-panied by other actions, including a written Notice of Violation to the licensee, providing an opportunity to respond to the citation and to describe corrective mea'.,ures being taken. The Order to Show Cause requires the licensee to convince the Commission that the particular- Order (either of revocation, modification, or suspension ~of its license) should not be made effective.
- b. Immediately Effective Orders In instances involving risk to the health or safety of employees or of the public, or involving willful violation of> the Commission's regulations, the notice provision may be-dispensed with and the Order may be made immediately effective.
- c. Orders Imposing Civil Penalties If the licensee does not pay civil penalties proposed with an NOV, an Order Imposing Civil Penalties should be issued unless a basis exists for withdrawal of the proposed penalties,
- d. Confirmatory Orders Confirmatory Orders may be issued to ensure that a licensee fulfills its commitments to take corrective action. If a problem requires immediate corrective action of a short-term nature, and
' a licensee has agreed to take such action, a Confirma-tion of Action Letter may be used in lieu of an Order.
On the other hand, if extensive corrective action requiring long-term commitments (for example, requiring longer than 30 days to complete) is necessary, an Order must.be used. 05.08 Preparing the Package - Necessary Documentation (See also, section 07.00 for examples of necessary documentation).
- a. Proposed Enforcement Actions and Nonescalated Enforcement Actions
- 1. Transmittal Letter- When an appropriate enforce-ment action is selected, the licensee is notified !
of the decision by means of a transmittal letter. A letter transmitting the Notice of Violation informs the licensee that an inspection was con-ducted, when, and ' by whom; details the area'i in which the violation was found; describet, any sanctions being proposed; presents the reason for the sanctions; describes the response that is necessary from the licensee; notes that the action is not subject to the Paperwork Reduction Act of 1980; and states that the letter and the licensee's response will be placed in the Public Document Room. 15 Issue Date: 04/24/85
0400-05.08a.2 ENFORCEMENT PROGRAM
- 2. Notice of Violation Notices of Violation are addressed in Section IV (a) of the Policy. /-
/ Notices of Violation should be signed and dated by the signer of the transmittal letter. They
) should contain a very brief description of circumstances of the event '(no more than one ! paragraph), the legal citation for the violation consisting of the requirement or requirements that
-were violated, the date of the violation, and the way in which the requirement was violated (the facts necessary 'to show that one or more elements of the requirement were not met), the severity level, and the proposed civil penalty amount, if appropriate.
~
The NOV also informs' the' licensee of the response required to be made to the NRC and, if applicable, of its option to . request mitigation for any or all of. any penalties being proposed.
- 3. Notices of Deviation. Notices of Deviation are written in the same format as Notices of Violation and are contained in a separate enclosure to a transmittal letter. The letter asks the individ-ual to respond, describing any corrective action taken to prevent recurrence, and stating the date when the corrective action will be complete. Each deviation should reference and should quote or )
paraphrase the commitment, guide, code, standard, or generally accepted practice which is pertinent, and should describe the manner in which the indi- ! vidual failed to meet it. Deviations against generally accepted practices for which there are no precedents should be concurred in by IE before corresponding with the individual. Notices of Deviatior$ should be signed and dated by the signer of the transmittal letter.
- 4. Commission paper For actions requiring Commission consultation (section 04.04), a Commission paper must be prepared that describes the violations, the proposed enforcement sanction, and the reasons why the severity level and sanction were chosen.
- b. Imposition of Civil Penalties
- 1. Letters Transmitting Orders Imposing Civil Penalties These letters reference previous correspondence between the licensee and the NRC relative to the action in question, take account of any licensee rebuttal or reasons for mitigation or remission, impose the civil penalty, note that the action is not subject to the Paperwork Reduction Act of 1980, and state that the letter and its enclosures will te placed in the Public Document Room.
Issue Date: 04/24/85 16 1
ENFORCEMENT PROGRAM 0400-05.08b.2
- 2. Evaluation of Licensee's Response to Proposed Action An Order Imposing Civil Penalty should be accompanied by an evaluation of the licensee's response as an Appendix to the Order. The evaluation should include a restatement of each violation, a summary of the licensee's response an NRC evaluation of the licensee's response, a,nd a conclusion.
- 3. Orders An- Order usually consists of five sections.
Tne first section identifies the licensee, the license, the type of facility and location, and the date of issuance of the license. The second section briefly describes the violation (s), when the Notice of
- Violation and proposed imposition of civil penalty was issued, and when responses were received from the licensee. The third section is the statement of the
~
Director's decision to impose the civil penalty. The fourth section is the statement that orders payment-of the civil penalty and the fifth section identifies the licensee's opportunity to request a hearing.
- c. Acknowledgement Letters
- 1. Nonescalated actions The regional office should review the licensee's response to any Notice of Violation for adequacy, acknowledge receipt of
[ the response, and request additional information Q from the licensee, if necessary. A 1?censee's response should be acknowledged within 15 days after receipt. *
- 2. Escalated actions IE/ES should prepare a draft acknowledgement letter which acknowledges receipt of payment of the civil penalty and indicates that the region will examine the corrective actions during subsequent insp2ctions. If the region determines that the corrective actions are inadequate, they will consider additional action.
05.09 Coordination and Review After forwarding an enforcement action to IE for concurrence, the regional enforcement staff should assist IE/ES in reviewing and, if necessary, in revising the enforcement package and in obtaining concurrences.
- a. Concurrences IE concurrence is required for all escalated enforcement actions and for all Severity Level III violations for which escalated enforcement action is not proposed. For packages requiring IE concurrence, the Regional Administrator concurs after the Director, IE/ES, and before the Director, IE.
17 Issue Date: 04/24/85
iI 0400-05.09b ENFORCEMENT PROGRAM
- b. Enforcement Notifications (ens) As a means of noti-fying the Commission of the proposed issuance of an '
escalatec enforcement action, and to give it time to review the action prior to its issuance, IE/ES prepares ) 1 an EN and forwards it to the Commission after the Director, IE, has concurred in the package. If after i 3 days the Commission has not objected to its issuance, the proposed imposition of civil penalty may be signed. If the Commission has already approved the action, the EN_ may be issued on the day the package is issued. I When an order is issued, an EN is issued on the same day the order is signed. If a delay will be encountered in signing a proposed civil penalty action after an EN is issued, the Office of Congressional Affairs must be notified to hold the EN until the action is signed.
- c. Signature The Regional Administrator, or designee, normally signs all nonescalated enforcement actions, and actions proposing civil penalties. The Director, IE, signs all other actions, including Orders Imposing Civil Monetary Penalties, and may sign significant <
escalated enforcement actiors.
- d. Mailing Normally, escalated enforcement packages are mailed by Express Certified Mail, return reccipt requested. '
- e. Distribution The office in which the package is
. signed is responsible for its distribution.
- f. Press Releases Regional enforcement personnel inform the regional Public Affairs Officer (RPAO) when an escalated enforcement action is about to be issued.
The RPA0 prepares a press release and provides copies to IE and to the regional staff for concurrence. After the enforcement action has been signed and the RPA0 has verified that the licensee has been notified of the action and has received a copy, the press release is issued. Each type of action requires a different j timetable for issuance of a press release. The RPA0 should be aware of this and, if in doubt, should consult the Regional Enforcement Staff. 0400-06 THE SUPPLEMENTS Ncte: This section will be provided at a later date and will contain information that has previously been included in EGM's. 0400-07 FORMS Examples of standard format and boilerplate to be use by the regions in preparing draft enforcement packages are provided in the appendices listed in this section. Issue Date: 04/24/85 18
. .L ENFORCEMENT PROGRAM' 0400-07.01 07.01 Letter Transmitting Notice of Violation and Proposed Imposition of Civil Penalty The' standard format and boilerplate for this letter is delineated in Appendix A.
07.02 Notice of Violation and Proposed Imposition of Civil Penalty The standard format and boilerplate for this Notice is delineated in Appendix 8. 07.03- Notice of Violation and Proposed Imposition of Civil Penalty (includes violarions that do not include a civil penalty) The standard format and boilerplate for- this Notice is delineated in' Appendix C. 07.04 Letter Transmitting Notice of Violation (no civil penalty) The standard format and boilerplate .for~ this letter is delineated.in Appendix D.- 07.05 Notice of Violation (no civil penalty) The standard format and boilerplate for this Notice is delineated in Appendix E. END I: 19 Issue Qate: 04/24/85
] APPENDIX A, 0400 . ENFORCEMENT PROGRAM APPENDIX A Docket No.
License No. EA Name of Licensee (Address) Gentlemen:
Subject:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (IES) (NRC INSPECTION (INVESTIGATION) REPORT NO. 50-XXX/85-XX) This refers to the inspection (investigation) conducted on (dates) at the (Plant name), (City), (State). The narrative that follows should, at a minimum, address the following areas: 1) who identified the violation, i.e., the licensee or NRC, and 2) if and when an enforcement conference was held. This paragraph should include the following: 1) a description of the event or circumstances that resulted in the-violation (s), 2) how long did the violation last or when was it identified, 3) what operational mode was the plant operating in, and 4) what was the root cause of the violation. _ To emphasize (state the area where improvement is needed), I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (ies) in the amount of Dollars ($XXX,XXX) for the violation (s) described in the enclosed Notice. In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2 Appendix C (1985) (Enforcement Policy), the violation (s) described in the enclosed Notice has (have) been categorized at a Severity Level . (For those civil penalties that have been escalated, use the following l statement: The base value of a civil penalty for a Severity Level violation is $XXXXX. The escalation and mitigation factors in the Enforcement Policy were considered. The base civil penalty amount has been increased by
~~
XX percent because (use factors as stated in the enforcement policy)
.) (For those civil penalties where mitigation is applicable use the following statement: The base value of a civil penalty for a Severity Level violation is $XXXXX. The NRC Enforcement Policy allows for reduction of a civil penalty under certain circumstances. In this case, the base civil penalty is reduced by XX percent because (use mitigating factors in enforcement policy).) (For those civil penalties involving no change use the following statement: The escalation and mitigation factors in the Enforcement Policy were considered and no adjustment has been deemed appropriate.)
CERTIFIED MAIL RETURN RECEIPT REQUESTED l A-1 Issue Date: 04/24/85
1 ENFORCEMENT PROGRAM APPENDIX A, 0400 . You are required to respond to this letter and should follow the instructions , specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, , including your proposed corrective actions, the NRC'will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2 Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room. The responses direc.ted by this letter and the enclosed Notice are not subjerc to the clearance procedures of the Office of Management and Budget as requirld by the Paperwork Reduction Act of 1980, PL 96-511. Sincerely, i Regional Administrator
Enclosure:
Notice of Violation and Proposed Imposition /'~
%,, )-
of Civil Penalty (ies) l Issue pate: 04/24/85 A-2
APPENDIX B, 0400 ENFORCEMENT PROGRAM APPENDIX B NOTICE OF VIOLATION
-AND PROPOSED IMPOSITION DT CIVIL PENALTY (IES) ,
Name of licensee i Docket No. Facility Name (for Power Reactor) License No.
~
City, State (if non-Power Reactor) EA During an NRC inspection (s) (investigations) conducted on (date) a violation (s) of NRC requirements was (were) identified. In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1985), the Nuclear Regulatory Commission proposes to impose a civil penalty (ies) pursuant to section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205. The particular violation (s) and associated civil penalty (fes) are set forth below: A. (State requirement that was violated) ' Contrary to the above, (date and description of how the requirement was violated.) This is a Severity Level violation (Supplement (Civil Penalty - 5 ).
).
B. (State requirement that was violated) Contrarv to the above, (date and description of how the requirement was violated.) Tr1s is a Severity Level violation (Supplement TCivil Penalty - 5 ). f _). Pursuant to the provisions of 10 CFR 2.201, (name of licensee) l is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region , within 30 days of the date of this Notice a written statement or I' explanation, including for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may issue an order to show cause why the license should not be modified, suspended, or revoked or why such i other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the ! i autnority of section 182 of the Act, 42 U.S.C. 2232, this response shall l te submitted under oath or affirmation. ! B-1 Issue Date: 04/24/85
\
ENFORCEMENT PROGRAM APPENDIX B, 0400 . l Within the same time as provided for the response required above under 10 , CFR 2.201, (name of licensee) may pay the civil penalty (ies) by letter addressed to the Director, Office of Inspection and Enforcement, l with a check, draft, or money order payable to the Treasurer of the 1 United States in the cumulative amount of (write the number) Dollars ($XXXX) l or may protest imposition of the civil penalty (ies) in whole or in part by a ' written answer addressed to the Director, Office of Inspection and Enforcement. Should (name of licensee) fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalty (ies) in the amount (s) proposed above. Should {nameoflicensee) elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty (ies), such answer may: (1) deny the violation (s) listed.in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty (ies) should not be imposed. In addition to protesting the civil penalty (ies) in whole or in part, such answer may request remission or mitigation of the penalty (ies). - In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C should be addressed. Any written a-nswer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate . parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. (Name of licensee) 's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for , imposing a civil penalty (ies). Upon failure to pay any civil penalty (ies) due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty (ies), unless compromised, remitted, or mitigated, may be collected by civil action pursuant to section 234c of the Act, 42 U.S.C. 2282. FOR THE NUCLEAR REGULATORY COMMISSION Regional Administrator Dated at , , this day of 198(X) h sue Date: 04/24/85 B-2
. i APPEN0fX C, 0400 ENFORCEMENT PROGRAM APPENDIX C 1 NOTICE OF VIOLATION l
-AND PROPOSED IMPOSITION 0I CIVIL PENALTY (IES) {
Name of licensee Cocket No. Facility Name (for Power Reactor) License No. City, State (if non-Power Reactor) EA j During an NRC inspection (s) (investigations) conducted on (date) a violation (s) of NRC requirements was (were) identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1985) the Nuclear Regulatory Commission proposes to impose a civil penalty (ies) pursuant to section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205. The particular violation (s) and associated civil penalty (ies) are set forth below: I. Violati.ons Assessed a Civil Penalty l A. (State requirement that was violated) l
~
Contrary to the above, (date and description of how the requirement was violated.) This is a Severity Level violation (Supplement ). (Civil Penalty - $ ). B. (State requirement that was violated) Contrary to the above, (date and description of how the requirement was violated.) This is a Severity Level violation (Supplement ). (Civil Penalty - 5 ). q II. Violations Not Assessed a Civil Penalty A. (State requirement that was violated) Contrary to the above, (date and description of how the requirement was violated.) This is a Severity Level violation (Supplement ). I i C-1 Issue Date: 04/24/85 '
l ENFORCEMENT PROGRAM APPENDIX C, 0400' , B. (State requirement that was violated) Contrary to the abote, (date and description of how the requirement was violated.) This is a Seierity Level violation (Supplement ). Pursuant to the provisions of 10 CFR 2.201, (name of licensee) is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region , within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation: (1) admission or denial of the elleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may issue an order to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of section-182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation. l Within the same time as provided for the response required above under 10 - ; CFR 2.201, (name of licensee) may pay the civil penalty (ies) by j
)
letter addressed to the Director, Office of Inspection and' Enforcement, with a < l check, draft, or money _ order payable to the Treasurer of the United States in the cumulative amount of (write tho number) Dollars ($XXX) or may protest imposition of the civil penalty (ies) in whole or in part by a written answer addressed to the Director, Office of Inspection and Enforcement. Should (name of licensee) fail to answer within the time specified, the , Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalty (ies) in the amount (s) proposed above. Should (name of l licensee) elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty (ies), such answer may: (1) deny the violation (s) listed in this Notice in whole or in part, (2) demonstrate extenuating j circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty (ies) should not be imposed. In addition to protesting the civil penalty (ies) in whole or in part, such answer may request remission or mitigation of the penalty (ies). In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. (Name of licensee) 's attention , is directed to the other provisions of 10 CFR 2.205, regarding the procedure for j imposing a civil penalty (ies). ! l Issue Date: 04/24/85 C-2 l 1 l l
APPENDIX C. 0400 ENFORCEMENT PROGRAM Upon failure to pay any civil penalty (ies) due which has been subsequently determined in accordance with the applicable provisions of 10 CfR 2.205, this matter may be referred to the Attorney General, and the penalty (ies), unless compromised, remitted, or mitigated, may be collected by civil action pursuant to section 234c of the Act, 42 U.S.C. 2282. FOR THE NUCLEAR REGULATORY COMMISSION Regional Administrator Dated at ' this day of 198(X) C-3 Issue Date: 04/24/S5
{ . e
'. j ENFORCEMENT PROGRAM -
APPENDIX D, 0400, APPENDIX D Docket No.
= License No.
EA Name of Licensee (Address) Gentlemen:
Subject:
NOTICE OF VIOLATION (NRC INSPECTION (INVESTIGATION) i REPORT NOT 50-XXX/84-XX) This refers to the inspection (investigation) conducted on (dates) at the (Plant name), (City), (State). (The narrative that follows should, at a minimum, address the following areas: 1) who identified the violation, i.e.', the licensee or NRC, and 2) if and when an enforcement conference 3 was held). This paragraph should include the following: 1) a description of the event or circumstances that resulted. in the violation (s), 2) how long did the violation last or when was it identified, 3) what operational mode was the plant operating in, and 4) what was the root cause of the violation. f In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Psrt 2, Appendix C (1985), the violation described in the enclosed Notice has (have) been classified at a Severity Level . Normally, a civil penalty is considered for a Severity Level violation. However,'after consultation with the Director, Office of' Inspection and Enforcement, I have decided that a civil penalty will not be proposed in this j case because (explanation based on mitigating factors in the enforcement policy), j You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. (Other specific responsec required should be addressed as required.) Af ter reviewing yuur response to this Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement requirements. action is necessary to ensure compliance with NRC regulatory In accordance with Section 2'790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room. l
- .ae Date: C4/24/85 0-1 l
I l APPENDIX D,_0400- ENFORCEMENT PROGRAM The' responses directed by this' letter and the enclosed Not. ice are not subject ', to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Sincerely, l Regional Administrator
Enclosure:
Notice of Violation 4 > i f** . D-2 04/24/85 Issue Da}e:
.- . i n:
ENFORCEMENT PROGRNM APPENDIX E, 0400 APPENDIX E-NOTICE OF VIOLATION Name of licensee Docket No. r Facility Name-(fer Power Reactor) License No. City, State (if non-Power Reactor) EA
~
'During-an NRC inspection (s) (investigations) conducted on-(date) a violation (s) of NRC requirements was (were) identified. The violation (s) involved (brief description). In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violation (s) is (are) listed below:
A. (State requirement that was violated) Contrary to the above, (date and description of how the requirement was violated.) This is a Severity Levei violation (Supplement ). Pursuant to the provisions of.10 CFR 2.201, (name of licensee)
~
is hereby required to submit'to this Office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply,
' including for each violation: (1) the reason for the violations if admitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time, i
Date at this- day of ,198(X). Issue Date: 04/24/85 E-1
., = l , Q,f- -y CC a
.I ,9t UNITED STATES
.[{e m s g ',caL i !2
,,,.[/
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT _ Washingten, D.C. 20555 [. INSPECTION AND ENFORCEMENT MANUAL J DI
/
CHAPTER 2512 LIGHT WATER REACTOR INSPECTION PROGRAM - CONSTRUCTION PHASE 2512-01 PURPOSE - To provide inspection requirements and policy for implementation of the inspection program during construction and major plant modifications. R ! 2512-02 OBJECTIVE The primary objective of the construction inspection program is to ensure public health and safety through the evaluation of the adequacy of licensee performance during construction and major plant modifications. This is to be accomplished by determining licensee effectiveness in identifying condi-
.s tions that may adversely affect operational safety and in achieving compli-( ance with NRC requirements and licensee commitments. This determination V} should provide sufficient information to establish a basis for making recommendations relative to the issuance of an operating license (0L).
Information for the above is to be obtained by direct observation of acti-vities, personnel interviews, review of procedures and records, and by evaluation of licensee and contractor performance, includirig licensee involvement and control over licensed activities. Another objective is to R place more emphasis on direct inspection of work and hardware as compared R to the review of procedures and records. The intent is to determine whether safety related materials, components, structures, systems, and j construction activities are technically adequate and are in accordance with NRC requirements and licensee commitments _ 2512-03 DEFINITIONS 03.01 Licensee. Any individual, corporation, or association that is au-thorized to conduct activities under a license or construction permit issued by the NRC. 03.02 Construction Permit (CP). Authorization from the NRC to begin con-struction of a facility pursuant to 10 CFR 50.10. 03.03 Limited Work Authorization (LWA). Authorization from the NRC to an f applicant to conduct certain construction activities pursuant to 10 CFR 50.10(e)(1) or 10 CFR 50.10(e)(3)(i).
.I I
I s s ue__D_a t e ___0_3 / 26/86_____ j
03.04 NRC Requirements. NRC requir:ments include provisions of the Atomic Energy Act, NRC rules and regulations, conditions of a construction permit , and Commission orders. ,
~
03.05 Licensee. Commitments. Written statements made by the licensee pro-viding informatio.n on how NRC requirements will be met relative to facility design and construction. Most of the commitments are contained in the SAR but may be elsewhere, such as in response to questions from NRR, in the SER, and in ASLB proceedings. 03.06 Quality # Assurance (QA). Quality assurance comprises all those l planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in ser-vice. Quality assurance includes quality control, which comprises those quality assurance actions related to the physical characteristics of a ma-terial, structure, component, or system which provide a means to control the quality of material, structure, component, or system to predetermined requirements. .- 03.07 Quality Assurance Manual (QA Manual). Quality assurance manual re-fers to the aggregate collection of internal instructions and procedures established by each organization that has been delegated QA program respon-sibilities and whose objective is to ensure acceptable implementation of the QA program. 03.08 Review. A deliberate, critical examination. 03.09 Construction Milestones. Preselected construction events that are .- used to determine construction status and to aid in establishing inspection " " ' points in the inspection program. For the purpose of scheduling, the term
" complete" means essentially complete or sufficiently complete so that other dependent activities can proceed. The following milestones are per-tinent to the construction inspection program.
Milestone Milestone Event 140 Application docketed 200 CP (or LWA) issued 209 Site preparation started ' 210 Site prepared 219 Safety-related structural concrete placement started 220 Reactor / containment building foundation completed 239 Installation of containment liner started 240 Containment structure and liner completed 249 Major component structures and supports started 250 Major component structures and supports completed
- l 260 Reactor / containment building crane installed 269 Installation of safety related components within reactor coolant boundary started
- 270 Reactor vessel installation completed 275 Installation of safety-related components within coolant boundary completed 279 Primary piping installation started 280 Primary piping installation completed }
284 Electric cable installation started I 285 Electric cable installation completed l Issue Date: 03/26/86 2512 j
Milestone Milestonc Event i 294 Instrumentation installation started -? 295 Instrumentation installation completed (s 300 Cold-hydro test completed 309 In-service baseline inspection started 310 In-service baseline inspection completed 320 Hot-functional test completed 340 Operating license issued 2512-04 RESP 0'NSIBILITIES AND AUTHORI' TIES 04.01 Director, Office of Inspection and Enforcement. The Director has responsibility and authority for:
- a. Overall direction of program development.,
- b. Overall direction of the assessment of regional implementation of the established inspection program.
04.02 Director, Division of Inspection Programs. The Director has respon-siblity and authority for:
- a. Administration and control of inspection program development and revision.
_ b. Administration and control of assessment of regional implementation of the established inspection program.
- c. Assessment of the effectiveness and uniformity of the established inspection program.
04.03 Regional Administrator. The Regional Administrator has responsibi-lity and authority for overall direction of the implementation of the in-spection program. 04.04 Director, Appropriate Regional Office Division. The Director has responsibility and authority for administration and control of the imple-mentation of the inspection program. 2512-05 PROGRAM POLICY 05.01 The licensee is ultimately responsible for the safety of the nuclear facility. The NRC ensures through an audit type of inspection program that this responsibility is carried out in an effective manner during the acti-vities of plant construction and major modifications. The construction inspection program presented in this chapter is considered the minimum necessary to achieve an acceptable level of confidence as to the quality of construction at a facility. 05.02 The program is supplemented by other related programs such as the Vendor Inspection Program (MC 2700) and the Construction Appraisal Team Inspection Program (MC 2920). These programs can be us'ed to assist in meeting the program objectives. un _e_ m_._ mm. e m, m,
2512-06 PROGRAM REQUIREMENTS 06.01 Inspection Requirements. The inspection procedures (IPs) and Tem-porary Instructions (tis) applicable during construction are provided in Appendices I and II. , R --
- a. The procedures in Appendix I represent the inspection requirements i
that must be satisfied before an operating license is to be issued. Regional management should assure that the requirements of the pro-gram have been met through Regional inspection, IE inspection, or otherwise/dispositioned through allowable options of SALP.
- b. The tis applicable to the constructi.on phase and the expiration dates are listed in Appendix II.
R 06.02 Level of Effort. The amount of inspection effort required to ensure the same degree of confidence that construction is adequate will vary from site to site. Similarly, different types of construction activity at the same site may require various levels of effort to provide the same degree of assuranc~e of quality work. Generally, an. increase or decrease of in-spection effort will be based on an evaluation of the licensee's perfor-mance, such as through the SALP program.
- a. For multiunit facilities, the construction inspection effort rela-tive to the review of QA/QC procedures may be reduced for subsequent units when no substantive changes have been made to the QA Program for subsequent units. This reduction may be accomplished in the detailed review of the QA/QC procedures established in the QA pro-gram. However, it should be noted that revisions to procedures that n.2 may have a significant adverse effect on quality should be examined for all units. Therefore, sufficient inspection is required to as-certain the adequacy of procedures common to each unit. Completion of construction inspection requirements relative to observation of work and review of quality records is required for each unit under construction, t
- b. Inspection procedures within each major construction discipline in-clude requirements to complete IP 35100, Review of QA Manual. Even though this procedure is referenced a number of times in construc-tion inspection procedures, it is not intended that the inspection requirements of IP 35100 be repeated for a specific organization at the site if the same QA procedures and same personnel were previous-ly examined. In general, the inspection requirements of IP 35100 need be completed only once for each site organization associated with a particular construction activity. It should be noted, how-ever, that diffe ent aspects, requirements, and procedures of the QA program may apply to different activities performed by one contrac-l tor at the same site. For example, inspection and documentation t procedures related to welding may be considerably different for reactor coolant pressure boundary pipe welding as compared to '
structural steel welding. If this is the case, parts of IP 35100 ! would be repeated. Generally, the various IPs indicate that changes to the QA Manual should be considered for review during scheduled l followup inspections in each area. If the changes to the QA Manual for a contractor have not been reviewed for a relatively long period j of time (e.g., over 2 years), the inspector should, as a minimum, l Issue Date: 03/26/86 2512
i determine whether any changes have been made and whether these changes are appropria,te and adequate. It'should be noted that IP 35100'is a reference procedure and is not to be used on Form NRC-766 _ to record an inspection effort. The procedure referencing IP 35100
'( is to be used for this purpose.
- c. Several procedures permit a reduction of effort for particular 'in-spection areas based on previous inspection results. They also identify specific items for increased inspection based on a Category 3 SALP . determination.
06.03 Program Scheduling. To adequately fulfill the requirements of this program, effective planning is required so that the various inspection re-quirements are completed in a reasonable time by properly qualified inspec-tors. - For example, although the construction phase of the LWR inspection program is predominately applicable to facility construction and miljor facility modification, it does include certain associated design ,and procurement activities which occur at the site. Also, activities conducted under other programs of MC 2500 need to be considered. Inspection of major construction activities will begin when a CP h LWA is issued. Some early construction activities such as soil b) ring, site pre-paration, ' ground water control, excavation, and concrete batch plant erec-tion may precede the issuance of a CP or LWA. In addition, ,some of the pre-CP phase inspection activities (MC 2511) are performed concurrently with the construction inspection activities. Final activities of the con-
, struction inspection program also overlap with the preoperational testing and operational preparedness . phase activities (MC 2513) and may continue during the startup phase (MC 2514).
- a. Some of the procedures of Appendix I are keyed to milestones re-lating to the status of work activities at the construction site.
Because NRC inspection activities must be coordinated with construc-tion activities, the inspector must be cognizant of construction . status for appropriate inspection planning. It should be noted that 1 the proper sequence of certain construction and inspection activi-ties also is important.
- b. In addition to listing the procedures associated with the NRC con-struction inspection program, Appendix I includes the frequency of inspection and the time frame for initiation and completion of the various inspection procedures. This time frame pertains to the actual work progress of that particular activity at the construction site and not to the construction status of the overall facility.
Some inspection procedures, such as those pertaining to welding, are required to be used throughcut most of tne construction phase. Because team inspections are an effective inspe': tion method, their c. use by the regional office is encouraged. 06.04 Use of Inspectors. In accordance with the obf.ective of this pro- R gram, the majority of the assigned inspector's time should be directed to R hardware inspections as compared to the review of procedures and records. R Inspection assignments should etnphasize the early identification of problem R areas. R oams a- _x-~- a n-- assensma
The regional offices have the responsibility to assign insp;ction require- R i ments to either the resident or regional inspectors consistent with the R l qualifications of the individual inspectors. In general, the resident R inspectors should provide some degree of direct verification of licensee R construction performance for all activities while the regionally based R - inspectors shoul'd provide the necessary expertise to complete specialized, R technical inspecti'on requirements of the inspection program. R Comprehensive reviews of programs and procedures should be conducted as a R result of an identified hardware problem with the objective of determining R the underlying u cause or generic implications of the problem. In following R up identified problem areas the emphasis should be on focusing the licen- R see's efforts to arrive at long-term resolutions. R It is the perogative of regional management to determine which program R areas are to be emphasized by the assigned inspectors. There are a number R of areas in which the inspectors can be utilized consistent with the status R of construction and the MC 2512 program.for the site. The.se are: R
~
- a. A more in-depth MC 2512 program. As the MC 2512 program defin'es the R required inspection effort to adequately assess plant construction, R the additional effort of the assigned inspectors may be used to R increase the scope of the routine inspection requirements for areas R of construction assigned a SALP Category 3 rating. It is suggested R that the effort be concentrated on the inspection procedures for R observation of work and completed construction. The inspection R requirements pertinent to previously identified problems or common R construction problem areas may be emphasized or performed again. R Inspection efforts should be more result oriented and focus on R AfD programmatic issues when there are problems that indicate program- R matic weaknesses. The inspectors should focus on problem areas to R determine the root cause and to verify the implementation of broad R corrective action. R
- b. Review of reports for applicability of identified problem areas. R The efforts of the regional or resident inspectors may be used in R evaluating reports of previously identified problems or potential R problems. The results of NRC and industry reports can be reviewed R and inspections performed to determine applicability to the specific R site. If the report is written against the specific site, the ef- R fort can be used in evaluating the adequacy of the licensee's cor- R rective actions. The types of reports to consider include Construc- R tion Appraisal Team, SALP, INPO and consultant reports of licensee R l
self-initiated evaluation of construction. These reports also can R provide direction toward the determination of problem areas and R their root cause. R
- c. Allegation investigation and followup. As construction approaches R completion, the resolution of allegations may rfquire increased R '
resources from the licensee and the NRC regional and resident R inspecte . R
- d. Craft and inspector training, qualification and performance. The R inspector's efforts could be directed towards an in-depth coverage R {
of the licensee's programs for training and qualifying their con- R ; { struction workers and inspectors. The licensee should be emphasiz- R ! ing that the job' be done right the first time and discourage an R j Issue Date: 03/26/86 2512 J
l l
, attitude that quality control'will catch the construction mistakes. R )
The adequacy of the . licensee inspector's performance and tools R (checklists, acceptance criteria, inspection reports) could .be R-
.( revie* d in detail. R
]
- e. Prevention and early identification of problems. Other efforts the R inspectors could emphasize for the early identification and preven- R ,
tion of problems include: R j 1
- 1. Review of the licensee's preparation for safety-related con- R {
struction activities. This .is to ensure the timeliness of R .i planning and program actions and the availability of resources R for upcoming and current construction activity. R
- 2. Informal discussions with licensee and contractor working level R personnel can be conducted to determine attitudes, demands of R schedule, and individuals' . perceptions of. work quality to.be R used as problem indicators. R
- 3. A preliminary as-built review can be conducted six months before R the formal NRC inspection to determine the licensee's level of R ;
readiness. This would include the status of procedures, ade- R quacy of resources (numbers, skills, qualifications), and a R sample of hardware for completeness. R
- 4. Periodic in-depth reviews of site management and performance. R An experienced, informed, effective and communicating management R 4 organization will help ensure problem identification and resolu- R !
~
tion and effective use of trending programs. Particular atten- R tion should be given to management's involvement in such areas R I as trending, diagnosing root cause of identified problems and in R effectively communicating the need for adequate corrective R action. R
- 5. Early evaluations of system turnover programs. , Emphasis should R be given to the review of the licensee's program and procedures R
.for control and turnover of systems from construction organiza- R tions to startup, testing, and operations organizations. The R turnover process represents an important step in verifying the R quality of construction completion and readiness for plant R testing. Inspections in this area should ensure that the or- R ganization's responsibilities are well defined, the construction R and quality status of turnover systems are accurately recorded R at turnover, and changes initiated to systems by startup or R ,
operations are properly documented, controlled, and appropriate- R
, ly inspected. R I
06.05 Major Plant Modifications. The regional offices are responsible ;
. for the preparation and implementation of a plan for the inspection of the .
safety-related aspects 'of major plant modifications. The plan should be j based on the inspection requirements of this and other related manual chap-ters. It should be developed and maintained in a current status on the > basis of licensee input on the scope of the effort, including applicable technical and quality commitments included in the SAR or SER, or supple- , ( ments thereto. This planning effort also should review the Licensee's pro- ) gram for control, protection, and requalification, as necessary, of safety- ) 1 cwao - - - - m *-r na can m nGveArNR
.' related items connectsd or adjacent to structures, systems, and co:ponents
- t. hat will be te:porarily re oved or otherwise affect 2d by the modification.
The regional offices should forward l a copy of the program plan for inspec-tion of major modifications, and of any significant changes thereto, to the IE Director of the Division responsible for inspection programs. - 2512-07 PROGRAM MANAGEMENT 07.01 Implementation. The Regional Offices are responsible for the imple-mentation of the ' inspection program described in this chapter and related
~
appendices. The inspection program is intended to provide the framework for managing the inspection effort without being totally prescriptive. Not all sample sizes and frequencies of periodic inspections are explicitly specified, and the time frame when certain inspection activities are to be performed is not rigid. Additionally, inspectors are required to initiate and conduct inspections outside the scope of the routine program as pre-vided by IP 92706, Independent Inspection Ef fort.- This .IP- provides a n opportunity to inspect portions of .the routi'ne program- in ' greater deteil, more frequently, and in areas not covered by the routine program, as cor' ditions warrant. Although this inspection program contains the minimum inspection require-ments, situations may arise where parts of the program cannot be completed or otherwise satisfied by related programs referenced in this chapter. In such cases, regional management shall review, approve and document such , modifications to the program. This usually should be part of the SALP pro-cess. 07.02 Inspection Findings. As stated in Title 10 CFR and in MC -2500, NRC inspectors perform a basic mission in determining whether a licensee meets ! current regulatory requirements and commitments. Identifying specific instances where a licensee fails to meet such requirements and commitments, although important, has frequently in the past resulted in correction of symptoms rather than correction of underlying causes of licensee problems. Inspection findings should result in the early identification and resolu-
- tion of problems, their root causes, and generic implications.
Because of limited inspector resources and the minimum baseline aspect of ) the program, the inspection procedures cover only a small sample of licen-see activities in an area. Thus, it is important that an inspector eval-uate whether a noted noncompliance or deficiency represents an isolated case or may be symptomatic of a broader, more serious problem in that area. i To provide the perspective to perform this evaluation, the inspector j should:
- a. Keep currently informed of deficiencies, audit findings, and plant proolems identified by the licensee's own Organization or by his l contractor's organization.
- b. Ascertain whether additional NRC inspection effort is merited in the area under consideration.
I l l l l Issue Date: 03/26/86 2512 __ _ _ _ _ _ _ . . _ _ _ _ _ . _ _ _ _ _____m.____..___ ______ _______ _ , _ _
Where the evidence indicates a symptomatic problem, action should be taken I to require the licensee to demonstrate to the NRC that it has not lost con-trol of that area. Regional Management should be consulted whenever such l action appears appropriate to the individual inspectors. Enforcement ac-
~
( tion, if warranted, should be in accordance with IE Enforcement Actions policy. 2512-08 INTERFACE WITH RELATED PROGRAMS 08.01 Construction Appraisal Team (CAT) Inspection Program. The CAT pro-gram uses integrated, multidisciplined inspections to determine if a faci-lity is being constructed in accordance with regulatory requirements and if i the applicant's management and quality control programs are effective. The ' inspections are focused primarily on hardware installation and construction quality. Although specific responsibilities are provided by MC 2920, the IE/ region interfaces are summarized here. .
- a. IE will solicit the region to provide an inspector who will partici-pate as an active team member. The resident inspector at the selec-ted facility, although not assigned as a team member, should attend the daily CAT briefing meetings and the exit meeting with the licen-see.
- b. The regional offices have the responsibility for followup action on the potential enforcement actions described in the CAT inspection reports. .
s
- c. The appropriate regional management will. be sent' recommendations on the extent to which the CAT effort satisfied the inspection program 4 requirements of this manual chapter.
- d. The CAT inspection results will be used in the assessment of region-al performance of the construction inspection program.
1 08.02 Licensee Contractor and Vendor Inspection Program (LCVIP). General I policies for Vendor Program / region interfaces are described in MC 2700. Changes, as they occur, will be addressed in a revision of MC 2700-08.03 Systematic Assessment of Licensee Performance (SALP) Program. The SALP program (NRC MC 0516) is a comprehensive, periodic appraisal by the , NRC staff of power reactor licensees. It is designed to improve licensee l performance, improve the NRC regulatory performance by determining which ; areas need increased inspection emphasis, and to provide a basis for man- i agement allocation of NRC resources. The regional offices have the respen-sibility to adjust their expenditure of inspection resources based on the rated performance of the licensee, and the inspection procedures provide l the flexibility for the regional offices to increase or decrease the amount of inspection consistent with the SALP evaluation. 08.04 Security and Safeguards Inspections. The Security and Safeguards inspection activities, as judged appropriate by regional management, will be conducted as an earlier effort of the program set forth in IE MC 2513. i l 2512 Issue Date: 03/26/86 _ - ____ -_____-
8
- 6 Selected portions of preoperational safeguards inspection activities, such '
as barriers for alarm stations and vital areas, should b2 conductett as rar-ly as practical during construction and installation of security ieatures. Such early onsite examination is, intended to preclude the existence of later identified problems which may not be resolvec; due to completed work. . _ _ Some of these early reviews may be possible during onsite accompaniment of licensing reviewers. END Appendices b,C' I l l Issue Date: 03/26/86 2512
LIGHT WATER REACTOR INSPECTION PROGRAM - CONSTRUCTION PHASE - APPEN0IX I, 2512 R l APPENDIX I R PURPOSE The puroose of this appendix is to list the current inspection procedures (IPs) that are applicable to construction and major modification activi-l ties, along with condensed scheduling information. 1 IP PROCEDURE . INSPECTION SCHEDULE NUMBER SHORT TITLE MAi START MUST START MUST COMPLETE l -
~
Management Meetings 30050B CP Corp. Mgt. Mtg. (CP issuance i 1 month) 30702B Management Meeting 200 As needed 340 30703B Management Meeting - (Every routine inspection) Entrance & Exit
- Quality Assurance 3 (' 35020 Audit of Applicant's 5 mo. after As needed ----
Surveillance of docketi'ng Contractor QA/QC 35051B Site Erected ---- ---- Before work is Reactor Vessels - 10% complete QA Procedures 35060 Lic. Ngt. of QA Act. Initial Insp. ---- CP + 6 mo. ---- Subsequent ---- ---- Every 18 months 35061 In-Depth QA Insp. ---- ---- Annually of Performance 35065 Procurement, Rec'g. and Storage Initial Insp. ---- CP + 12 mo. ---- Subsequent ---- ---- Every 24 months 35100 Review of QA Manual (As referenced in applicable IPs) 35960 QA Prog. Evaluation (As required) of Engrg. Serv. Org. e no *a n m -n ^^- ^~~ ~
l (* LIGHT WATER REACTOR INSPECTION ! 2512, APPENDIX I PROGRAM - CONSTRUCTION PHASE R I-
~
-IP PROCEDURE - INSPECTION SCHEDULE !
NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE 10 CFR 21 36100 Part21ibspection Initial Early const for ---- constr. mgr./ vendor, as req. l Subsequent ---- Major subs. and_ ---- vendors, as req.
~
Desian and As-Built Verification ~ 37051 Verif. of As-Builts ---- One year before ---- operating lic. 37055 On-Site Design Act. Initial ---- 6 mo. after ---- activity starts Subsequent ---- ---- Every 18 mo. - l-Fire Prevention and Protection 42051C Fire Prot./ Prev. After work Before work is Before work Procedures is started 20% complete is complete Geotechnical/ Foundation Activities 45051 Procedure Review 6 mo. before 1 mo. before Before signif work starts work starts work starts 45053 Work Observation Af'ter work 6 mo. after Before work ; is started work starts is complete 45055 Record Review With IP Before 9 mo. Completed work 45053 of work + 6 mo. Structural Concrete 46051 Procedure Review 3 mo. before Before work Before con-CP or LWA is started tainment ext. walls are placed 46053 Work Observation When placement Before contain- After last is started ment basemat significant ; is placed placement Issue Date: 03/26/86 AI-2 R l
- l l
LIGHT WATER REACTOR INSPECTION I PROGRAM - CONSTRUCTION PHASE . APPENDIX I, 2512 R j ( I IP PROCEDURE INSPECTION SCHEDULE l NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE 46055 Record Review With IP 46053 Before 9 mo. CAT I place-of CAT I ment complete placement + 6 mo. Containment (Post-Tensioning) 9 47051 Procedure Review After basemat 3 mo. before Before tendon . work starts P-T begins installation ! 47053 Work Observation When P-T begins ^ (As required by IP) 47055 Record Review With IP 47053 Before tendons P-T complete are 50% inst. + 6 mo. Structural Steel and Supports 48051 Procedure Review After proc. Before work Before work is are developed is started 20% complete 48053 Work Observation After work Before work is Before work is is started 10% complete 80% complete 48055 Record Review With IP 48053 Before work is Completed work 50% complete + 6 mo. Reactor Coolant Pressure Boundary Pipino 49051 QA Review 6 Mo. before ---- Before work i's work starts 10% complete 49053 Work Observation First Inspection After work is Before work is Before work is 10% complete 20% complete 30% complete Second Inspection After work is Before work is Before work is 50% complete 60% complete 80% complete
- Semi-Annual ----
Optional ----- l 49055 Record Review First Inspection After work is ---- Before work is 20% complete 40% complete Second Inspection After work is Before work is 280 + 1 mo. 60% complete 80% complete AX-1 lum fMm -M/N/K A 4
i LIGHT WATER REACTOR INSPECTION y 2512, APPENDIX I PROGRAM - CONSTRUCTION PHASE R
. ~.
IP PROCEDURE- INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE Safety-Related Pipina 49061 QA Review 6 mo. before , Before work is work starts 10% complete 49063 Work Observation After work is After work is Before work is 20% complete 40% complete 80% complete
. 49065 Record Review After work is .Before work is Before work is 30% complete 50% complete 80% complete Mechanical Components 50051 RV and Internals - 6 mo. before ----
Before work is QA Review install. comp 1. 10% complete 50053 RV and Internals - Vessel ---- During install. ---- Internals ---- During install. ---- Storage Insp. ---- Quarterly ---- 50055 RV and Internals - ---- When work is Work complete Record Review complete + 2 mo. 50071 Safety-Related Comp. 6 mo. before Before work Before work is Procedure Review work starts starts 10% complete 50073 Safety-Related Comp. i Work Observation First Insp. After work is Before work is Before work is 10% complete 20% complete 30% complete Second Insp. After work is Before work is Before work is 50% complete 60% complete 80% complete 50075 Safety-Related Comp. Record Review First Insp. After work is Before work is Before work is 20% complete 30% complete 40% complete l 1 Second Insp. Before work is Before work is Before work is 60% complete 70% complete 97L complete 50082B Site Erected RV ---- ---- Before work is Procedures 10%; complete l l 1 Issue Date: 03/26/86 AI-4 ,, R
T
^
LIGHT WATER REACTOR INSPECTION PROGRAM - CONSTRUCTION PHASE , APPENDIX I, 2512 R I( . v IP PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST STAE.T MUST COMPLETE _. 50083B Site Erected RV After work is Before work is 270 Work Observation 10% complete 30% complete 50085B Site Erected RV After work is Before werk is 270 + 1 mo. j Record Review 10% complete 30% complete
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50090 Pipe Support and ---- Before work is Work complete Restraint Systems 20% complete + 3 mo.
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50095 Spent Fuel Storage 3 Mo. before Before work is Before work is Racks ' installation 10% complete complete 50100 HVAC Systems (As required by IP) ElectricalandInstrumentatic[ 51051 Elec. Components Procedure Review Initial Insp. 4 Mo. before' 'Before work Before work is works starts starts 20% complete
^
Followup Insp. After work is After work is 40% complete 50%. complete Before work is 70% complete Il 51053 Elec. Components After work Before work is Before work is Work Observation starts 20% r6mplete 90% complete 51055 Elec. Components Record Review First Insp. After work is Before work is Before work is 30% complete 40% complete 50% complete Second Insp. After work is Befwe work is Work complete 60% complete 70% complete + 2 mo. 51061 Electric Cable Procedure Review Initial Insp. 6 Mo. before Before work Befo e work is work starts starts 20% complete Followup Insp. After work is After work is Before work is 40% complete 50% complete 70% complete 51063 Electric Cable After iork Before work is Before work is Work Observation starts 20% complete 90% complete (
- \
I Al .5 1ssue Date: 03/26/86 R
LIGHT WATER REACTOR INSPECT 10N 2512, APPENDIX I PROGRAM - CONSTRUCTION PHASE R _4
'IP PROCEDURE. INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE s
i b r . 51065 Electric, Cable Record Review first Insp. When cable When cable When cable wo'rk is 20% ' work is 30% work is 50% 4 complete complete complete Second Insp. When cable When cable Work complete
' work is 60% work is 70% + 2 mo.
complete . complete 52051 Instrument Comp. Procedure Review Initial Insp. 4 Mo. before Before work Before work is I work starts starts 20% complete l Followup Insp. After work is After work.is Before work is ' 40% complete 50% complete 70% complete 52053 Instrument Comp. After work Before work is Before work is Work Observation starts 20% complete 90% complete 52055 Instrument Comp. Record Review ~ First Insp. After work is Before work is Before work is
. 20% complete 30% complete 50% complete !
Second Insp. After work is Before work is Work complete 60% complete 70% complete + 2 mo. Containment Penetrations (Mechanical) 53051 Procedure Review Start of liner ---- Before work is ss installation 10% complete
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1 53053 Work Observation I 'First Insp. After work is Before work is Before work is 20% complete 40% complete 60% complete Semi-Annual ---- During install. ---- 53055 Record Review After work is Before work is Before work is 30% complete 50% complete 80% complete Welding and Nondestructive Examination ( 55050 Nuclear Welding General , First Insp. ---- After work is Bef. ore work is 5% complete 15% complete Issue Date: 03/26/86 Al-6 R
LIGHT WATER REACTOR INSPECTION PROGRAM - CONSTRUCTION PMASE APPENDIX I, 2512 R s ( , IP PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE Subsequent Insp. ---- Periodically ---- 55092B Site Erected Retr After work is Before Work 270 R Vssi Work Observ. 10% complete 30% complete R 550938 RV Internals Weld . ---- During Installation R Work Observation Installation + 1 mo. R 55100 Structural Welding - General _ First Insp.- -- After work is Before work is 5% complete 15% complete Subseq. Insp. ---- Periodically ---- 55150 ' Weld Verification (As required) 57050 NDE - Visual First Insp. After work is ---- Before work is 10% complete 25% complete Second Insp. After work is Before work is Before plant 75% complete 90% complete startup ; 57060 NDE - PT First Insp. After work is ---- Before work is 10% complete 25% complete Second Insp. After work is Before work is Before. plant 75% ccmplete 90% complete startup 57070 NDE - MT First Insp. After work is ---- Before work is 10% complete 25% complete Second Insp. After work is Before work is Before plant 75% complete 90% complete startup 57080 NDE - UT First Insp. After work is ---- Before work is 10% complete 25% complete Second Insp. After work is Before work is Before plant 75% complete 90% complete startup
, 57090 NDE - RT First Insp. After work is ----
Before work is , 10% complete ' 25% complete 1 AI-l Issue Date: 03/26/86 R
LIGHT WATER REACTOR INSPECTION { 2512, APPENDIX I PROGRAM - CONSTRUCTION PHASE R < i' IP . PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE Second'Insp. After work is Before work is Before plant 75% complete 90% complete startup containment Structural Integrity Test . 63050 SIT 2 months Before SIT Before OL before start starts issuance of test , Fire Prev'ention and Protection 64051B Procedures 220 269 280 64053B Fire Loop Install. After work is Before work is Before work 10% complete 50% complete is complete Low-Level Radioactive Waste Storage 65051 Radwaste Storage (As specified by IP) Inservice Inspection 73051 Program 6 mo. before ---- 309 309 73052 Procedures 4 mo. before 309 310 309 730538 Preservice Observ. After work is Before work is Before work is 10% complete 30% complete 90% complete 73055B Preservice Data After work is Before work is 310 + 2 mo. 20% complete 50% complete i Environmental Protection 80210 Initial Inspection Pre-LWA or CP Post-LWA or CP CP + 3 mo. R Subsequent Every 18 mo. after initial inspection R Event Reports 90712 In-Office Review (As required) R I Issue Date: 03/26/86 AI-8 R
l LIGHT WATER REACTOR INSPECTION , PROGRAM - CONSTRUCTION PHASE APPENDIX I, 2512 R IP PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START. MUST START MUST COMPLETE' Extended Construction Delay 92050 Site Activities Initial Insp. ---- When notified ---- Subsequent ---- Every 6 mo. ---- Followups Event Reports (As required) 92700 R 92701 Identif. Problem (As required) R 92702 Noncompliance (As required) 92703 IE Bull./ Action Ltr. (As required) 92704 HQ Requests (As required)
~
R
) Regional Requests (As required)
(P3 92705 R Independent Inspection Effort 92706 Indep. Effort (As required) Testimony for ASLB or ASLAB Hearings 94010B Hearings (As required) Operating Licensee Issuance 943008 OL Issuance (As required) Information Meetings with Local Officials 94600 Info. Meetings (As required) Meeting Participation 94700 ACRS (As required) 94702 NRR/ Licensee (4 required) . ( . moe nnne anom m#mem a l
I APPENDIX II
/ .
I PURPOSE The purpose of this appendix is to list the Temporary Instructions (tis) R j applicable to the Construction Phase. ' TI Number Title Expir. Date i 2512/07 (Rev. 2) Regional Construction Assessment 03/01/86 Team Inspections 2512/13 Inspection of Replacement of BWR (No expira- R Recirculation Piping. tion date) R These tis remain valid for use "as required" until -otherwise noted by a R Change Notice. (This appendix is not always kept current.) R
. { f' ,t V,
i ARRo? 9mc<ncm (ikon 'id)21AR(SOf%S
L
- ~4 .
I LIGHT. WATER REACTOR INSPECTION
. ' PROGRAM - CONSTRUCTION PHASE APPENDIX III, 2512 R APPENDIX III R A. ; PURPOSE
~
' The purpose. of this appendix is to list all inspection procedures (IPs) that may be in use during the construction phase, but are' not included in Appendix I of 2512 as current revisions. R B. BACKGROUND.
Most of the procedures' listed in this appendix have been superseded by. revised procedures. However, the intent ef this appendix is to recog-- nize that the ' listed procedures ara acceptable' for use where' the-
. ' inspection activity was started before the procedure was superseded. "
Therefore, the IPs listed in this appendix should be retained until. inspections using these IPs have been completed or until Regional management has decided to complete the inspection activity using the IPs listed in Appendix I. The early use of precedures listed in R Appendix I is encouraged. R The superseded IPs that should be retained are usually shown with asterisks on the Change Notices to the IE Manual. In general, IPs with a 'B' or 'C' suffix have been repTaced with IPs without suffix
. letters. '
IP PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE q i Management Meetings 30051B Construction QC (Annually after CP) Quality Assurance 350208 Audit of Applicant's 5 mo. after As required ---- Surveillance of docketing Contractor QA/QC Activities 35060B Lic. Mtg. of QA Act. (Once every 18 months) 35061B In-Depth QA Insp. (Annually) ' j of Performance i 35065B Proc., Rec'g & Stg. (Annually after CP) i 35100B Review of QA Manual (As required)
- ObM Si
4 '
- a LIGHT WATER REACTOR INSPECTION 2512, APPENDIX III PROGRAM - CONSTRUCTION PHASE R
. IP PROCEDUR'E INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE 10 CFR 21 361003 Part 21 Inspection Licensee (Once every 2 years) Constr. Mgr. (Once every 2 years) Design and As-Built Verification
~
37051B Review of As-Builts (1. year before OL) 37055B On-Site Design Act. (Annually after CP) Site Preparation 45051B Review of QA 140 ---- 209 + 1 mo. 45055B Record Review After work is Before work is 210 + 1 mo. 50% complete 60% complete Lakes, Dams and Canals jn .. ,, 45061B Procedure Review 200 - 6 mo. ---- Before work is L.- 10% complete 45063B Work Observation After work -is Before work is Before work is 20% complete 50% complete 60% complete 45063C Work Observation After work Before work is Before work is has started 20% complete complete 45065B Record Review After work is Before work is Work complete 30% complete 60% complete + 1 mo. Foundations 460518 Procedure Review 219 - 6 mo. Before work is 219 10% complete , l 46053C Work Observation After work Before work is Before work is has started 20% complete complete i 46055B Record Review After work is Before work is 220 + 1 mo. l 30% complete 60% complete j 46153B Site Prep. & Found. After work Before work is Before work R has started 20% complete is 80% com-plete ! Issue Date: 03/26/86 AII'I-2 R _______._________-m___
l LIGHT WATER REACTOR INSPECTION
, PROGRAM - CONSTRUCTION PHASE APPENDIX III, 2512 R l
IP PROCEDUR'E INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE l Containment (Structural Concrete) 47051B Procedure Review 200 - 3 mo. - ---- Before work is 10% complete 47053B Work Observation After work is ---- Before work is 10% complete 30% complete 47053C Work Observation After work Before work is Before work is has started 20% complete cocole'et 470548 Work Observation After work is Before work 1s Bef ww work is 50% complete 70% complete 801 < , s.plete 470558 Record Review After work is ---- Before work is 10% complete 50% complete 47056B Record Review After work is Before work is 240 + 1 mo. 50% complete 70% complete C) 47061B Proc. Review (P-T) 220 ---- Before work is 10% complete 47063B Work Observ. (P-T) After work is Before work is Before work is 10% complete 40% tomplete 80% complete 47063C Work Observ. (P-T) After work Before work is Before work is has started 20% complete complete 47065B Record Review (P-T) After work is Before work is 240 + 1 mo. 20% complete 60% complete Containment (Steel Structures & Supports) 48051B Procedure Review 220 ---- Before work is 10% complete 48053B Work Observation Af ter work is Before work is Before work is 20% complete 50% complete 70% complete 48053C Work Observation After work Before work is Before work is has started 20% complete complete 48055B Record Review After work is Before work is Before work is 30% complete 50% complete 80% complete I AIII-3 . Issue Date: 03/26/86 R
l LIGHT WATER REACTOR INSPECTION 2512, APPENDIX III PROGRAM - CONSTRUCTION PHASE R IP PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE Structures (Structural Steel and Supports)
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48061B Procedure Review Before work is 220 ---- 10% complete 48063B Work Observation After work is Before work is Before work is 10% complete 30% complete 40% complete 48063C Vork Observation After work Before work Before work is has started' 20% complete complete 48064B Work Observation After work is Before work is Before work is 50% complete 60% complete 80% complete 48065B Record Review After work is ---- Before work is 20% complete 50% complete 48066B Record Review After work is Before work is 250 + 1 mo. 50% complete 80% complete s Reactor Coolant Pressure Boundary Piping 49051B Procedure Review 279 - 6 mo. ---- Before work is 10% complete 49053B Work Observation After work is Before work is Before work is 10% complete 20% complete 30% complete 49053C Work Observation After work Before work is Before work is has started 20% complete complete 49054B Work Observation After work is Before work is Before work is 50% complete 60% complete 80% complete 49055B Record Review After work is ---- Before work is 20% complete 40% complete ! 49056B Record Review After work is Before work is 280 + 1 mo. 60% complete 80% complete l Safety-Related Piping
)
49061B Procedure Review 279 - 6 mo. ---- Before work is 10% complete 490638 Work Observation After work is Before work is Before work is 20% complete 40% complete 60% complete 1 1 Issue Date: 03/26/86 AITI-4 R 1 l '- _ __ ___ _ __ _
v* .. 9 LIGHT-WATER REACTOR INSPECTION j l: . PROGRAM - CONSTRUCTION PHASE APPENDIX III,'2512 R { 3
. __. . l IP. PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE 49063C Work'0bservation After work Before work is Before. work is
-' has started 20% complete complete 490658 Record Review After work is Before work is Before work is 30% complete 50% complete 80% complete Reactor Vessel and Internals 500518 Procedure Review 270 - 6 Mo.
- :- Before Work is.
10% Complete 500538 Work Observation ---- Before 270 270 + 1 mo. 50053C Work Observation After work Before work is .Before work is has started- 20% complete complete l 500558 Record Review ---- 270 270 + 2 mo. 50061B Procedure Review 270 - 6 mo. ---- Before work is 10% complete r'~')
*' 500638 Work Observation ----
During Installation installation + 1 mo. 50063C Work Observation After work Before work is Before work is has started 20% complete complete Installation. 50065B Record Review ---- Installation
+ 1 mo. + 2 mo.
Mechanical Components 50071B Procedure Review 269 - 6 mo. ---- Before work is i 10% complete 500738 Work Observation After work is Before work is Before work is i 10% complete 20% complete 30% complete 50073C. Work Observation After work Before work Before work is complete j has started 20% complete 50074B Work Observation After work is Before work is Before work is 50% complete 60% complete 80% complete 50075B Record Review After work is ---- Before work is 20% complete ,40% complete _ AIII-5 Issue Date: 03/26/86 R
~ . .
LIG'HTSkkERREACTORINSPECTION 2512, APPENDIX III PROGRAM - CONSTRUCTION PHASE R IP PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE 50076B Record,, Review After work is Before work is Work complete 50% complete 70% complete + 1 mo. . 50090B Pipe Supports ----
~ Before work is Work complete 20% co'mplete + 1 mo.
50090C Pipe Supports After work Before work is Before work is has started 20% complete complete
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50095B Fuel Storage Racks ---- Before work is Work complete 50% complete + 1 mo. Electrical Components and Cable 510518 Procedure Review 284 - 6 mo. ---- Before work is 10% complete 51053B Work Observation After work is Before work is Before work is 10% complete 30% complete 40% complete 51053C Work Observation After work Before work is Before work is ("' ,) has started - 20% complete complete ( _ 51054B Work Observation After work is Before work is Before work is 50% complete 60% complete 90% complete 51055B Record Review After work is ---- Before work is 20% complete 50% complete 51056B Record Review After work is Before work is Work c'omplete f 50% complete 70% complete + 1 mo. 510618 Procedure Review 284 - 6 mo. ---- Before work is l 10% complete 510638 Work Observation After work is ---- Before work is 20% complete 30% complete 51063C Work Observation After work Before work is Before work is has started 20% complete complete 51064B Work Observation After work is Before work is Before work is 50% complete 60% complete 90% complete 51065B Record Review After work is ---- Before work is 20% complete 50% complete l Issue Date: 03/26/86 AIII-6 R i
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l LfGHT WATER REACTOR INSPECTION PROGRAM - 20NSTRUCTION PHASE APPENDIX III, 2512 R IP PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE 51066B Reco'fdReview After work is Before work is 285 + 1 mo. 50% complete, 70% complete Instrumentation 52051B Procedure Review 294 - 6 mo. ---- Before work is 10% complete 52053B Work Observation After work is ---- Before work is
. 10% complete 30% complete 52054B Work Observation After work is Before work is Before work is 50% complete 70% complete 80% complete 520558 Record Review After work is ----
Before work is 20% complete 40% complete 52056B Record Review After work is Before work is 295 + 1 mo. 50% complete 80% complete 52061B Procedure Review 294 - 6 mo. ---- Before work is 10% complete After work is 52063B Work Observation ---- Before work is 10% complete 30% complete 52063C Work Observation After work Before work is Before work is i has started 20% complete complete 52064B Work Observation After work is Before work is Before work is 50% complete 60% complete 90% complete
- 52065B Record Review After work is ----
Before work is i 20% complete 50% complete 52066B Record Review After work is Before work is 295 + 1 mo. l 50% complete 70% complete 52153C Work Observation After work Before work is Before work is I has started complete 20% complete Containment Penetrations 530518 Procedure Review 239 ---- Before work is 10% Complete k 53053B Work Observation Af ter work is Before work is (Before work is l 20% complete 40% complete 60% complete
-AIII9 ---Issue Date: -03/26/86 R
- LIGHT WATER REACTOR INSPECTION 2512, APPENDIX III PROGRAM - CONSTRUCTION PHASE R IP PROCEDURE INSPECTION SCHEDULE j NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE l
/
l a 53055B Record Review After work is Before work is Before work is 30% complete 50% complete 80% complete Containment Welding 55051B Procedure Review 220 --- Before work is 10% complete 550538 Work Observation After work is Before work is Before work is
. 20% complete 40% complete 70% complete 55053C Work Observation After work Before work is Before work is l has started 20% complete complete l~
l 55055B Record Review After work is Before work is 240 + 1 mo. 1 30% complete 50% complete . Structures Welding l 55061B Procedure Review 220 ---- Before work is 10% complete 55063B Work Observation After work is Before work is Before work is 10% complete 20% complete 40% complete 55063C Work Observation After work Before work is Before work is has started 20% complete complete 55064B Work Observation After work is Before work is Before work is 50% complete 60% complete 80% complete 55065B Record Review After work is ---- Before work is 20% complete 50% complete 550668 Record Review After work is Before work is 250 + 1 mo. 50% complete 80% complete Reactor Coolant Pressure Boundary Pipe Welding 55071B Procedure Review 279 - 6 mo. ---- Before work is 10% complete 55073B Work Observation After work is Before work is Before work is 10% complete 25% complete 30% complete 55073C Work Observation After work Before work is Before work is has started 20% complete complete Issue Date: 03/26/86 AIII-8 R
J LIGHT WATER REACTOR INSPECTION PROGRAM - CONSTRUCTION PHASE . APPENDIX III, 2512 R ( IP PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE 550748 Work Observation After work is Before work is Before work is i 40% complet,e 70% complete 90% complete 55075B Record Review After work is ---- Before work is ' 20% complete 40% complete 55076B Record Review After work is Before work is 280 + 1 mo. 50% complete 80% complete ,
. Safety-Related Pipe Welding 55081B Procedure Review 279 - 6 mo. ----
Before work is 10% complete 55083B Work Observation After work is Before work is Before work is 20% complete 40% complete 60% complete 55083C Work Observation After work .Before work is Before work is has started 20% complete complete 550858 Record Review After work is Before work is Before work is 30% complete 5.0% complete 80% complete Structures and Supports Welding 55151B Procedure Review First Insp. * :.20 s 239 Before work is 10% complete Second Insp. After work is ---- Before work is 10% complete 30% complete Third Insp. After work is ---- Before work is , 50% complete 70% complete l I 55152B Material Control First Insp. s 220 s 239 Before work is
, 10% complete Second Insp. After work is ----
Before work is 10% complete 30% complete Third Insp. After work is ---- Befre work is g 50% complete 70% complete l _ _ _ _ _ _ _ _ _ _ - - - _ _ _ - - - - _ _ - - _ - - /ARRR-G 2- M* MMM
- I
'l LIGHT-WATER REACTOR INSPECTION 2512, APPENDIX III PROGRAM - CONSTRUCTION PHASE R IP PROCEDURE INSPECTION SCHEDULE l NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE !
l Fourth Insp. After work is --- Before work is i 80% complete complete j 55153B Containment-Work Observation 1 First Insp. After work is ---- Before work is 10% complete 30% complete Second Insp. ' fter work is ---- Before work is 50% complete 70%' complete Third Insp. After work is ---- Before work is 80% complete complete 55154B Outside Cont. - Work Observation First Insp. After work is ---- Before work is 30% complate ^ 10% complete ("~ :, Second Insp. After work is ---- Before work is 50% complete 70% complete Third Insp. After work is ---- Before work is 80% complete complete 55155B Struct. & Supports Visual Exam. . First Insp. After work is ---- Before work is 10% complete 30% complete Second Insp. After work is ---- Before work is 50% complete 70% complete Third Insp. After work is ---- Before work is , 80% complete complete l Issue Date: 03/26/86 AI]I-10 R
, ~ ..
LIGHT WATER REACTOR INSPECTION PROGRAM - CONSTRUCTION PHASE APPENDIk III, 2512 R __ . ) IP PkOCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE 55156B Struc.' & Supports Heat Treatment First Insp. After work is ---- Before work is 10% complete 30% complete Second Insp. After work is ---- Before work is-50%' complete complete-55157B Struct. & Supports Welder Qualif. First Insp. s 220
- 239 Before Work is 10% Complete Second Insp. After work is ----
Before work is . 10% complete 30% complete Third Insp. After work is --- Before work is , 50% complete 70% complete Fourth Insp. After work is ---- Before work is 80% complete complete 55158B Struct. & Supports Special Applic. First Insp. After work is ---- Before work is-10% complete 30% complete Second Insp. After work is ---- Before work is 50% complete complete Reactor Coolant Loop Welding 55171B Procedure Review First Insp.
- 279 ----
Before work is 10% complete Second Insp. After work is ---- Before work is 10% complete 30% complete Third Insp. After work is ---- Before work is 50% complete 70% complete AIII-11 Issue Date: 03/26/86 R
}
l . ; 1
- 1 LIGHT WATER REACTOR INSPECTION l 2512, APPENDIX III PROGRAM - CONSTRUCTION PHASE R l l
y i IP PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE l l 551728 Material Control First Insp.
- 279 ----
Before work is ' 10% complete Second Insp. After work is ---- Before work is 10% complete 30% complete Third Insp. After work is ---- Before work is l 50% complete 70% complete ' Fourth Insp. After work is ---- Before work is 80% complete complete 55173B Work Observation l 1 First Insp. After work is ---- Before work is ' 10% complete 30% complete Second Insp. After work'is ---- Before work is 50% complete 70% complete ' Third Insp. l After work is ---- Before work is 80% complete complete 55175B Visual Exam. i First Insp. After work is ---- Before work is 10% complete 30% complete Second Insp. After work is ---- Before work is 50% complete 70% complete Third Insp. After work is ---- Before work is 80% complete complete 55176B Weld Heat Treat First Insp. After work is ---- Before work is y ! 10% complete 30% complete i Second Insp. After work is ---- Before work is a 50% complete complete { 1 Issue Date: 03/26/86 AIII-12 R
LIGHT WATER REACTOR INSPECTION
. PROGRAM - CONSTRUCTION PHASE APPENDIX III, 2512 R
( , IP PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE 551778 Weldhr Qualif. First Insp. ~ 279 - ---- Before work is 10% complete Second Insp. After work is ---- Before work is 10% complete 30% complete Third Insp. After work is ---- Before work is 50% complete 70% complete Fourth Insp. After work is ---- Before work is 80% complete complete 55178B Special Applic. First Insp. After work is ---- Before work is 10% complete 30% complete
. Second Insp. After work is ----
Before work is 50% complete complete Other Safety-Related Pipe Welding 55181B Procedure Review First Insp.
- 279 ----
Before work-is . 10% coglete Second Insp. After work is ---- Before work is 10% complete 30% complete Third Insp. After work is ---- Defore work is 50% complete 70% complete 551828 Material Control First Insp. s 279 ---- Before work is ' 10% complete Second Insp. After work is ---- ' Before work is 10% complete 30% complete Third Insp. After work is ---- Before work is 50% complete 70% complete f . Fourth Insp. . After work is ----
.'Before work is 80% complete complete noo,_n a- an aesw oaa a
. 1 2512, APPENDIX III 3 LIGHTWATERR$ACTORINSPECTION i PROGRAM - CONSTRUCTION PHASE R l '\ \
___ _ j IP . PROCEDURE INSPECTION SCHEDULE NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE j i 551838 Work Observation First Insp. After work.is ---- Before work is 10% complete 30% complete Second Insp. After work is ---- Before work is 50% complete 70% complete Third Insp. After work is ---- Before work is 80% complete complete r 551858 . Visual Exam. First Insp. After work is ---- Before work is 10% complete 30% complete Second Insp. After work is ---- Before work is 50% complete 70% complete Third Insp. After work is ---- Before work is 80% complete complete 1 551868 Weld Heat Treat ' First Insp. After work is ---- Before work is i 10% complete - 30% complete l l Second Insp. After work.is ---- Before work is ' 50% complete complete 551878 Welder Qualif. 7 First Insp.
- 279 ----
Before work is 10% complete Second Insp. After work is ---- Before work is 10% complete 30% complete l l Third Insp. After work is ---- Before work is ! 50% complete 70% complete Fourth Insp. After work is ---- Before work is 80% complete complete Issue Date: 03/26/86 _AIII-14 R
~
LIGHT WATER' REACTOR INSPECTION PROGRAM - CONSTRUCTION PHASE APPENDIX III, 2512 R ( IP PROCEDURE INSPECTION SCHEDULE i NUMBER SHORT TITLE MAY START MUST START MUST COMPLETE 55188B Specihl$pplic. First Insp. After work is ---- Before work is 10% complete . 30% complete 3 l Second Insp. After work is ---- Before work is l 50% complete complete q i Nondestructive Examination l
' 571008 Site Erected RV ----
Before work is 270 + 2 mo. NDE 30% complete Extended Construction Delay 92051B Procedure Review (As required) 92053B Work Observation (As required) 92055B Record Review (As required) Event Followup 93700C Plant Incidents (As required) f Meetings 94600C Local Officials (As required) 4 ( . 1 0999m9$ 9 /3 c:e n n @nO A0 bb hb b
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t UNITED STATES NUCLEAR REGULATORY COMMISSION ,,,b 5
! OFFICE OF INSPECTION AND ENFORCEMENT L i Washington, D.C. 20555 gy+,..*,/
INSPECTION AND ENFORCEMENT MANUAL l OASIP CHAPTER 0610 INSPECTION REPORTS 0610-01 PURPOSE This chapter' establishes the procedures for the preparation and release of inspection reports, describes the standard format and content of inspec-tion reports, and establishes procedures for -the control and documentation of communications of inspection-related information given to non-NRC persons before the distribution of final inspection reports, while, at the same time, allows inspectors and regional management to promptly dissemi-nate information that could affect safe operations of licensed facilities. 0610-02 OBJECTIVES i The objectives of this manual chapter are to establish procedures to ensure that inspection findings accurately represent th? facts collected by, and
^
the conclusions drawn by, the NRC staff without improper influences by li-censees or their agents on the content and/or conclusions of NRC reports of inspections and to provide formats and procedures for preparing inspection reports so that they will: 02.01 Provide a basis for enforcement action and convey the results of the inspection to the licensee or vendor. 02.02 P ovide information to NRC Regional and Headquarters manage-ment on the implementation of the inspection program and on the identification of significant health and safety findings. 02.03 Provide information to the general public, 02.04 Provide a brief synopsis of activities and details of signi-ficant health and safety findings made by the inspector. 0610-03 DEFINITIONS 03.01 Deviation. Action or inaction by a licensee which (1) does not conform to provisions of an applicable Regulatory Guide, indus-try code, standard, or the generally accepted practice in the incustry, or (2) fails to satisfy a formal commitment which has not been made a regulatory requirement. These are items which Issue Date: 01/27/84 I
0610-03.01 INSPECTION REPORTS .f are not in violation of a specific regulatory requirement. Additionally, for vendor inspections, this also includes noncon-formances which is a unique category of findings used by the vendor branch and relates only to nonlicensees. , 03.02 Draft Inspection Report. All nonfinal versions of the inspec- l tion report. A draf t inspection report is the preliminary draft of the document which will provide the account and conclusions of an official NRC inspection. It is to be considered a draft inspection report from its initial development, and throughout the period of supervisory and management review, until final publication and distribution in accordance with IE Manual Chapter 0611. 03.03 Inspection. The examination, investigation, review, or evalua-tion of any record or activity of a licensee or vendor to determine the safety significance of that record or activity and/or to assure compliance with any rule, order, regulation, or license condition pursuant to the Atomic Energy Act. An inspection is considered to be:
- a. One or more visits to the licensee's or vendor's site and/or corporate headquarters made to satisfy an estab-lished inspection requirement. Normally, only visits made within a 30-day period may be considered to be a single inspection. Return visits to complete the exit interview with management or to conduct an enforcement conference are ^
included in the same inspection report.
- b. A series of activities conducted by resident inspectors during a period of up to six weeks.
03.04 Inspection Report. The written record of an inspection. The inspection report includes the inspection results obtained during the site inspection as well as the results of in-office inspection activities ccnducted before and after the actual travel to the site. An inspection report will be considered completed or final once it has been signed by the appropriate level of management on " approved by" line of the report cover page. 03.05 Licensee. The holder of an NRC license or a construction per-mit. 03.06 Open Item. Matters that require further review and evaluation by the inspectors. Open items are used to document, track, and ensure adequate followup on matters of concern to the inspector. 03.07 Unresolved Items. An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item , a deviation, or a violation. 03.08 Vendor. Any non-licensee or organization inspected as part of 4 the Licensee Contractor and Vendor Inspection Program. Issue Date: 01/27/84 2
L. , I INSPECTION REPORTS 0610-03.09 4 03.09- . Violation. Action or inaction that violates a legally binding NRC requi rement. j 0610-04 RESPONSIBILITIES AND APPLICABILITY All -staff members who conduct inspections are required to prepare inspec-tion reports to document the.results of' inspections in.accordance with this manual chapter. l l 0610-05 DOCUMENTATION REQUIREMENTS
'05.01 All inspections must be documented in an inspection report ,
unless otherwise specified in the inspection program. 05.02 All inspection reports, except materials field notes, consist of R (1) a. cover page that identifies the licensee, date(s)of R inspection, and other sumary details (see Section 05.03, R l- below), and (2) subsequent pages which provide inspection R-I ' details and the necessary infomation to support and substanti- R ate significant safety findings '(see Section 05.04, below). R 05.03 Cover Page. Provides basic identifying information about the l licensee inspected and a brief sumary of the scope and findings l of the inspection. An example of a cover page for an inspection report is provided in Exhibit 1. Most of the infonnation re-quired for the cover page is obvious from the captions (some explanatory notes are provided in Exhibit 1). It may be the only record of the inspection and should be typewritten but may be printed . legibly in an ink that can be photocopied (see Section 05.03e, below). The Inspection Summary on the cover page provides a brief, narrative description of the scope and results of the inspec-tion. It contains the dates of inspectiM1, the report number, a description of the subjects or areas examined, and the results of the inspection. Since the summaries may be in a computer file for later retrieval, it is important that each sumary be an accurate description of the inspection. Avoid putting the inspector's advice, opinions or recommendations in the sumary or the underlying report. Keep the summary as 'brief as possible. It should be a factual representation of what was inspected and the findings. Use abbreviated statements where possible. Since the cover page of all-inspection reports is intended for release to the public, no classified information, safeguards information, or other infor-mation exempt from disclosure shall be included. See Section 06 for procedures for handling exempt information. Additional details on some of the infomation to be included in the summary are provided below: 3 Issue Date: 01/09/85
0610-05.03a 1NSPECTION REPORTS
- a. . Description of subjects or areas examined.
The inspector
.should list in brief narrative form the principal areas and F functions inspected. and any inspertion ~ procedures covered.
, b.. Inspection ~ effort. Include a statement to show the total amount of onsite inspection time (inspector hours) and the number of inspectors involved. If appropriate, identify the number of offshift inspection hours.
,t
- c. Results. . When violations and/or deviations are found,
' include a sentence that describes each item very briefly and in general tems. When no such items are disclosed, it is sufficient to report that no violations or deviations were disclosed.
- d. Exempt information. If the report contains information that is exempt from disclosure to the public, the summary shall exclude all such exe.npt information. All exempt infonnation is to be contained separately in an enclosure to' the inspection report, if possible. The distribution of inspection reports containing safeguards information will be controlled in accordance with NRC Manual Chapter 2101.
Before placing these reports in the PDR or making general distribution, delete all safeguards information. The sumary shall contain no safeguards information. The " description of subjects examined should nomally present no particular problem in drafting the -description to exclude exempt information, but care should be exercised. Viola-( I tions and deviations must be described in general terms to preclude disclosure of exempt information. .
- e. Materials inspections. A complete fomal report must be R prepared for any materials inspection that involves (1) R ,
an inspection of a Priority 1 licensee except a radiogra- R pher, (2) a special inspection conducted in response to R p an allegation or licensee incident or event, or (3) an R inspection that may result in elegated enforcement. R Other material inspections may be documented with a femal R cover page plus inspection notes or a completed NRC Form R 591 plus inspection notes. Inspection notes should be leg- R ible and contain sufficient detail to define the scope of R inspectio'n, the status of compliance of topics examined R during the inspection, the status of followup item invol- R ving prior enforcement or reported licensee events, and R sufficient information to support any findings of noncom- R pliance. R
- f. Vendor inspections. For vendor inspections, the summary should contain brief statements that describe the systems or processes examined. Deviations from comitments are de-scribed similarly to violations at licensed facilities.
Additionally, for vendor inspection reports, the example shown in Exhibit 2 shall be used. he Date: 01/09/95 4
(- l' INSPECTION REPORTS 0610-05.04 [ 1 05.04 Inspection Details. This part.of the inspection report includes a brief description of the inspection activities carried out during the inspection and a detailed discussion of inspection findings to substantiate any identified health and safety con-cerns, violations, or deviations. The report must be ' factual; findings must be clearly stated and must, include a discussion of how' the findings and conclusions were determined but should not discuss conclusions on enforcement issues. - The emphasis should be on significant findings that may have an impact on sefety or safeguards and/or represent noncompliance [ ' with NRC regulations or license conditions. The report is not i intended to be a lengthy discourse of activities carried out so ; as to justify the time spent or to demonstrate one's knowledge ! of a particular technical area. If no violations or deviations ! I were identified, .then succinctly state the activities carried out during the inspection and state the con::l usions drawn- ; relative to the 1.icensee's, contractor's, or vendor's perfor- j mance. l l The inspection details will include sections, as appropriate, for each of the topics identified in Section 05.04a-d, below. Examples of inspection reports (cover page and inspection details) are provided in Exhibits 3-5. Guidance on the extent of detail expected for each section of the inspection details is l- provided below: a, Persons Contacted. List the licensee or vendor representa- l tives or any other individuals who furnished information for the inspection. Limit the list to those who contri-buted significant information during the inspection. . Include the name and title of each individual. I Indicate by an asterisk or other suitable note those , individuals who participated in the exit interview. The I inspector may summarize the number and type of people interviewed but who - did not provide substantive or rele-vant information. Also include other NRC personnel in attendance such as the Resident Inspector for region-based inspection reports.
- b. Action on Previous Inspection Findings. Describe any sig- '
nificant licensee or vendor action on previously identi-fied inspection- findings. Trovide a description of the findings and a statement as to whether each item ir.cludeo remains open or is closed. Inspection reports are not used to track all matters Con-sidered open; therefore, it is not necessary to list all 1 outstanding items and all violations that the Regional Office still considers open. Rather, this part of the ! report contains information related only to those items examined during the inspection. 5 Issue Date: 01/27/84
e
=0610-05.04c- XNSpECTION REPORTS
- c. Functional or Program Areas Inspected. This is the _ main body of the report which briefly. describes the functional or program. areas inspected and provides the . necessary '
description ' of inspection findings. It is divided into paragraphs titled with the subjects or titles of the
. inspection procedures under which the inspection was performed. If independent inspection effort was expended-on the inspection, a separate paragraph should be.provided to discuss the area inspected.
For each program or functional area examined, the~ inspector should report: (1) what was inspected, (2) time period covered by .the examination or review, (3) a brief descrip-tion. of specific inspection activities carried out during _._. the inspection, and (4) the significant. findings and conclusions ' of the inspector relative to the .1icensee's performance. . With respect to conclusions, for each subject area covered, the inspector should include a statement similar to one of the following: No violations or deviations were identified in the review of this program area. This program area requires further review and evalua-tion and is considered to be an open or unresolved item. (A reason should be stated.) - The following violations (and/or deviations) were identified during the inspection of this program area. The above statements are illustrative and are not intended to be used exactly as written. In addition, other state-ments may be appropriate in certain situations. For violations and deviations, the extent of reporting is related to the inspection findings as follows:
- 1. Violation. It is necessary to provide full substan-tiating information for violations. Safeguards viola-tions must also be fully substantiated; however, precautions must be taken to prevent disclosure of exempt information (see Section 06, below). The information required is a clear statement of the requirement - appropriately referenced, paraphrased, or quoted - and a detailed description of the manner in which the licensee or vendor did not meet the requirement. This description should be in suffi-cient detail to permit a knowledgeable reader to come l to the same conclusion. The description of.the viola- l tion shall include, as appropriate: 1 the requirement how requirement was violated
.e .' ate: 01/27/84 6
_ _ _ _ . _ . _ - _ _ _ _ _ _ _ Q
.' i
-TN5PECTION REPORTS , 0610-05.04c1 when.and for how long did violation exist by whnm was it violated who discovered and/or' reported 'the ,v'olation are there multiple examples of the ' violation what caused the violation is there evidence of careless disregard for re-quirements or management involvement how many opportunities did licensee have to' dis-
. cover the violation !
what corrective action and/or compensatory mea-sures were taken I'f the requirement is conditional, the supporting information should describe the way in which the conditions are satisfied to make it clear when the requirement applies and when the violation occurred. Reference to severity level will not be made in'the inspection report.
- 2. Deviations. The required substantiating information is similar to that for a violation except that, instead of describing a requirement, the inspector must describe the provisions of the applicable guide, coce, or standard, or the generally accepted practice in the industry or the licensee's failure to meet a legally non-binding commitment.
1 This is followed by the detailed description of the a action- or lack of action constituting the deviation. j In addition, the inspector snould describe the safety ; or safeguards significance of the deviation.
]
- c. Exit Interview. List the names and positions or titles of persons present at the exit interview (s) with licensee or vendor management. If the list of persons contacted identified the person (s) participating in the exit inter-view (s) (see Section 05.04a, above), a referencing note is adequate and the list need not be repeated.
This section should briefly describe each subject discussec at the exit interview, but should not describe in detail i the specific items discussec elsewhere ~In the report. ] To tne extent that management expresses a position (agrees, j cisagrees) on the inspection findings, this position should be factually reported. It is not necessary, however, to recort the licensee's or vendor's plannec corrective action 1 7 Issue Date: 31/27/N i
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m .: '. 0610-05.04d INSPECTf0N REPORTS for noncompliance and deviations .'since the licensee or . vendor will !be given . an opportunitylto provide the cinfor- ' mation in writing. F' Any Contact af ter the exit interview regarding changes in either the licensee's 67 inspector's positio( on anc item s should also be reportern , q w t
- e. Enforcement Conference /Ranagement Meeting. If anienforce-ment conference or management meeting is held before the inspection report is' issued, then a . brief summary of 'i t should be included in the report.
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u 0610-06 INFORMATION EXEMPT FROM DISCLOSURE , n . 06.01 Ge ne ra l '. Except for those attachments to inspUtion reporis ~ tIiat.contain exempt information, all inspection report's will be ' routinely disclosed to the puolic in accordance with IE Manual , Chapter 0611. Care must be exercised to prevent the disclosure of exempt . .information. In some cases, -it may be necessary to include exempt information in inspection reports sent to . the licensee and NRC addressees and, at the same time, withhold disclosure'to the public. To simplify the administrative details of identifying and withholding exempt information in inspection reports, all exempt information' must be separately ?iuentifed and included in an enclosure (s) to the report, or in the case of safeguards'information, deleted. The identification of' types of ~ exempt -information .and the basis .for exempting information,, from l public disclosure are discussed in Section 06.02, below. l l 06.02 Exemot Information. The following types of information shall l not De included in inspection reports except as noted in the y e discussion below: A , e, Personal preferences of the inspector as opposed to presen-
- tation of technical positions on items and areas inspectea T (ref. 5 U.S.C. 552(b)(5)). ,,l Note: The inspector's own opinions and advice, as well as
" recommendations of individuals interviewed during the inspectien, should not be included. Inspectors may make their personal concerns known through an evaluatidra meso-randum to NRC Regional and Headquarters management. This memorandum may be subject to release under the Freec z .nf Information Act (FOIA) but in most cases could be with6eha pursuant to exemption 5.
- b. Icentity of persons providing information tc the NRC unde,r an express pledge of confidentiality, or under such circum-stances that confidentiality can De inferred, and any information that would reveal the ice.ntity of such persohs (ref. 5 U.S.C. 552(b)(6))..
Issue Date: 01/27/S4 B 1
. & r $ ~) ,, , 4@
m, TNSPECTTONREPORT$ '0610-06.02b Exception: If it'. is necessary to report confidential information to' support the~ inspection findings. and the information would reveal' tne identity of the source, then 3
.. s the information .should be included in an enclosure to the
~ report and in a manner that it will be disclosed only to N" NRC addressees who have expressed a :need - to know Such g information should be clearly identified and pages shall be a;A '( V .ma'rked that the information is not for public disclosure,
+
- c. ' Names of individuals who have received exposure to radia-
%- tion, or other ' identifying information and other personal and medical information, the disclosure of which would con-stitute a clearly unwarranted invasion of personal privacy (ref. 5 U.S.C. 552(b)(6)).
d [ Excerpts'from.NRC'or other government agency documents that 7 have not been disclosed to the public (ref. 5 U.S.C. 552 (b)(5)). '
%. o . ,
ec Information exempt from mandatory public . disclosure pur-
. suant.to.5 U.S.C. 552(b)(4) - trade secrets, commercial or financial'information - and safeguards information pursuant to section 147 'of the Atomic Energy Act. Exempt informa-tion in accordance with this Manual Chapter also includes:
- 1. information exettpt from mandatory disclosure under 10 CFR Part 2, " Rules of Practice for Domestic Licensing Proceedings," Sections 2.740 and under 10 CFR Part 9, "Public, Records," Section 9.5, " Exemptions."
- 2. information received by the Commission as set forth in 10 CFR Part 21 (21.2), submitted to this agency pur-
, suant to a claim for withholding from public disclo- i' sure, relating that a facility or activity or basic component supplied to a facility or activity. . (a) contains substantial safety hazards, or F. ;
(b) contains defects which could create a substantial I safety hazard.
- 3. information submitted in confidence to tne NRC by a foreign source and which is determined by NRC to be exempt from public disclosure pursuant to 10 CFR 2.790(d)(2).
Exception: This type of information is exempt from puDlic oisclosure. Inspectors :hould cttcmpt to prepare inspec-tion reports without including information exempt from cublic disclosure. In situations where the information must ce included to support and substantiate inspection findings, the information should be identified ano incluoed in an enclosure to the report. The inspection report and 9 Issue Date: 01/27/84
0610-06.02e INSPECTION REPORTS
' appropriate pages shall be marked and protected in accord-
- ance with NRC Manual Chapter 2101, Appendix XVI require-
' ments.for that type of information. < 0610-07 TIMELINESS OF REPORT PREPARATION Inspection reports should be dispatched within. 20 calend days after completion of the inspection. For an inspection that cons ts of a series of visits to a licensee site or office, the inspection report is to De dispatched within 20 calendar days after completion of t last site visit. For a resident inspector, the inspection report should e dispatched within 20 calendar days after the last day covered by t' e inspection report. 0610-08 SAFETY A'ND SECURITY ISSUE COMMUNICATE 5 08.01 Safety and security concerns m t be addressed by prompt, positive actions. Accordingly, afety or security information must be promptly and clearly i ntified to responsible licensee management to obtain prompt 1'censee evaluation and, if appro- 3 priate, safety-related corre ive actions. Such clear communi- l Cdtions are necessary to ha intaining required levels .of safety and security at licensed acilities. When such communications are made as a result of ncerns that arise during the course of preparation of an ins ection report, a copy of any written communication should e included in the report. The inspector should keep ' regional management informed of verbal and written communications with the licensee regarding safety and security. 1 NOTE: Significa violations identified by a resident inspector during the earl part of the inspection period should be identi-fied by the p mpt issuance of a Notice of Violation (NOV) with a cover lett r indicating that detals will be provided in the inspection eport to be issued later The inspection report will refer ce the NOV transmitted earlier. 08.02 As dire ed and where approved by regional management, inspec-tors m y, in preparation for exit interviews, management meet- ; i ings, or enforcement conferences, provide to the licensee a list ..g uf apparently significant issues developed in tne course of n inspection, in order to facilitate communication of I in ection findings that require corrective action. However, n tes, draft reports, draft evaluations, draft notices of viola-ions or noncompliance, or other material containing preliminary inspection conclusions, findings, and recommendations are not to be provided to the licensee, except as recuired by safety or security concerns, as noted above. 08.0 Briefing materials prepared by the staff for use in meetings with licensees occasioned by inspection activities should be reviewed by Regional management before they are distributed at a meeting, and should be appence.1 to the inspection report. - Iss.e Cate: 01/27/64 10
1
)
~
, 0610-06.02e I INSPECTION REPORTS {
o ( P appropriate pages shall be marked and protected in accord- k I ance with NRC Manual Chapter 2101, Appendix XVI requi re-ments for that type of information. 0610-07 TIMELINESS OF REPORT PREPARATION (
- Inspection reports should be dispatched within 20 calendar days after com-I pletion of the -inspection (major team inspection reports should be dis- P.
patched within 30 calendar days). For an inspection that consists of a R series. of vicits to a licensee site or office, the inspection report is to be dispatched within 20 calendar days after completion of the last site visit. For a resident inspector, the inspection report should be dis-patched within 20 calendar days after the last day covered by the inspec-tion report. 0610-08 SAFETY AND SECURITY ISSUE COMMUNICATIONS 08.01 Safety and security concerns must be addressed by prompt, positive actions. Accordingly, safety or security infonnation , must be promptly and claarly identified to responsible licensee management to obtain prompt licensee evaluation and, if appro- - priate, safety-related corrective actions. Such clear communi-cations are necessary to maintaining required levels of safety and security at licensed facilities. When such conrnunications are made as a result of concerns that arise during the course of preparation of an inspection report, a copy of any written ! communication should be included in the report. The inspector should keep regional management informed of verbal and written communications with the licensee regarding safety ano security. NOTE: Significant violations identified by a resident inspector ! during the early part of the inspection period should be identi-fied by the prompt issuance of a Notice of Violation (NOV) with a cover letter indicating that detals will be provided in the inspection report to be issued later. The inspection report will reference the NOV transmitted earlier. 08.02 As directed and where approved by regional management, inspec-tors may, in preparation for exit interviews, management meet-ings, or enforcement conferences, provide to the licensee a , listing of apparently significant issues developed in the course of an inspection,.in order to facilitate communication of p inspection findings that require corrective action. However. notes, draft reports, draft evaluations, draft notices of viola-tions or noncompliance, or other material containing preliminary inspection conclusions, findings, and recommendations are not to be provided to the licensee, except as required by safety or security concerns, as noted above. l 08.03 Briefing materials prepared by the staff for use in meetings with licensees occa: aned by inspection activities should be 1 reviewec by Regional management before they are distributed at a meetinc, and shoulo be appended to the inspect 1on report. f !
.ssse Date: 01/09/85 10 I
l {
f 1225550:2515 1 IMU 05 * *- C Ih siv .. U :. L t551 0 SF005 L INSP
' uti t Y .; i v i 513 *, D I R E C T JF E 5-2.
.".- I .3T'.; , DC 20555 i ,i
a _INSPEC?f0N REPORTS 0610-09 0610-09 RELEASE OF INSPECTION REPORTS 09.01 The primary emphasis. with regard to control over the release of draft inspection reports is to ensure that official NRC docu-ments and their inspection conclusions are published without any taint, either real or perceived, of improper influence by those we regulate. At the same time, these procedures are not" intended to inhibit the NRC field staff from freely commenting > on safety issues at . the preliminary stages of fact collection and evaluation. However, these procedures and underlying policy ~' also serve to address the basic prcblem that licensees shall not be afforded opportunities to modify NRC documents to their advantage outside the public arena. 09.02 Uncer to circumstances shall draft inspection reports or por-tions of such reports be given to licensees, their agents, or members of the general public without the express permission of I the Executive Director for Operations (EDO). In the event any draft inspection report is inadvertently or otherwise released contrary to this policy, the EDu should be promptly advised in writing. The EDO will take or recommend action as appropriate. 09.03 Regional management and inspectors are not prohibited from l discussing the findings with licensee management or their agents for the purpose of effGCting corrective action relating to safety or security matters before the time the inspection report is in final form as discussed in Section 08. Inspectors fre-quently need to advise a licensee of inspection findings not yet i in final form in order to initiate prompt action. This kind of communication, for instance, exit interviews, management j meetings, and enforcement conferences, is entirely reasonable ' when done verbally or in writing divorced from the report itself. However, a copy of any such written communication should ce included in the report. Verbal communication re-garding safety and security matters should be documented in the report. A succinct sunmary of what was said will suffice. I It is important that inspectors communicate safety information quickly; however, when time permits, written inspection findings j associated with draft inspection reports should be discussed 4 with Regional management before such information is released, 09.04 This manual chapter does not apply to SALP reports which are covered under a different set of procedures. , i 09.05 Proprietary review and subsequent release of completed inspec-tion reports shall be in accordance with IE Manual Chapter 0611. 11 Issue Date: 01/27/84 _ _ _ _ _ ________-_____-_____O
-{
0610-06.10 XNSPECTXON REPORTS 0610-10 . RELEASE OF INPUT FOR INVESTIGATION REPORTS 10.01. Occasionally, . inspectors accompany investigators on investiga- # tions. When part of such an investigation team, the inspector shall not release either the inspectors' input for'the investi-gation' report and/or the investigation report itself. 10.02' Office of Investigations (01) reports of' investigation,- while in preparation. or review, will. not be. circulated outside NRC. l without specific approval of the Chairman (OI Policy- Statement 23). 10,03 With the exception of significant . safety issues, information regarding an ongoing OI investigation will not be disclosed by any NRC employee -outside NRC without the specific approval of the Di re c to r', 01, or his designee (OI Policy. Statement 18). 10.04 Investigators and others assigned to an 01 investigation ' or inquiry will normally not discuss the substance of ongoing OI inquiries and investigations with licensees or other non-NRC personnel in entrance or exit interviews, except safety items requiring immediate' corrective action (01 Policy Statement 19). END O l 1 Issae Date: 01/27/84 12 l l
- l. ________________________________________a
l. l INSPECTXON' REPORTS EXHIBIT 1, 0610 l
, SAMPLE INSPECTION REPORT COVER PAGE i
U.S. NUCLEAR REGULATORY COMMISSION REGION Re,nart No.1 Docket No.2 License No.2 Safeguards Group 2 License No.3 Priority 3 Category 3 Licensee: (or Company) Name Adaress Facility Name: Inspection at: (Location, if different from licensee address) Inspection conducted: (Dates, do not include travel time) Inspectors: Signature Date Signed Signature Date Signed i Approvea by: 4 Signature Title Date Signed Summary: (Summarize the scope and findings of inspection) i l I 1 IFor Materials licenses, aceket no., year - sequential number of report in that year; for all others, Docket no./ year - sequential number of report { in that year. 1 0For other than Part 30 licenses. ! 3For Materials licenses. ' 4Maragement level as designated by Regional Administrator. l El-1 Issue Date: 01/27/94 l _ _ _ _ _ - _ - - _ - _ _ _ - _ _a
INSPECTION REPORTS EXHIBIT 2, 0610 SAMPLE FIRST PAGE FOR VENDOR INSPECTION REPORTS ORGANIZATION: Company, Division C1,ty, State REPORT Docket / Year INSPECTION DATE OF LAST INSPECTION NO.: DATE(5): INSPECTION: ONSITE HOURS: CORRESPONDENCE ADDRESS: Corporate Name Division I ATTN: Name/ Title . Address City / State / Zip Code ORGANIZATION CONTACT: Name/ Title Telephone Number PRINCIPAL PRODUCT: Description of type of components, equipment, or services supplied. NUCLEAR INDUSTRY ACTIVITY: Brief statement of scope of activity including percentage of organization effort, if appli'- cable. ASSIGNED INSPECTOR:* __
.. Signature Date OTHER INSPECTOR (5):
- Signature Date APPROVED BY:
- Signature Date INSPECTION BASES AND SCOPE:
A. Bases: Pertain to the inspection criteria that are applicable to the activity being inspected, i.e., 10 CFR Part 21, Appendix B, and SAR , or Topical Report commitments. B. Scoce: Summarizes the specific QA program areas that were reviewed, and/or identifies plant systems, equipment, or speci fic components that were inspected. For reactive (identified problem) inspections, the scope summarized the problem that caused the inspection to be per-formed. PLANT SITE APPLICABILITY: Lists docket numbers of licensed facilities for which equipment. Services, or records were examined during the inspection. '
'Typec Name E2-1 Issue Date: 01/C7/S4
n------- - - - - j.
.y 0610^, EXHIBXT 2 INSPECTXON REPORTS SAMPLE SECOND PAGE FOR-VENDOR INSPECTION REPORTS o
ORGANIZATION: Company, Division City, State REPORT NO: INSPECTION RESULTS: Page.2 cf 2 A. VIOLATIONS:' Shown here'are any inspection results determined to be in violation of Federal regulations (such as 10 CFR Part 21) that are applicable.to the organization being inspected. i B. NONCONFORMANCES: Shown here are any inspection results determined to j be in nonconformance with applicable commitments to NRC requirements. In addition. to identifying the applicable NRC requirements, the speci-fic industry codes and standards, company QA manual sections, or oper-ating procedures which are used to implement these commitments may be referenced . C, OPEN ITEMS: Shown here'are inspection results about which more infor- ! mation is requibed in order to determine whether they are acceptable items or whether a violation of deviation may exist. Such items will ce resolved during subsequent inspections. D. STATUS OF PREVIOUS INSPECTION FINDINGS: This section is used to iden- ' tify the status of previously identified violations, deviations and/or open items until they are closed by appropriate action. For all such ; items, this section will indicate open/ closed classification, identify ' the inspection report that first produced the item, describe the nature.of the item, and if closed, include a brief statement concern-ing action that closed the item. If_this section is omitted, all previous inspection findings have been closed. E. OTHER FINDINGS OR COMMENTS: This section is used to provide signifi-cant information concerning the inspection areas identified under
" Inspection Scope." Included are such items as mitigating circum- !
stances concerning a violation or deviation, statements concerning the limitations or depth of inspection (sample size, type of review per-formed) and special circumstances or concerns identified for possible fcilowup. For reactive inspections, this section will be used to summarize the disposition or status of tne condition or event that caused the inspection to be performed. i
- ss_s Cate: 01/27/e4 E2-2
' l 2NSPECTXON REPORTS EXHXB?T 3, 0610 EXAMPLE.OC A DETAILED OPERATING PLANT INSPECTION REPORT i
, s ** *
- c
.-" UNITED STATES 5i ,jc, j[3 } t NUCLEAR REGULATORY COMMISSION REClONll n , Qw' ,f
, 101 MARIETTA ST., N W,. suits 3100
,e a _gr ATLANTA, oaoRGIA 30303 Report Nos, 50-330/82 45 and 50 331/82-45 Licensee: , Utility Electric and Power Company P, 0, Box 26789 Jamestown, VA 21234 Facility Name: North Mary Units 1 and 2 Docket Nos. 50-330 and 50-331 License Nos, NPF-X and NPF-Y Inspection at Nortti Mary site near eerkeley, Virginia Inspectors: M '0 //I Ib C. Browne v Cate 519eed 9%Mo 6 M. Smytne U sh7/rb Da te Signes Approved ey: [o f/ 7((d-I. RoDerts, Chief, Otvision of Date Signed Dreject anc Resident Programs-
SUMMARY
Inscection on April 5 - Acril 19,1982 Areas Inspectec
**t s routire inscection by the aes14ent inscectar involvec 261 insoector-nours on site in the areas of followup of previous inscection finoings,11censee event resorts, previously ident1fieo items, post tmolementation review of :LRE3 0737 ttems, ltcensee concitions for Unit 2, refueling act1vities, cutage items, soevetilance, maintenance activities, clant operations, offsite Review "ocntttee anc offsite Suppcrt Staff, During this inspection, Inspection Procedures 62M2, 61725, 71707, 92706, 93702, and 90712 were covered, cesu'ts C' tae t ,elve areas inspected, no violatiers or deviations were identified.
'do t e : pereas a statement regarding status of compliance thould be at the end of laCM se'. tion, none appears in this example until Section 11.
E3-1 Issue Cate: 01/27/34
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LO610, EXHIBIT 3 INSPECTION REPORTS-
'l
?
DETAILS
!. Eersons Contacted Licensee E.mployees
*W. W. Craig, Station Manager i A. E. Huf f, Assistant Station Manager j
*P. J. Himes," Superintendent - Technical Services L. J. Hawnins, Superintendent
- Ma intenance P. O. Barter,5uperintencent - Operations l- ,
6 G. %rchy, Superintendent - Aaministra tive Services r i A, J. McGeer, Coerations Cocrcinator R. Bell, instrumeet Supervisor D. A. Sanders, wealth Physics Supervisor !
. J. Scott, Engineering Supervisor
- r. Thomas. Engineering Supervisor E. D. firkpatrick, Engineering Superviser ,
- 3. Shoe *a ker. 'Mecna nical Ma intenance Supervisor - i L. O. Ta ylor Electrical suceevisor 8 M. Harmon, Sr. , Site OC. Ma nagee
' A, F. Foster s Sta f f AMsistant P. M. Moss. 00 Supervisor -
P. r., Minton, Clerk
. e Otner licensee employees contactec incluced technicians, operators, D' me:nanics, anc office personnel, j
*.*.ttencec one or more ex1t interviews !
- . Exit :nterview
*re inspection scoce anc fincings .ere summarices on Aort! 13. 19E2, witn i
- nose persons incicatec in paragraon 1 acove.
- Licensee aciton on Previous :nspection Fincings ;
1:se: .it'st'cr 130 *BO-29-02 Instrument stop valves on several 'eec.ater
'lo transal:ters -ere founc :o se isolateo. ine Dre-Start o. Onectoff Lis:
.as revises. Tae enecklis: 2-0#-;A rev 1 page a catec Septemoer 11, 1983
'tas signoff statas recuirec for all ESF anc Reactor Protection transmitter
<alve Itneups per instrument procecures. The inspector nac no furtner cuestions. ints item is :loseo.
4 Lnresolvec ltems Jnaesol sec items were not 1:entifico curing tnis inspeciton.
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i k l 15 sue Date: 01/27/34 E3-2 l,
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INSPECTION REPORTS EXHIBIT 3,'0610 s . 2
- 5. Plant Status Unit 1 During tnis inspection period tne unit operatec at or near capacity load except for t'e followieg. On April 7 at 1451 the unit was manually tripped fem 100% power. ine unit was tripsec Decause power was lost to tne 1G ous-(cue to supply breaker 15G1 tripping open on a mmentary undervoltage sp1ke, and creaker 15G1 failing to auto transfer) causing tne loss of circulating wa ter pumps. The unit was manually tripped anc tne vacs Dreakers were opened to prevent damage to tne LP turbine rupture cisks. The unit was automatically tripped at 2047. April 7 while returning the unit to service when reactor power exceecec lus witn tne generator output oreeters open causing a turDine trio / reactor trip. The unit automatically trippec
. april 15 at 0934 from 100t power. This trio was caused wnen tne reactor operator repositioned the f443 power range gain ac3ustment potentiometer.
The repositioning of the potentiometer nesea on results of a calorimetric,
- ausec a spike to be generatec ano caused a N43 n1gn posit *ve rate trip.
.444 cnannel was in tne trip concition, so 2/4 logic .es cocpleted for an automatic reactor trip. The unit was rampeo down on April le to repair a steam generator blowcown valve (1-80 2) leak and to reo41r 5B feeuwater
- eater. The unit aos automatically tripped fra approximately 5t power
, wnen tne instrumeat tecnnician as adjusting N15 (power range) trip setpoints for 85% anc cid not clear rti Rate flux (ii) trip on one enannel prior to entering another channel for testing. (See Note below.)
Unit 2
- During inis inspection perioc Unit 2 remainec snutcown wntle unce going t e first refueling outage. The unit went.from Hoce 6 to lloce 5 at 2000 on April 15. after tne nead was installed and refueling was completec.
- c. Followup of Previously Identified Items (Closec) 339/81-24-01. Inspection of loop isolatice valve stuas. All loop 1 solation valve stuos anc nuts were insoectec under tne following main-tenance reoorts, 2-4C-i40V-2590 (f42-81 !C260736), 2-RC f t0V-2591 (N2 l 10:507:7), 2 RC ft0V-2592 (N2-31-1C250738) 2 RC-;40V-2593 (12-51-1;260M9),
2.10-ft0V-2594, (12-61-10260740) 2-RC MOV-2596 (N2 dl-10260741). ine <1sual examination was concuctec per NDE VT Form 1, anc all were founc acceptaDie, , (Closed) 339/30-29-02 Core cooling monitor cactnet movement. ine core ! cooling monitor cacinet was moved to the left eno of the Unit 2 bencnocara per E&OCR 2727 and is oesignatec as 2 EI-CB 01A sect 1on 2-3. (Closec) 339/80-28-06 Pressurizer pressure prote: tion enannels out of calibration. Discussion by UEPC0 engineering altn tne vencor concerning poss1:le pressure set as nt;n as 35-40 pst were ciscusseo anc cecicec not I Note: inis amount of cetai! may not te necessary unless it is pertinent to the areas inspectes. E3-3 Issue Date: 01/27/84
4 0610, EXHIBIT 3 INSPECT 10N REPORTS
-3 pcssible. The venoor states tnat a pressure set of very small magnitude ,
; suen as 1/a pst at 2500 ps1 coes occur. Calibration recorcs for tne three j icentif tec pressure transmitters snowec tnat the incicatec pressure was 7.2. . I 2.2 anc 13.6 psi telow actual pressure wnen eneckec approximately four i montns af ter being placeo .into service. Since tne transmitters cr1f t is in j tne same cirection (low). crectoility to tne pressure set enaracteristtes of teese transmitters nas been snown. ,
- 7. Licensee Event Report (LER) Followup The following LER's 4re reviewed anc closec. The inspector verified that ;
reporting requirements nac been met, causes nac been icentified, corrective i actions appearec appropriate. generic applicability nac been constcerec. and ! tne LER foms were complete. maattionally, for tnose reports icentifico ey asterisk, a more cetailed review was performed to verify tnat the licensee ( nec reviewec :ne event, corrective action nac been taxen, no unreviewec safety cuestions were involvec, anc violations of regulations or Technical l Spectf1 cation conc 4:1ons nac been toentifiec. 233/S2 25 Incividual Roc 80 sition incication ceviatec from canx l position ey greater tnan 12 steos. ; J
'339/31 07 Dtlution of Boron Injection Tank celow tecnnical specificat1on limits.
( .l
'3:9'SI-21 Dilution of Boron Injection Tank below tecnnical spec 1ficatlors 11mits. (I LIR 339: 31-07. 81 21 cotn icentified croelems witn ene Boron Injection Tanx (B!il Deing samplec and the boren concentration below the Technical i icecification limit of 20.000 ppm. It was seterminec :nat check valve .
2 CH-155 in tne boric acic supply line to tne olencer was allowing plencer !
- ri-ary grace. water to backflow via tne recirc line to tne SIT anc c11uting t :entents.
s'uring the current refueling outage tnis enect valve ('2-CH-155) was :ut out are replacea asing maintenance proceoures 'NtP-C P1 anc !VtP-CW 4 uncer FR s'i2-82 C329C901. These LER's are closec,
- s. Tit: Action Plan Requirements tem !!.E.4.2:15 reoutres that containment purge isolation valves snall se uncer administrative controls to assure tnat they cannot De inadvertently openee.
The inspector verifiec that all valves were under administrative control. Issue Date: 01/27/84 E3-4 1
l
.e 1 INSPECTION REPORTS EXHIBI_T 3, 0610
\
a g 4-Item II.E.4.2.7 reovires snat containment pur;e and vent isolation valves must close on a nign radiation signal. The containment purge and vent isolation valves remain sealed closed as discussed above; tnerefore closure from radiation signals are not recuirec. Mowever ractation levels are routinely monitored during moces 1 tnrougn 4 anc alarm set points anc hign radiation trip of tne containment surge and vent valves are reinstated prior to entry into refueling mooe (6). 1
- 9. Information fleeting with Local Officials anc Inspection of tne Local Public
. Document . Room (LPOR) i
- a. On April 18, 1982 the Senice Resident inspector in accordance with 4 Regional Instruction and manual chapter requirements visited the LPDR I at Susan County Courthouse, Susan, Virginia. The resident inspector :
visited the LPCR at the Teller Ubrary at the College of Virginia. l in Tarrvtown to assess the condition of NRC and licensee documents filed there. Condition of the documents was acceptable. l j i 1 i I
- o. Tre SRI et witn tne enairman of :ne Boarc of supervisors of 5,. san
;oun ty, ime following topics were eiscusseo:
'.1, The role of tne resioent inspe: tor;
;I) Cur-ent status of Nortn Mary Units ; anc 2; (2) Tae NRO's relattorsnio to tre comunity; I E3-5 Issue Date: 01/27/P4 i
]
, 0610. EXHIBIT 3 INSPECT 10N REPORTS l o (4) Name and EDIepnene number of the resicents' office was left witn tne CnairTlan in tne event any future correspondence or assistance wa s reautsted. , , ;
- 10. unit 2 License Conc 1*1ons The following items relate to specific license concittons as icentified in previous inspection recort 339/82-00,
- a. License Condition (LC) 2.C(4)(b) 339/82-08-05, Pressure triinsmitters and differential pressare transmitter replacement.
7nere .ere 30 pressure transmitters ano differential pressure trans-ntt:ers replacec; 21 in' containment and 9 in tne quenen spray area. Inese transmitters nave oeen instal, leo and testing is being concuctec. Followuo oy the restcent inspectors on tnis modification is still c0n:Inving.
- o. L". 2.C.(4)(c) 239/82-08-06 Wice range resistance temperature cetector '
(RTO) snail oe Qualifie1 f0r raciat1on exposure for 40 years plant life anc conc 1:1ons cue to resign sists acc1 cents. Ice Commission 155uec- , Amencment No. 23 ca tec Acril .e, ; H2 to tne !icense for Unit-2. I: V l 1ction of tne internals was conoucted tnrougn tne existing 6" l inspection ports and througn tne newly installed 2S" ports. 4 ine visual examination revealed no inoication of flow slot obstruction , ! or closure;. No otner visual evidence of degradation.was noted, f. l The EC inspection of A and B steam generator indicated minor corrosion h=" in :ne tube to suoport plate intersections. However this was previously noted curing the inspection concucted in 1979. There as no evicence of tuoe denting as tnat noted in C steam generator. ine E0 inscection of C steam generator indicatec tnat approximately 95g of tne tubes on tne not leg stee snowed evidence of minor centing. ine centing was noted at approximately 35% of tne tube anc tube support plate intersections. - The centing was estimated to De less than one mil ; (0.001") at all locations. l The licensee olans on conducting a boric Acid conditioning program on , tnese steam generators s1m114r to tnat concucted on Unit i steam generators. A coric acia soak at low power followec ey intermittent ooric ecto trea tment caring power operations is D'annec. This process Innioits corrosion ey enemically canoining witn magnetite, a corrosion i procuct tnus forming corasite wnten is a less permeable compounc. ine I corasite compound is less sun;ect to corrosion activity. ine inspector nas no furtner ouest1ons at tnis time. l l l i. s Issue Cate: 01 /2 //84 E3-10
INSPECTION REPORTS EXHXBfT 3, 0610 1 f i 8 10
- 11. Plant Operation ;
'Jumerous containment entertes were made curing the current Unit 2' refueling . 1 ou tage. Tnese entries were mace to review work in progress, overall house.
neeping and safety during work activities, assure acnerence to licensee mealtn Pnysics Policies. On a regular basis ractation work procecures (RWP's) were reviewed and tne specific work activity was monitored to assure the activities were being conducted per tne RWP's. Radiation protection instruments were verified operable and calibration /cneck frequencies were reviewea for completeness. Ine inspectors kept informed on a daily basis of overall status of botn anits and of any significant safety matter related to plant operations. Discussion ere neld with plant management and various members of tne operations staff on a regular basis. Selectec portions of daily operating logs and operating cata sneets were reviewec catly dur1ng tnis report period. The taspectors conducted various plant tours and made frequent visits to tne control room. Observations inclucec: witness 1ng woru activities in progress, status of operating and stancby safety systems anc equipment, confirming valve positions, instrument readings anc recordings, annunciator alams, housekeeping and vital area controls. No violations were identified in these areas.
- 10. Of fsite Review Corimittee (40701)
The inspector rev1ewed the Safety Evaluation and Control (SEC) organt:ation , to verify snat it is conducting tne independent review function as described ! in tne referencea documents. Tne SEC nas replaceo tne committee type revtew organt:ation for tne performance of offsite independent reviews. The inspector reviewec monthly reports _between April 1981 ano liaren 1982 anc verified tnat the SEC was reviewing tnose activities reautred by the Tecnnical Specifications. Tne ovalifications of the SEC staff wre also reviewed for Tecnnical Specification adequacy. In addition to tne SEC, the inspector reviewed tne coeration of tne Nuclear Overview Consnittee, a license imposea senior management review group organizec to periodically review var 1ous aspects of nuclear power plant operations. Inis area nas evalaated in conjunction witn inspection 280, 2S1/82 02. Based on tnts review, no violations or caviations were identified.
- 13. Offsite Support Staff (40703) ine inspector reviewec tne referenced documents to verify that tbe licensee !
nas identifiec :ositions anc responsibilities in the company offices to perform the offstte funct1on of Quality Assurance, Design Engineering and Procurement. ine inspector interviewed individuals in eacn functional area at the managerial level . During the interview, the inspector verified tnat eacn indivioual was cualified for nis position and was aware of n1s respons10tlities and autnority in relation to the company organt:stion anc j i l l l E3-11 Issue Date: 01/?7/8 l
p
'0610, EXHIBIT 3- INSPECTION REPORTS 1
11 ene Quality Assurance Program. This area ass evaluated in conjun: tion witn Inspection 280, 281/82-02.
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faseo'on tnis review, no vtolations or oeviations were icentifiec. l U
.]
i l i l
- ste : ate: 01/27/84 E3-12
INSPECTION REPORTS EXHIBIT 4, 0610 EXAMPLE OF A LESS DETAILED INSPECTION REPORT (OPERATING PLANT) U.S. NUCI.F.AR RICUIATORY COMMIS$10N REGION III Report No. 50-999/82-C8 Docket .No . 50-999 License No. NPF-3 Licensee: Dayton Edison Company Dayton Plaza, 100 Monroe Avenue Dayton. OH 49999 Tacility Name: Nuclear Plant 1 Inspection At: Cinnamon Falls, OH Inspection Conducted: March 1 - May 5, 1982 e Inspectors:
'Y
?. . Shell (p /ff a.
(. or do f 4/ tit 1-Ylok2,, A; proved By: J M. Syn. , A ng Chief Projects Section 3D Inseectton summary inspection en March 1 - May 5. 1982 (Report No. 50 999/82-08 Areas Inspected: Routue resident 1.nspection of actions on previous inspection f andtags, monthly maintenance observation, sonthly sarveil-Lance observation, licensee event reports; IE Circulars; plant opera-tions; refueling activities; inspection during long tets shutdown; and locked valves. The inspection involved 228 inspector hours onsste by two NRC inspectors tacludtag 60 inspector hours onsste during of f shif ts. Results- Of the si.no areas inspected, no iteas of noncoarpliance or deviations were identified in six areas. Three items of noncompliance were teentified tn three areas (failure to meet storage requirements - Paragraph 7; fatlure to meet testing requirements Paragraph 8; failure to provide written authertsation for disassently of motor control center F168 Paragraph 9). Ncte: A statement regarding status of compliance should acDear at the end o' e8Ch se0t10n. E4-1 Issue Date: 01/27/84 .
s._ l 0610, EXHIBIT 4 INSPECTION REPORTS l \. e s f DETAILS j 1 Persons Contacted
*V. Bede, Station Superintendent J. Gower. Assistant Station Superintendent
*R. Manning, Assistant Station Superintendent S. Spenser Adminsitrative Coordinator C. Marlowe, Operations Engineer B. Jonson. Chemist and Health Physicist A. Pope, Operations Supervisor J. Swift. CA Director.
'W. Morrte. sA Supervisor M. Arn.'id, P*ocurement Services Manager T. S. Tupper, Material Control Operations Manager C. K':tredge. Procurement Director
- Denotes those attendtag the exit Lnterviews on March 15 and May 3, i,
i 1982. The inspectors also interviewed other licensee esployees Lacluding memoers of the technical, operations, saLatonance I6C, training, construction, and health physics staf f.
- 2. Action on Previous Inspeccion Findinas g' . ,
(closed) Open Itse (999/81-18-05). The Laspector verified that ' l1 EP 1202.11. SP 1104.11 and $P 1106.06 had been revised or temporarily / . modaf ted to provide the correct Laformation required. l (Closed) Noncompliance (999/81-04-01) . The inspector verified that ST $099.02, "Miscellaneo'sa Inst rument Daily Check", had been revised to clarify the contaLnsent purge logging requirements. Also, the inspector verified that proper entries had been made Ln the con
- tatnsent purge log throughout January, February and March of 1982 with no discrepancies noted.
- 3. Monthly Maintentnee Observation Station maintenance activities of safety related systems and cem- .
ponents listed below were observed / reviewed using inspection procedare(s) as a guide to ascertain that they were conducted in accordance with approved l procedures, regulatory guides and industry codes or standards and in con. f ormance with technical specifications. Issue Date: 31/27/84 E4-2
INSPECTION REPORTS EXHIBIT 4, 0610 1 I The following maintenance activities were observed / reviewed: Changeout of the motor cutoff switch on Delaney 13.8 KV air ciscuit breakers to the A and & buses. 6 I I During followup of LER 99 99 and subsequent resident inspector obser- i !' vation of the motor cutof f switch changeout, a probles with the capability of 13.6 KV/4.16 KV switchgear arose. The probles concerna an unoonitored f ailure of this switchgear in an unanalysed condition. Specifically, the mechanical ILakage, if slightly warped, will not go the full length of travel and the "b" contact will nts close. Vith- , out the "b" contact clos tag, current to the close in solenoid cannot be provided. The licansee is checking for warpage and removing any warpage by hammer blows and adding washers behLnd the contact relay so the mechanical ILakage has less distance to travel in accordance with Delaney Field installation instructions. Delaney has ' Laformed the licensee that the probles is unique to Nuclear Plant 1, however, the inspector considers this f ailure mechanise to be generic and has abbeitted this itse as a generic issue to NRC supervision for review.-
- 4. Monthlv Surveillance Observation The Lnspector observed technical specifications required surveillance j testing on the Control Room Emergancy Ventilation. TRAIN #1, ST 5076.02 and Soric Acid Heat Tracing, Veekly Test, ST 5011.1 and verified that testing was performed in accordance with adequate procedures, that test l Instrumentation was calibrated, that 1Leiting conditions for operation I were set. that removal and restoration of the affected components were acceeplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the Ladividual directing the test, and that any deficiencies identtited during the testLng were properly reviewed and resolved by appropriate j sanagesaet personnel.
{ The Lnspector also witnessed portions of the following test activitiest i PT 5186.01 Locked Valve Verification ST 5030.16, RPS Monthly Functional l Test in 5butdown Bypass for Channel 6. 3 l l E4-3 Issue Date: 01/27/84
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-0610 EXHXBIT 4- INSPECTION REPORTS i
$, Licensee Event Reports To11owuo Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that deportability requirements were fulfilled, tamediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished 1.n accordance with technical specifications.
LIR 99-11 Quadrant Power Tilt in excess of Transient Limit due to dropped rod.
- .ER 49-O ' Siphoning of Spent Tuel Level below T.S. limit.
LIF 4 8 - P. Five C M iscletion valves not tested at required frequency. LEA 98-?) Tive C"HT isolation valves not tested at required frequency.
- LIP 99-10 H 10 found sispositioned.
LER 99-002 RE2007 STAS Containment Ridiation Monitors Tailed Iow LER 99-01' Valves CS20. TV766 and IV790 found sispositioned
- 6. II Circular Tollown For the !E Circulars listed below, the inspector verified that the .<
Circulars were received by the licensee management, that a review b ; for applicability was performed, and that if the circulars were' i applicable to the facility, appropriate corrective actions were taken or were scheduled to be taken.
.IEC 76-13 Inoperability of Service Water Pumps IEC 81-06 Potential Deficiency Affectir.g Certain Texhall 10 50 Milliaopero Transmitters
? Review of Plant Oeerations - Procurement I n e inspectors reviewed the licensee's storage activities to ascertain wnether estersale and supplies used for safety related functions are maintained in conformance with the licensee's approved CA program i and taplementing procedures.
The inspection was performed in two stages. The first stage was a tour of the warehouse, he second stage was a tour of the station grounds to u sure that once 1sterial has removed from the warehouse that preter storage requirements were being met prior to installation. l l i 4 l 4 ssue Cate: 01/27/34 E4-4 4 l 1
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l INSPECT 10N REPORTS EXHfBIT 4, 0610 i s
- s. During the tour of the warehouse the following itses were identifiedi (1) Severst safety related cable on roots did not have the ends taped properly or not at all in accordance with Section 6.2.2 of AD 1867.03. Not all cable was found improperly taped but the improperly taped cable was interstaed with properly taped cable. This same specific finding was identified in the 1980 Forformance appraisal Brant.h (P&B) inspection. The above finding was identified to the 11 consee who promptly took corrective action.
(2) Safety reisted 18". 65* ethews staged in the Quality
!.ngineering hold tree had their weld preparation surf aces prstected with cardboard and improperly taped. Identical elbows from the same purchase order were stored in the warehouse with properly taped plywood dites protecting the weld preparation surfaces. This was identified to the licenses who promptly took correctiv, action by replacing the cerdboard with plywood covers (3) Out-of date material in escoes of s helf hife requirements had not been purged free the warebcuse. Items which did not meet shelf life requirements were stored with items- .
which did meet shelf life requirs u ts presenting the possibility of unknowning use of aanconforming material. Also, the liceasse used informatt,c tage as modified hold tage. The inforestian on the iniarmation tage was frequently found to be incorrect. The P&B inspection of 1960 identified irregularities in the control / storage of asterial with shelf life requirements. I.icensee management was present when this finding was made. (4) Both the east and west safety related storage areas outside the warehouse were observed to be unlocked during the day. shift. In addition, the east storage was also found unlocked on March 11, 1942 during the backshift. h e inspectors entered the storage area and remained approminately five minutes. At no time were the inspectors challenged. The inspectors observed that a security patrol drove past the af fected gate just prior to their entry and shortly af ter they departed the storage ares. The licensee was nottfied of this occurrence. Inflammable materials, points, oil and other based ink (3), watch has a flash point of 110' y were stored adjacent to safety related asterials on March 9. 1982. Section 3.3.3 of AD 1847.03, "Materiale Handling and Storage Requirements" lists this as prohibited material. This same specific finduts was identified during the 1960 P&3 inspection. The inspectors questtoned warehouse personnel and learned that sanagement directed that these asterials s i E4-5 Issue Date: 01/27/82
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0610. EXHXBIT 4 INSPECTION REPORTS ,1 .. i be stored in the warehouse. The licenses stated that the other based ink would be removed 1sumediately and th.s belance of the inflammable would be removed within two weeks. The inspectors returned to the warebouse on April s. 193.1 and again found inflammable motorials including the etbe.t based ink. The inspectors informed the licensee of their findings and aspressed their concern about the repeethbility of the finditgs . (6) The inspectors noted the significant improvesnats which have been nede in the physical facility, b, During the tour of the station grounds the following items were identified (1) Safety reisted cable was improperly statre.' 5/a reels of level C cable requiring inside storage wor's stored outdoors in the sud adjacent to the United Engineers and Constructors (LTAC) fabrication shop. Numerous reels of level D cable l were also in the sud in this some area. Level D cable is required to be blocked off the ground and in an area of
. adequate drainage. Cable not on reels was laytag in the '
sud in this same area. The laydewn eres outside the fahrt* cation shop also contained t.able reels which had no ident1*
- fication tags; therefore, segregation between safety related and non saf ety related meterial was not belas notatained.
In addition adjacent to the cable reels was a great deal of trash and debris. Dne reel of level C cable se es a trash # pile nest to the gatehouse in direct observation of all personnel entering the gatehouse. (2) A safety related 20" flange was stored in the service water tunnel on March 3. 1932 w*th its weld preparation surface unprotected. (3) Three pieces of safety reisted unistrut channst designated for insise storage level C. were outside with one pnece in the sud. Itsas (1). (2), and (3) were brought to tLe attention of QC. A bold was placed on all improperly stored cabis. The flange's weld prep , was covered wsth plywood and properly taped. The unistrut was stored properly. The above Insted items are considered esemples of noncoe-p1&ance wsth 10 Cn 50. Appendix 8. Cratss en X111 (34.6/f 2 08 01). S. lefuelis Activities The inspector verifsed that prior to the handling of fuel 1,n the core, all surveillance testing required by the technical spectisc.ations and licensee's procedures had been completed; verified that during the cutage the periodac testing of refueling reisted equapeett was 6 1 A
!ss s Date: 01/27/8 E4-6
7 l-JNSPECTION REPORTS EXHlBF 4, 061 1 l l l l performed as required bt technical specifications; observed three I shifts of the fuel handling operations (removal, inspection and l insertion) and verified the activittee were performed in accordance with the tecJmical specifications sad approved procedures; verified l that containsect integrity was osintained as required by technical specificattor.o; verified that good housekeeping was saistained on the refueling ares; and, verified that staf fing during refueling was in accortance with technical specifications and approved procedures. Subsequent to removs1 of the reactor veneet head and upper plenum the inspector determined that all applicable inspection requirements l had not been completed on the polar crane. Specifically. the docu-i mented rope inspection required at sia month intervals er prior to l use (whichever greater) had not been done at the required frequency. I n e last rope inspection was at the end of July 1961 and was not performed prior to the head lift in March 1932. Review of the crane inspection procedure revaaled that the procedure specified an annual or at* refueling taspection frequency for the rope. This is considered an ites of noncompliance 10 CTR $0 Appendia I, Criterica XI!!. The licensee subsequently inspected the cable and revised his procedures to prevent recurrence of this probles. No response is required.
- 9. Inspection Durir.r Iona Tore Shutdown
. Tha inspector observed control room operations. reviewed applicable l logs and conducted discussions with control room operators durang the inspection period. The dnapector verified survettlance tests required during the shutdown were accomplished, re h /ed tagout records, and verified applicability of containment istegrety. Tours of containment, suailfary building, turbine building accese.
. ible areas including exterior areas were made to make independent assessments of equipment conditions, plant conditions. radiological controls, safety, and adherence to regulatory requirements and to verify that maintenance requests had been initiated for equipment in need of estatenance. De inspector observed plant housekeeping /
cleanliness conditions, including potential fire hazards, and varie fled implementation of radiation protection controls. The Anspector by observation and direct interview verified that the physical security plan was being implemented La accordance with the station security plan. D e anspector reviewed the licensee's jvaper/ bypass controls to verify there were no conflicts with technical specifications and verified the amplementattos of radioactive weste systes controls. It vaa noted that general housekeeping improved during the sonth of April. During a four of the turbine building the inspector observed a worker disassembling a new essential 30 V setor control conter (MCO) which had been staged on the 603' level of the turbine building prior to saata11stion in the Imergency Ventilattoo Systes (EV3) fan room on the 623' level of the auxtlaary building. The inspector inquired why the disassembly was being performed ana under what work authoria sation. The reply was that the disassembly was necessary te get the M00 into the EV8 f an roos and the work was authorim by I ( 1 7
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E4-7 Issue Date: 01/27/84 l - _ - . . . . . . . . . -- w
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-i j d610,EXH1BfT4 INSPECTION REPORTS
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MWO 81 103 56. Review of this MVO and all other 81-103 series MWO's provided no such authorization for the disassembly of the motor control conter. This is considered an ites of noncompliance with 10 CTR 50, appendia 8, Criterion V (346/82 06*02). , l
- 10. tock.d valv.s {
The licensee controls approximately 300 specific volve in critical safety systems on the plant site via locks with administrative control over the keys to the locks and over operation of the valves. The keys to the locks are kept in a locked cabinet in the shif t super- 4 visor's office and possession of a key requires the permission of l the shif t supervisor. Once a valve's position is changed from its normal position it is logged in the " lacked Valve Log" elong with the reason for the position change and the positioner initiale for the position change. While the valve is in its abnormal position the lock is kept unlocked. When the valve is returned to its normal position the positioner iattials that the action has been completed in the f.ocked Valve !og. An independent verifit.ation is also made when the valve is returned to its normal position and the verif ter ( initials this to be so in the tecked Valve 143 The locked Valve i , leg is required to be reviewed by each oncoming shif t supeWisor as part of his acceptance of shif t responsibility. A valve verifi-cation of all the valves centro 11ed by the locked valve log is l performed on a monthly basis. l Trom mid February to mid2Harch there were three instances of incon- - l sistencias between actual valve position and that sta?od in the tecked
- Valve tog. Valves DM 10 .C5 10. FW766 and W790 were found to be out I of the documented position. These valves had no safety significance y for the mode in which the plant was operating, as a result of this loss of control, the licensee has counseled all individuals who are allowed access to the locked valve keys in the importance of adherence to the locked valve procedure. The licensee will change the locks on the locked valves and every four days is performing the monthly veri-fication of the locked valves required for Modes S/6 until licensee management regains confidence in the locked valve procedure. Alsu, the licensee ts planning to go to a dedicated cabinet for the locked valve keys. After the third incident the inspector performed a valve verification of all the locked valves with no inconsistencise noted.
11 Esit teterview
"'be inspector set with the licensee representatives (denoted in Paragraph 1) throughout the inspection period and on March 15 and May S. D82, and sumstrised the scope and findings of the Laspection activities.
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- ssue Date: 01/27/84 E4-8
INSPECTION REPORTS ~ EXHIBIT 5, 0610 EXAMPLE OF A PHYSICAL SECURITY INSPECTION REPORT U.S. NUCLEAR REGULATORY COMMISSION . OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.+ 50 938/82-11 Docket No. 50-938 License No. OPR 732 Licensee: Southeastern Utilities, Inc. 2515 rennedy Areaue Bigtown. Arkansa s 72166 Facittty Name: King Point Units 1 & 2 Inspection at: King Point Site, Kingston, Arkansas Inspection conducted: June 9-11.1982 Oate of Last Physical Securit, inspection Visit:- April 10.1982 Type of Inspection: Unannounced Physical Security Inspectors: Name Title Date Approved by hame Title Cate
!espectice Surrary Areas Inscected: Included review of f ecurity Plan and Implementing Procedures; Security Program Audit; Security Organtrations Personnel; Physical Barriers -
Protected Area; Physical Barriers Vital Areas; Lighting; Access Control Personnel; Access Control vehicle; Act.ess Control Package; and Testing and "a i nt ena nc e . The inspection involved 68 manhours Desite by two NRC insDeCtors. The inspectiCn was begun during an offsnif t perioc; 12 inspection mannours were accomplished durieg offshift periocs. I Not?: A statement at the end of each section regarding status of Compliance should be included. E5-1 Issue Date: 01/27/84
0610, EXHlBfT 5- XNSPECTION REPORTS - -
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Results: The liceeste was found to be in Compliance with NRC requirements - within the 10 areal examined during the inspection except for the following A . items; ) 1 i
- 1. Security Organization . Personnel: A security guard, during ! .l Questioning by an inspector. Could not Satisfactorily demonstrate on understanding of and an ability to perform Certain duties.
- 2. Physical Barrieel = . Protected Area: A Visual obstruction that Could aid an intruder was found in the Protected Area.
- 3. ACCe15 Control 5 VehiCIe: A Security guard failed to learch a' pcrtion of' vehicle entering a PA.
4 Access Controls Personnelk ' A Vital Area door mas .found unleCured ' and una ttended. l ! l l 1 11 l l l
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Issue Date: 01/27/84 E5-2 4 L
l, . INSPECT!ON' REPORTS l EXHIBIT 5."061u. 4 peport Details
- 1. rev Persons' Contacted "T. Boss Plant Manager; "J. Mixx, Site Security Manager; **R. Bocha Site Security Supervisor Ace Detective Co.
The inspectors also interviewed several other licensee employees and members of the security organization.
- 2. License 6 Action on Previous inspection Findinos (Closed) Noncompliance (99 07 01) Failure to document all duties recuired of a security guard controlling access to vital area. The inspector found that the required procedures had been written.
l 3. Exit inte* view"* 4 Unresolved items"*
- 5. Independent inspection Ef fort""
- 6. MC B1126 - Security Organization cersonnel 4 One item of noncompliance was noted.
*' On June 10.1952, at 8:30 p.m.. John Adams. a security guard manning Post No. 4. a foot patrol of the Protected Area was Questioned by Inspector G. Smith. Adams could rot satisfactorily demonstrate an understanding of the use of force that could be used on peaceful demonstrators, violent demonstrators, and an intruder whose intentions and capabilities were I unknown. Furthermore. Adams did not know how to use the can of mace with which ne had been provided. Adams was promptly relieved of dutics by J. Mixx and replaced by a qualified guard. Mixx stated that Adams would be limited to other duties which he was cualified to perform until he had been trained and Qualified in the deficient areas (821101).
*me words " Safeguards information are typed here if the report contains ssca information.
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** Denotes tiose present at the exit interview. Should be identified in the report by a symbol and footnote.
*** Provide as appropriate.
"" Provide details of issues not covered in specific inspection program as ,
appropriate, j 1 1 E5-3 Issue Date: 01/27/84 1 2
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0610, EXHIBIT 5' INSPECTION REPORTS-i i l
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- 7. "C 91M1 Physical Barriers - protected Area One area of noncompliance was noted.
On' June 9.1982, at 2:00 p.m... during a tour of the protected area by Inspec-ter r. Jones and J. Mixx a power transmission (telephone) pole was dis-covered lying across the isolation zone inside the protected area {. tone No.
- 12) 200 f t south of the northeast corner of the protected area barrier. The pole was approximately 20 f t long and 2 f t in diameter and could aid an in.
trster. ir undetected penetration into tne protected area. A photograph of erea and pole is attacred 199 11-02).
- 8. MC 81174 Access Coeteot - Vehicle On Jure 11,1982.' at ?:05 p.m., while Inspectors Jones and Smith were ob-serving avtivities at the veMcle entran.ce into tee protected area adjacent to tee "ain Access Control Point. E. Rea a security guard, failed to search the engine compartment of a United Parcel Service van, Arkansas License EQU 243. Other portions cf tre van were searched, including the cargo area, but not tre cargo itself :99-11-03),
- s. ' N !!!?O Access Control - Personnel Ore *tet of noncompliance was noted.
- Cn Jsne 9,1982, at 10:05 a.m. during a tour of vital areas by Inspector Smith and J. Mixx. door No. 53 on the third level of the reactor building (s -I (wrich leads into the cable spreading room - a vital area) was found open with no one controlling access, either at the door or within the area.
($ ketch of area is attached.) An examination of automatically recorded entries indicated that D. Cave. a reactor operator had entered the cable screading room at 9:45 a.m. and was properly authorized to do so- A sub-secuent interview witt Cave revealed that he had been contacted s" the contrcl room at approximately 9:55 a.m. and was informed that he should
'a' mediately check control No, 2 in the switchgear room. J l ave cos1d not rememter if be had secured door Nc. 53 when he departed. A c"ece o' the caole screading room by Cave aed L. Brick, senior reactor op-era tca. dicciosed that nothing was amiss fi9-1104).
- . Attac % eats j
!1) photograch (MCB1151)
(2) Sketen (wC S1170)
- 7"e words " Safe 1sards Informatio,n" are typed here if the report contains such Information.
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- me One: 01/n/9 E5-4
b p. L iTNSPECT20N~ REPORTS EXHIBIT 6, 0610 EXAMPLE OF A MATERIAL CONTROL AND ACCOUNTING (MC&A) INSPECTION REPORT . .
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U.S.' NUCLEAR REGULATORY COMMIS$10N OrFICE OF INSPECTION AND ENFORCEMENT REGION _ Report No. Docket No.: Ltcense No.: Safeguards Group.: Licensee: Facility Name: Inspection at: Inspection Conducted: Oate of Last MC&A inspection visit: s Type of Inspection:
,i Name Title Da te l
i Apprcved by: l Name Title Da te i I lespection Summary Areas Inspected ($ ample entries in this section of report are facility Organi-
- ation, facility Operation Measurement and Statistical Controls, Shipping and
; Receiving, Storage and Internal Control, lD and Associated Limit of Error. Recor:!s
, and Repcrts. and Management of Material Control System. )
f Frovide a statemert of number of inspector. hours involved, whether the inspection was or ite, number of inspectors involved and whether inspection was begun during j tae regular hours, during offshift periods, etc.
- Results: Provide here the number of areas inspected and the number of areas in
.nich noncompliance or deviations were identified. List those areas. If no vio-lat'ons or deviations were found state that fact.
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E6-1 Issue Date: 01/27/"4 l l
4 0610, EXHIBIT 6 INSPECTION REPORTS
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e peport Details
- 1. vey persons Contacted List here names, positions, and affiliation (if atplicable) of people who were Contacted. Note also by means of a footnot", those persons uno were present at the exit interview.
- 2. Liceesee Action on Previous lespection Findings Note here items of noncompliance noted on tPe previous inspection and iden-tify the previous report by number, if an tem of noncompliance has been Closed, note that fact by beginning with nctation "(Closed)."
- 3. Enit Interview 0escribe the interview as appropriate.
4 Unresolved items Provide as appropriate.
- 5. Independent faspection Effort Provide details of ef fort not covered in specif1C inspection program as appropriate.
**6. MC 852028 - Facility Oceaniza tion _ ,
No items of noncompliance noted. The inspection results were attained 4ip througn discussions with licensee management and review of licensee's funda-mental nuclear material Control plan (FNMC) and procedures.
**? we ac20am . Facilit y Operation No items of noncompliance noted. The inspection results were attained through a review of the licensee's process operation.
The following modifications were made since the last inspection:
- a. Effective July 1.1978. the MBA ICA structure for the facility was modified to reflect the rationale for change described in the May 8-12 1978 inspection report (section B-2-a Report No. 70-387/79-03 (It 78-20)). The key f eatures of this modification included the com-cining of scrap recovery (formerly MB A-3). ..
- The notation "10 CFR 2.790(d) Information" is typed here if applicable.
Ibe manual Chapter discussed here has been selected for illustrative pu posesr only. The portion of the IE Manuel on MCLA inspections specifies unich man-wal CPacters are to be accomplished. 1 L issue Date: 01/27/84 E6-2
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*. - - INSPECTION REPORTS EXHIBIT 6, 0610 l
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**8. MC 652068 - Measurement and Statistical Controis Two items of noncompliance were noted: ,
The licensee failed (1) to consider rounding errors in the determination of random weighing error ar.d (2) to update errors associated with the nondestructive gama assay system. The inspection results were attained through: (1) a tour of the facility to observe the Itcensee's measurement points and sampling points. (2) obser-vations of some of the measurement systems as they were functioning, as well as discussions with the operators of these sustoms.....(6) review of the util116 tion of these measurement errors in the calculation of the LEIO.. . The inspector reviewed the methods of determining the random and system. stic errors for the three types of measurement systems. Each error as it applies to each system is discussed below,
- a. Random (weighing) . The licensee determines this error by ....
- b. Systematic (weighing) - The Itcensee does not determine this error,
- c. Random Dampling (amperometric) - This is determined from the analysis performed per lot. Random and sampling errors are not separated,
- d. Systematic (amperometric) - This is determined from the results of the NBS 949 standard.
4
- e. Random and Systematic (gasuna scanner) - These errors are not determined.
g Consequently, they are not updated. The licensee uses a 50% error for this system in limit of error calculations (78 06 02). The licensee's failure to consider rounding errors in the determination of the random weighing error, and the licensee's f ailure to update errors associated with the game scanner constitute items of noncompliance, of the deficiency level. During the inspection. the licensee was unable to produce documentation of the annual measurement reviews for 1976 1978. ..For this ressor. this item will remain unresolved pending review of these reports during a future inspec tion (78-06-04).
"9. MC 852009 - Shippino and acceivino No items of noncompliance were noted.
Inspection results were attained through review of each of the prepared NRC.741. Nuclear transaction Reports. against criteria for preparing / completing the form. timeliness in issuance and completion. correctness of the coding information/ quantitative data, and evidence of significant. .. See footnotes or previous page, 2 E6-3 Issue Date: 01/27/B4 1
E ,;c - -- - t , :.. ; c ,- 0610,1 EXHIBIT'6' INSPECTION REPORTS- . . l e i e
**10. MC 852108 Storace and internal Contrels )
PS items of noncompliance were noted.
"13. ' MC 857188 - Management of Materials Control Systees No items of noncompliance noted.
The inspection results were attained through review'of'the Licensing Sa fegdards Audit, which is similar in scope to that for the Ad hoc Comit. tee Audit. ano the Pleasurements Audit. 14 . Attachments Seference any attachments. See footnotes on page 1. t s l 3 4 Issue Date: 01/27/8.: E6-4 i
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E UNITED STATES
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NUCLEAR REGULATORY COMMISSION i , OFFICE OF INSPECTION AND ENFORCEMENT Washington, D.C. 20555 INSPECTION AND ENFORCEMENT MANUAL ! DQAVT/DI CHAPTER 1245 l l 1 INSPECTOR QUALIFICATIONS R 1245-01 PURPOSE ,- To provide guidelines .for the qualification of inspectors through regional, formal classroom, and on-the-job training. 1245-02 OBJECTIVES 02.01 To ensure that inspectors meet minimum knowledge and qualification standards. 02.02 To maintain inspector qualifications and training in general e conformance to standards for comparable job activities in the nuclear industry. 02.03 To provide a standardized methodology for determining that 'an inspector has met the minimum training requirements. ; i 1245-03 POLICY Inspector personnel must understand the facilities, processes, and activities for those areas they inspect in addition to the criteria, techniques, and mechanics of inspections. Newly hired personnel seldom possess all of these required qualifications. Therefore, formal class-room, self-study, and on-the-job training are needed to ensure that the i newly hired inspector ootains the required knowledge and understanding necessary to be considered qualified to implemer.t the IE inspection program. Each inspector must complete the required training (outlined in Appendix A of this chapter) or verify (through successful completion of a written equivalency examination) that he/she has the desired level of knowledge in his/her specialty. The passing grade for each course, series of courses, or equivalency examination is 70%. Training activities for new inspectors will be documented in a Regional Training and Qualification Journal which encompasses regulatory, adminis-trative, and technical practices pertinent to each area of inspection. Completion of a Regional Training and Qualification Journal and formal Issue Date: 08/01/86 ____._.____-__-J
e training courses (or equivalency examinations) constitutes the minimum ' inspector qualification requirements. Other requirements such as regional ' training may be used to supplement or enhance training. Once an inspector has completed the Regional Training and Qualification Journal and formal training courses, that inspector will be evaluated by an oral qualification board (Board). Each region will constitute an oral qualification board for this purpose using the guidance in Section 08 of this manual chapter as minimum requirements for the Board. In a situation where qualification is delayed as a result of an inspector not being able to schedule certain formal training courses, or for other time restraint considerations, the Regional Administrator (or his delegate) or Office Director (or his delegate) may provide interim qualification for those areas where the inspector is considered qualified. Approval author-ity for interim qualification can be delegated to the Division Director " level. , Inspectors who are receiving on-the-job training and have not completed qualification can perform inspection activities under the direct instruc-tion of a . qualified inspector. With the exception of inspectors who are receiving on-the-job training, an inspector is expected to be qualified for the area being inspected. In some cases where an inspector has taken most but not all of the required training, this may require the issuance of interim qualification. (Aninspectorwhochangesdisciplines,forinstance,achangefromconstruc-tion to operations, must meet the training and qualification requirements gror the new discipline. In such cases, it is expected that similar train- - ing requirements between the two disciplines will not have to be repeated. The requirement for an inspector to be qualified by the process of an oral bJ qualification board applies to those inspectors who have not been qualified by the issuance date of this manual chapter. Special circumstances (e.g. , loss of contracts or lack of instructors) may make it impossible to provide employees with required formal classroom training within the time frames specified in Appendix A. When this occurs, the Director, Technical Training Center (TTC), will issue a memorandum to the regional training coordinators indicating the affected training l courses, circumstances involved, and reinstatement dates. 1245-04 DEFINITIONS Course Series. A progressive sequence of courses in a particular techno-logy for which a composite examination grade is given. Equivalency Examination. An examination administered through the Technical Training Center or its contractors in lieu of specific course attendance. Observation Training. A training / work assignment, for up to 6 months at a utility facility. On-Site Training. Required training for resident inspectors designed to tnorougnly acquaint these inspectors with specific site systems, structures, and management organization.
- ssue Cate: 08/01/86 1245 i
._ ___ ____-_-____-_________-___-_____-_---___--_--_O
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. Required Training. Formal classroom and on-the-job . training representing the minimum acceptable level of knowledge in a given field.
Supplemental Training. Optional courses, depending on the inspector's pre- 3 h vious work experience and planned inspection act'vities that may be re- ' quired for performing inspections in specific areas. Refresher Training. Required training designed to update and maintain qualification. IE Training and Qualification Journal. A document that establishes the 1 minimum training requirements for formal classroom instruction, on-the-job I training, local training sessions, and self-study. This document serves as a guideline for developing regional training and qualification journals. ] Regional Training and Qualification Journals. Documents developed by regional . offices to implement and document the minimum training require- f j ments as outlined in the IE Training and Qualification Journal. l Oral Qualification Board. This Board consists of regional management and inspector personnel and meets for the purpose of reviewing and document-ing the qualification of an inspector to conduct the prescribed IE inspection program. Interim Qualification. Qualification of an inspector by the Regional Administrator (or his- delegate) or Office Director (or his delegate) to conduct independent inspections in specified areas of the inspection pro-gram before that inspector completes all required training. i 1245-05 RESPONSIBILITIES AND AUTHORITIES
. 05.01 Director, Technical Training Center. Administers the training pro-gram and implements formal classroom and simulator training outlined in this chapter.
05.02 Directors, IE Divisions. Assist the TTC in developing and main-taining the IE Training and Qualification Journal and inspector qualifi-cation policy. 05.03 Regional Administrator. Ensures that inspectors achieve and main-tain qualifications in accordance with the guidelines provided in this chapter. Develops regional procedures for the establishment and perform-ance of an -oral qualification board to review and document an inspector's qualifications. Certifies that an inspector is qualified to inspect specified areas. This certification is usually based on the recommendation of an oral qualification boar'd. 1245-06 TRAINING ACTIVITIES 06.01 All inspectors must successfully complete the training require-ments for their individual inspection areas as listed in Appendix A. l
- a. Written examinations will be used to determine whether inspectors have cotained the required 70% level of knowledge and understanding.
f 1245 Issue Date: 3/1/3 G
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- b. Inspectors who fail courses will be given the opportunity to acquire the knowledge level required through self-study and reexamination or
- to repeat the course as described in IE Manual Chapter 1249.
- c. NRC management assumes that inspectors possess the necessary moti-vation and ability to achieve such a level of knowledge and under-standing. In the rare situation where such is not the case, management will decide what action to take on an individual basis.
06.02 Classroom and simulator training are designed to supplement the inspector's education, experience, and NRC on-the-job training by provid-ing basic theory and knowledge as well as job-related techniques. 1245-07 IE TRAINING AND QUALIFICATION JOURNAL 07.01 The TTC is responsible for developing and maintaining the IE Training and Qualification Journal (IE Journal). The use of the IE Journal is described in Appendix B of this chapter. 07.02 The IE Journal will provide the regions with a guideline to develop Regional Training and Qualification Journals. Newly hired inspectors will then have a detailed series of activities and study areas to be completed in a specific period, usually within the first 2 years of employment. The l , journals cover self study and seminars or group discussions in the areas of: i a. Code of Federal Regulations ,
- b. pertinent NRC and IE manual chapters I c.
d. technical areas of inspection, methods, and knowledge schedule of orientation and required training as delineated in h Appendix A 07.03 Assistance in development and maintenance of these journals will be provided by the regions and IE Divisions.
- 1245-08 ORAL QUALIFICATION BOARD AND CERTIFICATION 1
I The oral qualification board (the Board) will be convened for the purpose of reviewing an inspector's completed training records and for determining, by the process of an oral examination, that the inspector meets the minimum knowledge and qualification standards specified in this manual chapter. Af ter the Board nas completed its examination of an inspector, the Board will determine whether or not an inspector meets the minimum qualifications required to be certified. An acceptable decision by the Board will result l in a f avorable recommendation to' the Regional Administrator. Concurrence by the Regional Administrator, as certifying official, will be documented j and a record kept in the inspector's training file. This documents certi- l fication of the inspector to conduct independent inspections. The region will be responsible for establishing administrative procedures l for the implementation and maintenance of a Board. s l 08.01 Board Members. The minimum numoer of personnel required to consti-tute a Boaro should be three. A cross-section of qualified regional l I Issue Date: %'l / W . , 1245 j
v perso_nnel should be included and can range from a peer level inspector to'a , division. director. Regional management of at least the branch chief level should be included on each Board in addition to the inspector's immediate supervisor.
'08.02 Board Conduct. The region should develop a list of review ques-tions that include all areas of the Regional Training' and Qualification Journal. These questions should allow and encourage the inspector to verbalize his/her depth of knowledge and understanding of a given area, rather =than questions that require a ' yes or no type answer. Major emphasis in questioning should be directed toward those situations that require the inspector to demonstrate his/her knowledge of NRC policy and philosophy as it relates to the licensee and the implementation of the inspection program. This should not exclude questions of a technical nature; however, since the inspector has already been tested in this area I by the TTC courses, it should not be a major area of questioning by the Board.
08.03 Board Documentation. At the conclusion of each Board meeting, the Board should prepare a written recommendation. to the Regional Administra-to r. The written recommendation will either recommend that the inspector be certified as qualified or recommend that more training be given in a certain area. This documentation should be entered into the inspector's training file in the region and at the TTC. 1245-09 . INTERIM INSPECTOR QUALIFICATION 09.01 'An inspector who has not completed all requirements for final certification in one of the areas listed in Appendix A may be qualified to perform independent inspections in specified areas. 09.02 To establish an interim certification, the inspector's supervisor will evaluate his/her qualifications and identify the portions of the inspection program for which interim qualification is appropriate. ' 09.03 A request will then be generated thrcugh the individual's manage- ' ment for interim .quali fication in the identified areas. The request should be approved by the Regional Administrator or the Office Director. 09.04 Approval of interim qualification will be documented and a record kept in the individual's training file. END Appendices 1245 Issue Date: 2/1/ % 1
APPENDIX A i TRAINING ACTIVITIES A. PURPOSE To identify those training activities necessary to ensure that inspectors:
- 1. know the NRC role and mission
- 2. understand the responsibilities and legal authority of an inspector
- 3. know inspection techniques and procedures and are capable of per-forming the inspector function
- 4. have the type and level of technical knowledge needed to adequately perform inspection activities *
- 5. . understand the inspection program B. BACKGROUND In general, only those inspectors who have successfully completed the required training will be allowed to perform inspections. However, if responsible management evaluates the background and performance of an R individual inspector and concludes that the inspector has demonstrated an ability to perform inspections in specific areas, even though the required training has not been completed, the Regional Administrator or Office R Director, as appropriate, can authorize the individual to perform inspec- R tions in those areas. When this approach is used, the successful comple-tion of the training is still required within the time limits specified. !
l it is not the intent of this chapter to require persons to participate in j each of the defined training activities if they already possess the type l and level of knowledge that would be acquired by completing training. If l inspectors, when hired, through previous work experience and training, are deemed to possess the appropriate knowledge level, then equivalency exam-ination(s) may be taken and thereby satisfy the training requirements. . l C. TRAINING REQUIREMENTS i Each of the seven sections of this appendix provides the training require- ) ments for a particular inspection activity as indicated below.
'. N 5 A-1 Issue Date: S/l/%
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i Section Inspection Activity' ,' I Radiological Safety Inspection - L
' l Reactor Operations, Resident and Region-Based II ProjectInspection III Reactor Construction, Resident Inspection IV Reactor Engineering' Support Inspection V Safeguards Inspection
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VI' Vendor Inspection VII Emergency Preparedness Inspection VIII Reactor Design Inspection u }. 1" t L] t 4 i i h i l l Issue Date: Elll 70 A-2 1245 l
l SECTION I RADIOLOGICAL SAFETY INSPECTION TRAINING REQUIREMENTS FOR RADIATION SPECIALIST INSPECTORS A. APPLICABILITY The training described below is required for all radiation specialist inspectors assigned to perform radiological safety inspection activities at reactor and fuel facilities and material licensees facilities. B. TRAINING
- 1. Reouired Regional Training. This training is conducted in the region using the Regional Training and Qualification Journal.
Regional Orientation Code of Federal Regulations Final Safety Analysis Report Regulatory Guides NRC/IE Manual Industry Codes and Standards Radiological Safety Inspection Accompaniments
, 2. Required Training Courses. This training is coordinated through and conducted by the Technical Training Center or its contractors.
Reactor Health Physics Insoectors 4 (1) BWR Technology Course (R-100 level) R (2) PWR Technology Course (R-100 level) R (3) BWR/PWR Radwaste Course (H-302) (4) Fundamentals of Inspection Course (G-101) Fuel Facility Radiation Specialist Insoectors (1) Occupational Respiratory Protection Course (H-311) R (2) Whole Body Counting / Internal Dosimetry Course (H-312) R (3) Fundamentals of Inspection Course (G-101) Materials Radiation Soecialist Inspectors (1) Medical Uses of Byproduct Material Course (H-304) R (2) Safety Aspects of Industrial Radiography Course (H-305) (3) Fundamentals of Inspection Course (G-101)
- 3. Supplemental Trainino Courses. Depending on the inspector's pre-vious work experience ano planned inspection activities, those
' optional courses are required for performing inspections in specific areas. 12a5 A-3 Issue Date: 2/l M
Reactor Health Physics Inspectors I
.(1) Reactor Health Physics Technology Course (H-200)
(2) Radiological Emergency Response Course (H-303) (3) Radiological Emergency Planning Course (H-306) (4) Radiological Accident Assessment Course (H-307) .; (5) Transportation.of Radioactive Materials Course (H-308) ; (6) Occupational Respiratory Protection Course (H 311) (7) Whole Body Counting / Internal Dosimetry Course (H-312) R (8) Advanced Health Physics Course (H-401) . 4 Fuel Facility and Materials Radiation Specialist Inspectors (1) BWR Technology Course (R-100 level) R (2) PWR Technology Course (R-100 level) R ! (3) Reactor Health Physics Technology Course (H-200) (4) BWR/PWR Radwaste' Course (H-302)
'(5) Radiological Emergency Response Course (H-303)
(6) Radiological Emergency Planning Course (H-306) (7) Radiological Accident Assessment Course (H-307) (8) Transportation of Radioactive Materials Course (H-308) (9) Advanced Health Physics Course (H-401) , R
- 4. Refresher Training. Appropriate refresher training for each inspec- R tor will be determined.by regional management and will be documented R through the Individual Development
- Plan (IDP) process. Reactor R Health Physics Inspectors are required to complete the Advanced R Health Physics Course (H-401). R i C. EXCEPTIONS ALLOWED j j
- 1. Personnel assigned as radiation specialists after January 1,.1984, must complete the training / qualification requirements for s el f-study, on-the-job training, and required training identified in the Regional Training and Qualification Journal.
- 2. Inspectors who have been trained / qualified under existing regional journals do not have to requalify under the Regional Training and Qualification Journal.
- 3. At the discretion of regional management, inspectors currently work-ing to complete their training / qualification under existing regional journals may transfer appropriate self-study, on-the-job, and re-quired training courses to the Regional Training and Qualification Journal.
D. TIME' LIMITATIONS FOR COMPLETING TRAINING
- 1. Required Regional Training and Training Courses. All newly hired personnel and assignees are required to complete the required train-ing activities or take and pass equivalency examination (s) within the first 24 months after being assigned.
- 2. Refresher Training. Inspectors are required to complete refresher R training courses within 4 to 5 years after completion of required R \
training courses and every 4 to 5 years thereafter. R
.s sue Date:. 4/1/% A-4 1245 l
'SECTf0N II-
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.1
' REACTOR 0PERATIONS, RESIDENT'AND REGIONALLY-BASED PROJECT INSPECTION
. TRAINING REQUIREMENTS FOR BWR OPERATIONS INSPECTORS A, APPLICABILITY-
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2The training describe'd' below~ is required for all resident and regionally based project inspectors assigned to perform preoperational testing, start-up testing and/or operational' inspection activities at BWR facilities. B. TRAINING
- 1. ~ Required Regional Trainino. This' training is to be conducted at the site or, in the region using the Regional. Training and. Qualification-Journal.
Regional and/or Site Orientation Code of Federal Regulations Final Safety Analysis Report Regulatory Guides NRC/IE Manual Industry. Codes and Standards Onsite Training Power Plant Inspection Accompaniments
- 2. Required Training Courses. This training is coordinated through and conducted by the Technical Training Center or its contractors.
(1) BWR Technology Course Series (R-200 level, R-300 level, or R-400 R level; R-500 level; and R-600 level) (2) Fundamentals of Inspection Course (G-101) 1 (3) Radiation / Contamination Protection Course (G-102) or equivalent plant training.
- 3. Supplemental Training Courses. Depending on the inspector's pre-vious work experience ana planned inspection activities, these op-tional courses are required for performing inspections in specific areas.
(1) BWR Technology Course (R-200 level) R (2) BWR Simulator Course (R-600 level) R (3) GE Nuclear Engineering Course (R-8018) (4) Reactor Health Physics Technology Course (H-200) (5) Power Plant Engineering Course (G-110) (6) Quality Assurance Inspection Course (G-303) R
. (7) PRA Basics for Inspection Applications Course (G-500) l (8) Observation Training
- 4. Refresher Training. Refresher training will be conducted using a simulator or classroom course of the same vendor design as the I
l 12a5 A-5 Issue Date: E/il16 ; i I
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, reactor to which the resident inspector is assigned. If a simula- 1 tor for that specific design is not available for training, regional .
management will determine what available refresher training is appropriate. (1) BWR Simulator Refresher Course (R-700 level) or R (2) GE Nuclear Engineering Course (R-8018) or (3) BWR Technology Course (R-200 level) or R (4) BWR Advanced Technology Course (R-500 level) R C. EXCEPTIONS ALLOWED f J
- 1. Regionally based project inspectors can satisfy BWR training re- )
quirements by successfully completing the required regional training identified in Section II.B.1(BWR) (this appendix) and the following training activities: 1
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(1) BWR Technology Course (R-200 level or R-300 level) l i (2) Fundamentals of Inspection Course (G-101) (3) Radiation / Contamination Protection Course (G-102) R (4) Those construction technology courses identified in Section III.B.2 (this appendix) that are pertinent to the inspector's area of inspection. . When individuals complete only the above-defined training activi-ties, they are restricted to assignment as regionally based project ." inspectors. When assigned as a resident inspector, the training ) identified in Section II.B.2(BWR) (this appendix) must be com-pleted. If a new employee will eventually be assigned as a resident inspector, it is recommended that the training requirements identi-fied in Sections II.B.1 and 2(BWR) (this appendix) be completed as soon as possible.
- 2. Personnel assigned as resident or regionally based project inspec-tors at BWR facilities after October 1,1983, must complete the training / qualification requirements for s el f-study , on-the-job training, and required training identified in the Regional Training and Qualification Journal, j i
- 3. Inspectors who have been trained / qualified under existing regional inspector journals do not have to requalify under the Regional Training and Qualification Journal.
l
- 4. At the discretion of regional management, inspectors currently work- j ing to complete their training / qualification under existing regional inspector journals may transfer appropriate self-study, on-the-job, and required training courses to the Regional Training and Qualifi-cation Journal.
- 5. Inspectors who, through prior experience and education, possess suf-ficient knowledge to meet minimum requirements may validate a course by requesting an equivalency examination. This request, from n
- ssLe Date: SM/S A-6 1245
p ; l c', the inspector's supervisor to the Director, TTC, should include a summary of the relevant experience and education. The Director, TTC, will determine if an equivalency examination is appropriate, D. TIME. LIMITATIONS FOR COMPLETING TRAINING
- 1. ' Required Regional Training and Training Courses. All newly _ hired I personnel and new assignees are required to complete the required training activities or take and pass . equivalency examination (s)-
within the first 24 months af ter being assigned.
- 2. Refresher Training. R'eactor operations resident and regionally-besed project inspectors are required- to' attend refresher training-24 to 30_ months _ af ter. completing r_equired training and every 24 to 30 months thereafter. This requirement must be met,as long as the inspection activities identified 'in Section II. A(BWR) (this appen- -l dix) are assigned.
TRAINING REQUIREMENTS FOR PWR OPERATIONS INSPECTORS j A. APPLICABILITY The training described below is required for all resident and regione11y ! based project. inspectors' assigned to perform preoperational testing, start-up testing, and/or operational inspection activities at PWR facilities. B. TRAINING
- 1. Reouired Regional Training. This training is to be conducted at the site or in the region using the Regional Training and Qualification Journal.
Regional and/or Site Orientation Code of Federal Regulations Final Safety Analysis Report Regulatory Guides NRC/IE Manual Industry Codes and Standards Onsite Training Power Plant Inspection Accompaniments i
- 2. Recuired Training Courses. This training is coordinated through and conducteo by the Technical Training Center or its contractors.
(1) PWR Technology Course Series (R-200 level, R-400 level, R-500 R level, and R-600 level) (2) Fundamentals of Inspection Course (G-101) : (3) Radiation Contamination / Protection Course (G-102)'or equivalent plant training.
~N5
. A-7 Issue Date: S///%
If k . 11
- 3. !Supplemedal-TrainingCourses. Depending l on .the inspector's pre-vious work experience and. planned inspection; activities, these op-tional courses are ' required ~ for performing inspections..in specific areas. ,
(1) PWR Technology Course.(R-200 level). R (!).PWR Simulator Course.(R-600 level)- R I (3) Reactor Health Physics Technology Course'(H-200) , L(4) Power Plant Engineering Course (G-110) R l
-(5) Quality Assurance Inspection. Course (G-303) R (6) PRA Basics' for Inspection Application,(G-500) R-(7) Observation Training
'4.
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Refresher Training. . Refresher . training will be conducted using . a simulator of.,the .same vendor. design .as the reactor to which the resident inspector is assigned. If a simulator' for that specific j design is not available for l training, regional management will j determine.if available refresher training is appropriate, q (1) PWR Simulator Refresher Course (R-700 level) or R
.(2) PWR Technology Course (R-200 level, R-300. level or R-400 level) R (3) PWR Advanced Technology. Course (R-500 level) R C. EXCEPTIONS. ALLOWED i
*1. Regionally based project inspectors can satisty PWR training re-quirements .by successfully completing the. required regional train-ing identified in Section II.B.1(PWR) (this appendix) and the following training activities: f"N (1) PWR Technology Course;(R-200 level, R-300 level, or R-400 level) R (2) Fundamentals of. Inspection Course (G-101)
-(3) Radiation / Contamination Protection Course (G-102) R (4) Those construction technology courses identified in Section 111.8.2. (this appendix) that are pertinent to the inspector's -
area of inspection. j When individuals complete only the above-defined training activi- ! ties,' they are restricted to assignment as regionally based project l inspectors. 'When assigned as resident . inspectors, the training R identified in Section II.B.1(PWR) (this appendix) must be com-pleted. If a new employee will ever,tually be assigned as a resident inspector, it .is recommended that the training requirements. identi-fled in Sections II.B.1 and 2(PWR) (this appendix) be completed as i
.soon as possible.
I 2 .' _ Personnel assigned as resident or regionally based project inspec-tors at PWR facilities after October 1,1983, must complete the training / qualification requirements for self study, on-the-job training, and required training identified in the Regional Training and Qualification Journal. . k Issue Date: Yl/84 A-8 1245
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3. Inspectors who have been trained / qualified under existing regional L inspector- journals . do not .have to requalify under the Regional Training and Qualification Journal. - 4. At the discretion of regional management, inspectors currently work-ing to complete their training / qualification under existing regional inspector journals may transfer appropriate self-study, on-the-job training, and required training courses to.the Regional Training and Qualification Journal.
- 5. ' Inspectors who, through prior experience and education, possess suf-ficient knowledge 'to meet minimum requirements, may validate a course by' requesting an equivalency examination. This req'uest; from the inspector's supervisor to the Director, TTC, should include a summary of the relevant experience and education. The Director, TTC will determine if an equivalency examination is appropriate.
D. TIME LIMITATIONS FOR COMPLETING TRAINING
- 1. Reauired Regional Training and Training Courses.
- All newly hired personnel and new assignees are required to complete the required training activities or take and pass equivalency examination (s) within the first 24 months after being assigned.
- 2. Refresher Training. Reactor operations resident and regionally R based project inspectors are required to attend refresher training R 24 to 30 months.after completing required training and every 24 to R ,
30 months thereafter. This requirement must be met as long as the R inspection activities identified in Section II.A.(PWR) (this appen- R dix) are assigned. 1205 A-9 Issue Date: E
SECTION Ifl REACTOR CONSTRUCTION, RESIDENT INSPECTION TRAINING REQUIREMENTS FOR REACTOR CONSTRUCTION INSPECTORS A. APPLICABILITY
'l
.The . training described below is required for .all resident . inspectors 1 assigned to perform construction inspection activities' at. BWR. and PWR l
facilities.
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B. TRAINING'
- 1. Required Regional Training. This training is to be conducted at the-site or in tne region using the Regional Training and Qualification
~ Journal.
Regional and/or Site Orientation Code of Federal Regulations Final Safety Analysis Report , Regulatory Guides j ' NRC/IE Hanual Industry Codes and' Standards Onsite Training. Construction Inspection Accompaniments 1 1_ 2. Required Training Courses. This training is coordinated through and f.,, I conducted by the Technical Training Center or its contractors. ! L; (1) BWR Technology Course (R-100 level) R' i (2) .PWR Technology Course (R-100 level) R (3) Concrete Technology and Codes Course (C-302)
.(4) Welding Technology and' Codes Course (C-303)
(5) Electrical Technology and Codes Course (C-304). l 4
-(6) Instrumentation Technology and Codes Course (C-305)
(7) NDE Technology and' Codes Course (C-306) (8) Fundamentals of Inspection Course (G-101) j l
- 3. Supplemental Training Courses. Depending on the inspector's pre- '
vious work experience and planned inspection activities, these op-tional courses are required for performing inspections in specific 1 areas. (1) Inservice Inspection Course (C-308)
)'
(2) Radiation /Contaminatierr Protection Course (G-102) or equivalent plant training 4 (3) Quality Assurance Inspection Course (G-303) R 4 Refresher Training. Appropriate refresher training for each inspec- R tor wil be cetermined by regional management and will be documented R through the Individual Development Plan (IDP). R g Issue Date: 95/% A-10 1245 i L . _ . _ _ _ . . _ _ _ _ _ _ _ _ _________________J
)
n. j i C. EXCEPTIONS-ALLOWED
\
- 1. Personnel assigned as resident inspectors after- January 1, 1984,.
mus t .: complete the training / qualification requirements for. self-study, on-the-job training,- and required -training identified in. the I Regional' Training and Qualification Jot'enal.
- 2. ' Inspectors ~ who .have' been trained / qualified under existing regional
~ inspection journals . do not have to requalify under the Regional'
. Training and Qualification Journal. , ,
- 3. At' the discreti:on of. regional management, inspectors currently work-ing to complete their training / qualification under existing regional inspector:. journals may transfer appropriate self-study, on-the-job training, and required training courses to the Regional Training and Qualification Journal.
D. TIME LIMITATIONS FOR COMPLETING TRAINING 1.' Required Regional Trainir.g'and Training Courses. All' newly hired personnel and new assignees are required to complete the required , training activities or take and pass equivalency examination (s) I within the first 24 months after being assigned.
- 2. Refresher Training. Inspectors are required to complete refre' sher R' training courses within 4 to.5 years.after completion of required R training cnurses and every 4 te 5 years thereafter. R l
'.235 A-11 Issue Date: 9b/86
SECTION IV REACTOR ENGINEERING SUPPORT INSPECTION TRAINING REQUIREMENTS FOR REACTOR ENGINEERING SUPPORT INSPECTORS a A. APPLICABILITY The training described below is required for all regionally based reactor engineering support inspectors assigned to perform construction, preopera- ~ tional testing, startup testing and/or operational inspections at BWR and PWR facilities, i B. TRAINING
- 1. Required Regional Training. This training is to be conducted in the regions using the Regional Training and Qualification Journal.
Regional Orientation Code of Federal Regulations Final Safety Analysis Report Regulatory Guides NRC/IE Manual Industry Codes and Standards Inspection Accompaniments
- 2. Reouired Training Courses. This training is coordinated through and conducted by the Technical Training Center or its contractors. #'s
-(1) BWR Technology Course (R-100 level) R (2).PWR Technology Course (R-100 level) R (3) Fundamentals of Inspection Course (G-101)
-3. Supplemental Trainino Courses. Depending on the inspector's pre-vious work experience and planned inspection activities, these op-tional courses are required for performing inspections in specific areas. For those inspectors whose specific duties involve inspec-tions at operating reactors, either a BWR or a PWR course series is strongly recommended.
(1) BWR Technology Course (R-200 level, R-300 level, or R-400 level) R ! (2) BWR Advanced Technology Course (R-500 level) R (3) BWR Simulator Course (R-600 level) R (4) GE Nuclear Engineering Course (R-8018) (5) GE Maintenance Overview Course (R-802B) R (6) PWR Technology Course (R-200 level, R-300 level, or R-400 level) R i (7) PWR Advanced Technology' Course (R-500 level) R (8) PWR Simulator Course (R-600 level) R (9) Reactor Health Physics Technology Course (H-200) or equivalent plant training (10) Concrete Technology and Codes Course (C-302) (11) Welding Technology and Codes Course (C-303) (12) Electrical Technology and Codes Course (C-304) (13) Instrumentation Technology and Codes Course (C-305) h Issue Date: S //I% A-12 1245
(14) NDE Technology and Codes Course (C-306) (15) Inservice Inspection Course (C-308) (16) Radiation / Contamination Protection Course (17) Power Plant Engineering Course (G-110) R (18). Quality Assurance Inspection Course (G-303) R (19? PRA Basics for Inspection Applications Course (G-500) R
- 4. Refresher Training. Appropriate refresher training for each inspec- R tor will be determined by regional management and will be documented R through the Individual Development Plan (IDP), process. Examples R are:
R (1) BWR Simulator Refresher Course (R-700 level) R (2) GE Nuclear Engineering Course (R-8018) R (3) PWR Simulator Ref resher Course (R-700 level) R 1 (4) GE Maintenance Overview Course (R-8028) R C. EXCEPTIONS' ALLOWED
- 1. Personnel assigned as regionally based reactor engineering' support inspectors after January 1,,1984, must complete the training /quali-fication requirements for self-study, on-the-job training, and re-quired training identified in the Regional Training and Qualifica-tion Journal.
- 2. Inspectors who have been trained / qualified under existing regional -
inspector journals do not have to recualify under the Regional Training and Qualification Journal,
- 3. At the discretion of regional management, inspectors currently work-ing to complete their training / qualification under existing regional inspector journals may transfer appropriate self-study, on-the-job training, and required training courses to the Regional Training and Qualification Journal.
D. TIME LIMITATIONS FOR COMPLETING TRAINING
- 1. Reouired Recional Training and Training Courses. All newly hired personnel ano new assignees are required to complete the required training activities or take and pass equivalency examination (s) within the first 24 months after being assigned.
- 2. Refresher Training. Inspectors are required to attend refresher training 48 months after completing the required training and every 48 months thereafter. This requirement must be met as long as the inspection activities identified in Section IV.A (this appendix) are assigned.
I i l-1 i 1245 A-13 Issue Date: Sh I%
SECTION V SAFEGUARDS INSPECTION . !
, TRAINING RE0VIREMENTS FOR SAFEGUARDS INSPECTORS 7 i
I A. APPLICABILITY l i The training described below is required of all safeguards inspectors assigned to perform physical security and material control and account-ability inspection activities. B. TRAINING
- 1. Reguired Regional Training. This training is conducted in the region ncing tne Regional Training and Qualification Journal.
Regional Orientation Code of Federal Regulations Safeguards Inspection Procedures Regulatory Guides NRC/IE Manual Industry Codes and Standards Safeguard Inspection Accompaniments
- 2. Recuired Training Courses. This training is coordinated through and conducted by the Technical Training Center or its contractors.
c. Physical Security Inspectors D i (1) Reactor Safety Systems and Vital Equipment for Safeguards R Personnel Course (S-401) R (2) Fundamentals of Inspection Course (G-101) (3) Radiation / Contamination Protection Course (G-102) or equivalent plant training (4) Industrial Facilities Protection Course (5-2105) Fuel Facility Material Control and Accountability Inspectors (1) Fundamentals of Inspection Course (G-101) (2) Radiation / Contamination Protection Course (G-102) or equiva?ent plant ' raining (3) Basic Statistics Course (5-101A) or equivaient (^) Safeguards Chemical Analysis Course (5-401A) or equicGnt R (5) Fundamentals of Nondestructive Assay of Nuclear Matemals Course R (S-602A) R i Issue Date: T// M A-14 IM5
..._.._._.__._._..m
1
- 3. Supplemental Training Course. Depending on the inspector's previous work experience and planned inspection activities, these optional courses are required for performing inspections in specific areas. {
Physical Security inspectors (1) Reactor Coacepts Course (G-300) (2) Computer Security Course (S-2115) l- (3) Intrusion Detection Systems - Operation and Maintenance Course (S-3205) (4) Electronics for Electricians Course (S-3305) Fuel Facility Material Control and Accountability Inspectors (1) Adva'nced Statistics Course (5-301A) (2) Neutron Assay of Nuclear Material Course (S-603A) (3) Gamma-Ray Assay of Nuclear Material Course (S-604A)
- 4. Refresher Training. Appropriate refresher training for each inspec- R tor will be determined by regional management and will be documented R through the Individual Development. Plan (IDP) process. Inspectors R are encouraged to attend appropriate workshops and seminars, such R as, the Physical Security Workshop (American Society for Industrial R Security) and the Protective Security Workshop (International Assoc- R iation of Chiefs of Police).
~
R C. EXCEPTIONS ALLOWED
- 1. Personnel assigned as safeguards inspectors after January 1,1984, must complete the training / qualification requirements for self-study, on-the-job training, and required training identified in the Regional Training and Qualification Journal.
l
- 2. Inspectors who have been trained / qualified under existing regional inspector journals do not have to requalify under the Regional Training and Qualification Journal.
'3. At the discretion of regional management, inspectors currently work-ing to complete their training / qualification under existing regional inspector journals, may transfer appropriate self-study, on-the-job training, and required trhining cotii'ses to the Regional Training and !
Qualification Journal.. 0 ' TIME LIMITATIONS FOR COMPLETING TRAINING l s 1. R_e,guired Regional Training and Trainino Courses. All newly hired 1 personnel and assignees are required to complete the required train-a ing activities or take and pass equivalency examination (s) within the first 24 months after being assigned. j 2, Refresher Training. Inspectors are required to complete refresner R training courses witnin 4 to 5 years after completion of required R ' training courses and every 4 to 5 years thereafter. R
'.2
- 5 A-15 Issue Date: Shin l i
L SECTION VI VEN00R INSPECTION TRAINING REQUIREMENTS FOR VENDOR INSPECTORS
]
1 A. APPLICABILITY
~1 The training described below is required for all vendor inspectors assigned to perform architect and engineer (A&E), nuclear steam system supplier R (NSSS),_ equipment qualification (EQ), or component inspection activities. R B. TRAINING
- 1. -Required Training. This training is to be conducted at IE (Head- R quarters) using the IE Training and Qualification Journal. R Administrative Orientation R Code of Federal Regulations Final Safety Analysis Report Regulatory Guides NRC/IE Manual-Industry Codes and Standards Vendor Inspection and Accompaniments Document. Control System (DCS) - User Training Course R
- 2. Reouired Training Courses (Special Project Section Inspectors). R This training is coordinated through and conducted by the Technical R ""
Training Center or its contractors. R ()
; (1) BWt Technology Course (R-100 level) R I
(2) PWR Technology Course (R-100 level) R (3) Fundamentals of Inspection Course (G-101) (4) Technology Courses (e.g. welding, NDE, instrument technology) as R determined by VPB management depending on area of assignment, R previous training, and experience. R
- 3. Required Training Courses (Reactive Section Inspectors and Program R Coordination Section Inspectors). This training is coordinated R through and conducted by the Technical Training Center or its con- R tractors.
(1) BWR Technology Course (R-100 level) or PWR Technology Course R (R-100 level) R (2) Fundamentals of Inspection Course (G-101) R (3) Technology courses (e.g.. welding technology, electrical techno- R logy) as determined by VPB management depending on area of R assignment and previous training and experience. R 4 Reouired Training Courses (Equipment Qualification Section Inspec- R tors). This training is coordinated through and conducted by the R Technical Training Center or its contractors. R (1) BWR Technology Course (R-100 level) R I (2) PWR Technology Course (R-100 level) R Issue Date: 5/t /% A-16 1245 4
l i l
. (3) Fundamentals of fnspection Course (G-101) R (4) Electrical Technology and Codes Course (C-304) R q (5) Instrumentation Technology and Codes Course (C-305) R J
- 5. Supplemental Training Corrses (All Sections). Depending on the in- R spector's previous work experience and planned inspection activi-ties, these optional courses are required for performing inspections in specific areas.
(1) Radiation Contamination Protection Course (G-102) or equivalent plant training (2) Power Plant Engineering Course (G-110) R (3) Quality Assurance Inspection Course (G-303) R (4) PRA Basics for Inspection Applications (G-500) R
' (5) BWR or PWR Techno10gy Course (R-200 level, R-300 level, or R-400 R level) R (6) BWR or PWR Advanced Technology Course (R-500 level) R (7) DWR or PWR Simulator Course (R-600 level) R
- 6. Refresher _ Training. Appropriate refresher training for each inspec- R tor will be determined by VPB management and will be documented R through the Individual Development Plan (IDP) process. R C. EXCEPTIONS ALLOWED
- 1. Personnel assigned as vendor inspectors after January 1,1984, must complete the training / qualification requirements for self-study, on- R the-job training, and required training courses identified in the R Vendor Inspectors Training and Qualification Journal. R
- 2. Inspectors who have been trained / qualified under existing regional R inspector journals may transfer applicable sections of their exist- R ing qualification to the Vendor Inspectors Training and Qualifica- R tion Journal. R
- 3. At the discretion of VPB management, inspectors who are currently R working to complete or have completed their training / qualification R under existing regional inspector journals may transfer appropriate self-study,on-the-job training, and required training courses to R the Vendor Inspector Training and Qualification Journal. R D. TIME LIMITATIONS FOR COMPLETING TRAINING
- 1. Recuired General Training and Technical Trainino Courses. All newly R hireo personnel and new assignees are required to complete the re-quired training activities or pass equivalency examination (s) within the first 24 months of assignment.
- 2. Refresher Training. Inspectors are required to complete refresher R training courses within 4 to 5 years after completion of required R training courses and every 4 to 5 years thereafter. R 1245 A-17 Issue Date: Sh lS fo i
)
, SECTION VII EMERGENCYPREPAREDNESSINSPECTI0t!
TRAINING REQUIREMENTS FOR EMERGENCY PREPAREDNESS' INSPECTORS l A. APPLICABILITY
-The training identified below is required for all emergency preparedness analysts / radiation speci list inspectors assigned to perform emergency, preparedness inspection activities.
B. TRAINING
- 1. Required Regional Training. Tnis training is to be conducted in the -
region using the Regional Training and Qualification Journal. Regional Orientation Code of Federal Regulations Final Safety Analysis Report Regulatory Guides NRC/IE Manual Industry Codes and Standards Emergency Preparedness Inspecti,on Accompaniments
.2. Reauired Training Courses. This training is coordinated through and conducted by the Technical Training Center or its contractors.
(1) BWR Technology Course (R-100 level) R (2) PWR Technology Course (R-100 level) R .'. l (3) Fundamentals of Inspection Course (G-101) (4)' Radiation / Contamination Protection Course (G-102) R
- 3. Sucolemental Training Courses. Depending on the inspector's pre-vious work experience and planned inspection activities, these op-tional courses are required for performing inspections in specific areas.
(1) Reactor Health Physics Technology (H-200) (2) Radiological Emergency Response Course (H-303) (3) Radiological Emergency Planning Course (H-306) (4) Radiological Accident Assessment Course (H-307) . (5) Health Physics in Radiation Accidents (REAC/TS) (H-309) ' (6) Management 0,ersight and Risk Tree (MORT) Analysis Seminar . (G-201) ! 4 Refresher Training. Appropriate refresner training for each inspec- R tor will be oetermined by EPB management and will be documented R q through the Individual Development Plar. (IDP) process. R C. EXCEPTIONS ALLOWED l
- 1. Personnel assigned as emergency preparedness analysts / radiation {
specialist inspectors after January 1, 1984, must complete the b
- n e Cate: b A-18 1245 l
l
l l training / qualification requirements for self study, on-the-job I training, and. required training courses identified in the Regional l l
?
Training and Qualification Journal, l- ]
- 2. Inspectors who have been trained /qt.alified under existing regional inspector journals do not have to requalify under the Regional Training and Qualification Journai.
- 3. i l
At the discretion of regional management, inspectors currently work- i ing to complete their training / qualification under existing regional inspector journals, may transfer appropriate self-study, on-the-job i training, and required training courses to the Regional Training and Qualification Journal. . D. TIME LIMITATIONS FOR COMPLETING TRAINING
- 1. Required Regional Training and Training Courses. All newly hired personnel and assignees are required to complete the required train-ing activities or take and pass equivalency examination (s) within the first 24 months after being assigned. !
2, Refresher Training. Inspectors are required to complete refresher R training courses within 4 to 5 years after completion of required R training courses and every 4 to 5 years thereafter. R l i 1:05 A-19 Issue Date: S/1/14 i
I SECTION VIfI R REACTOR DESIGN INSPECTION TRAINING REQUIREMENTS FOR REACTOR DESIGN INSPECTORS-A. APPLICABILITY The -training described below is required for all reactor design inspectors assigned to perform Integrated Design Inspections (IDIs), Readiness Review Program design' reviews, Independent Design Verification Program inspec-tions,- Engineering Assurance . Program inspections, and the design aspects of modifications made during an outage, and Safety System Functional inspections. B. TRAINING
- 1. Required Training. This training is to_ be conducted at' IE (Head-quarters). using the Reactor Design Inspectors Training and Qualifi-cation Journal.
(1) General Orientation , (2) Code of Federal Regulations (3) Final Safety Analysis Report (4) Regulatory Guides (5) NRC/IE Manual (6) Industry Codes and Standards (7) Design Inspection Orientation - (8) Document Control System (DCS) - User Training Course ;
- 2. Supplemental Training. A prerequisite' for assignments as a design inspector is extensive design experience with nuclear architect l
engineering firms, nuclear steam supply system companies, or other areas of the nuclear industry . performing original design work. . The following technical training courses are recommended as supple-l mental courses and should be incorporated in the individual devel- , ment plans, as appropriate. This training is coordinated through j and conducted by the Technical Training Center or its contractors. I These courses also may be specified by QAB management as required refresher courses for individual inspectors. i (1) BWR Technology Course Series (R-200, 300, or 400 level; R-500 ) level; and R-600 level) l (2) PWR Technology ' Course Series (R-200, 400 level, R-500 level, and R-600 level) .
)
(3) Fundamentals of Inspection Course (G-101) (4) Quality Assurance Inspection Course (G-303) (5) PRA Basis for Inspection Applications (G-500) (6) Electrical Technology and Codes Course (C-304) (7) Instrumentation Technology and Codes Course (C-305) C. EXCEPTIONS ALLOWED i 4 l
- 1. Personnel assigned as design inspectors must complete the training / j qualification requirements for self-study, on-the-job training, and !
l Issue Date: MM A-20 1245 l l
tors Training and Qualification Journal. required training s gn Inspec-2. Inspectors who have been trained / qualified ander existi inspector ing journals qualification may transfer applicable ng sections regional 7 of th i e r exist-to the Reactor Design Inspectors Qualification Journal. Training and 3. At the discretion of QAB management, working to complete or have completed their trainin / inspectors who g qualification under self existing regional inspector journals study, may transfer propriate ap \ on-the-job training, and required training courses t the Reactor Design Inspector o D. TIME LIMITATIONS FOR COMPLETING TRAININGTrainin Required General Training and Technicalourses. Training C personnel and new assignees are required to complet All newly hired activities assignment. 1988. or pass equivalency examination e the (s) within required the fi training The corresponding time limit for current inspectors rst 24 months of anuary is J s k 1245 21
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APPENDIX B l l IE TRAINING AND QUALIFICATION JOURNAL j l A. PURPOSE. To establish a method of conducting and documenting successftil completion { of the training requirements set forth in this manual chapter. l B. BACKGROUND d
~The IE Training and Qualification Journal (IE Journal) is designed to ensure j that a uniform method of conducting and documenting training is being fol-lowed for all inspectors.
The IE Journal establishes the minimum training requirements that must be met for all required general and formal training courses listed in R Appendix A and serves as a guide for development of other training and R qualification journals'(i.e., regional and vendor journals). R
, C. BASIC REQUIREMENTS The IE Journal must be used to conduct and document training activities for R all inspectors.
The Technical Training Center (TTC) is responsible for developing and main-taining the-IE Journal. Each regional office is responsible for developing and maintaining its Regional Training and Qualification Journal and noting completion of the regional journal in each inspector's personnel record. The TTC, Vendor Program Branch, and regions will develop and make available R applicable journals according to the following schedule: ; Regional / Design / Title IE Journal Vendor Journal R Radiological Safety Inspectors 07/01/83 01/01/84 Reactor Operations, Resident and 04/01/83 10/01/83 Region-Based Project Inspectors Reactor Construction, Resident 07/01/83 01/01/84 '
. Inspectors ,
Reactor Engineering Support 09/01/83 01/01/84 t Inspectors Safeguards Inspectors 09/01/83 01/01/84 Vendor Inspectors 09/01/83 07/01/85 R Emergency Preparedness Inspectors 09/01/83 01/01/84 Reactor Design Inspectors 09/01/83 01/15/86 R Issue Date: 3 /l M B-1 1245
'l 120905063635 1 iMU U S NRC I E-DI V 0F INSPECTION PROGRAMS .
D IVISION DIRECTOR E WS- 360 DC 20555 W ASHI t4 T ON l an+. t.
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- i i *' % UNITED STATES
( 3( ! NUCLEAR REGULATORY COMMISSION OFFICE Washington, OF INSPECTION AND ENFORCEMENT ( s....../ D.C. 20555 INSPECTION AND ENFORCEMENT MANUAL d DI INSPECTION PROCEDURE 94300 STATUS OF PLANT READINESS FOR AN OPERATING L s PROGRAM APPLICABILITY: 2512, 2513, and 2514 94300-01 OBJECTIVES 01.01 Provide a status of the inspection program and findings. 01.02 Provide a summary status of preoperational testing and iden incomplete system acceptance and testing by the licensee. 01.03 identify areas where construction is incomplete. Provide a su 01.04 Provide an evaluation of the licensee's management readiness to perform QA activities during operation of the plant (reference Exhibit 2). 01.05 Provide a status of open items and their significance (specific milestones). 94300-02 REQUIREMENTS 02.01 90-Day Status Reoort. issuance of the operating license, the regional office will prepar tus report using the format of Exhibit 1. The status report will be trans-Office of Nuclear Reactor Regulation (NRR) with a c Office of Inspection and Enforcement (IE). , This memorandum will include the region's date evaluation as to whether or not the published fuel 'oading is realistic licensee. in terms The status of the work remaining to be completed by the report priate: will address the following areas, at appro-
- a. Inspection Procram. Review requireo oy MC 2512, 2513, the status and findings of ir,spections i inspection areas and the reason (s) for the incompletion.and 2514, a
- b. Enforcement Items.
Identify any violation for which corrective action has not oeen completed and all unresolved items and their status. Issue Date: 02/14/86
- c. Testing Programs. Identi fy Category I-III preoperational testing committed to in the FSAR that is incomplete, startup tests not yet '
developed and'their statu's, and list system performance deficiencies and plans for correction.
- d. Cons'truction Status. Define systems for which construction is not completed, list any system or significant component not formally accepted by the licensee, and list items from the construction punchlist which could offset the safe startup and operation of the plant.
02.02 Status Report Update. The 90-day status report will be updated every four to six weeks until one month before scheduled fuel loading. 02.03 30-Day Status Report. Approximately 30 days before the operating license is scheduled to be issued, the regional office will prepare a sta-tus report using the format shown in Exhibit 2. The region will transmit the status report by memorandum to the Director of NRR with a copy to the Director of IE. This memorandum will include the results of the region's inspection efforts; items that remain to be completed, with appropriate milestones; a statement concerning the implementation of the licensee's QA program; and the region's recommendations for issuance of an operating license. Items remaining to be completed and their impact on the proposed issue of the operating license will be listed by completion milestones and identified in separate enclosures. Each item should be written with suffi-cient detail provided so that the material may be directly incorporated into the license. Sufficient detail should also be provided to support the rationale for incorporation into the license. Enclosures will address the following milestones as appropriate. t
^
- a. Items to be Completed Before Fuel Loading.
- b. Items to be Completed Before Initial Criticality,
- c. Items to be Completed Prior to Exceeding 5% Rated inermal Power.
- d. Items to be Completed Prior to Achieving Full Power Operation.
94300-03 GUIDANCE 03.01 General Guidance. Conditions for issuance of an operating license are defined in 10 CFR 50.57. Any items that could affect the issuance of an operating license must be identified to NRR directly with a copy to IE. 03.02 Specific Guidance
- a. 90-0ay Status Report 02.01. The status report issued 90 deys before the scheduled fuel loading date may be fairly general in topic iden-tification. It is intended to present a general scope of the status of construction completion, preoperational testing, and the inspec-tion program. It is the firsi identification of overall facility status and provides the initial Iist for tracking open items as well as identification of any special problem areas. The region uses the information contained in this report to comment on the feasibility of the licensee's schedule for fuel loading.
Issue Date 02/14/86 94300 j j
W '
- b. Status' Report Update 02.02. ' Past experience has indicated that the C);
1icensee's scheduled. fuel' 1oading date is generally. optimistic. When there isi a large variance in' the scheduled fuel loading date -
. and the region's estimated fuel loading date, it may be preferable to update. the status report on a 6-week basis. or. longer, depending on the variance. As the licensee gets closer to the fuel loading date, the issue frequency of the report should increase and it should become more specific with emphasis placed on impact assess-ment. If appropriate, the listing of open items- also should be discussed with the licensee on a continuing basis.
'c . 30-0ay Status Report 02.03. The 30-day report should categorize the remaining. open items by the milestone at which they must.be comple-ted. To arrive at this milestone categorization, the proposed tech-nical specifications may be used as guidance. Open items must be resolved for any. system or component, prior to the time the facility technical specifications requires 'it to be operable. Categories'of open items are to be considered only as regional recommendations until they are endorsed by the operating license. In those situa-tions where the list of open items is long and/or the fuel loading date is delayed after the the 30-day report is issued, the region should consider issuing a' final memorandum a few days before the anticipated issuance of the operating license. If the region be- 3 lieves - that issuance of the 30-day reper t is premature based on plant circumstances, the report. can be delayed; however, status report updates should continue as stated in section 02.02.
END !
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I i i l l I 94300 3-Issue Date: 02/14/86 4
j- 'W j EXHIBfT 1 EXAMPLE FORMAT FOR 90-DAY STATUS REPORT MEMORANDUM FOR: Robert Bernero, Director BWR Licensing Division, NRR FROM: Charles.C. Norelius, Director: Division of Reactor Projects, Region III
SUBJECT:
CLEVELAND ELECTRIC ILLUMINATING, PERRY UNIT 1 DOCKET ~NO. 50-440, STATUS OF FACILITY COMPLETION 1 This memorandum is forwarded to provide you information on the preparedness for licensing 'of Perry Unit 1. Enclosures 1 through 4 include items re-quiring inspection and resolution before a finding of readiness for opera-tion can be endorsed by Region III. The categories used are consistent " with those used by the applicant. Cleveland Electric Illuminating esti-mates a fuel load date . of early November 1985. Region : III considers December 1985 as a realistic, yet optimistic, time frame for a licensing decision, contingent upon satisfactory resolution of the issues presented
'in the enclosures to-this memo.
If you have any questions concerning this' matter, please contact me or Mr. R. C. Knop of my staff. Charles C. Norelius, Director Division of Reactor Projects cc: J. Taylor, IE
Enclosures:
- 1. Open Items Including Enforcercent and Unresolved Items ;
- 2. Preoperational and Acceptance Testing Status -1
- 3. Construction Status l
- 4. Status of Inspections Required by MC 2512, MC 2513 and MC 2514 (Summary) ;
(For each item in the above enclosures, the expected or required completion date and an assessment of the significance, should be included.) El-1 Issue Date: 02/10/86
- - - - _ _ - - - - - - J
.W-STATUS OF PLANT READINESS EXHIBIT 2 94300 V EXAMPLE FORMAT FOR 30-DAY STATUS REPORT MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM: J. Nelson Grace, Regional Administrator
SUBJECT:
DUKE POWER COMPANY, CATAWBA UNIT 1, DOCKET NO. 50-413, STATUS OF FACILITY COMPLETION Based on the results of our. inspection efforts in implementing the pre-scribed NRC inspection program and other related inspection activities, we- 3 have determined that construction and preoperational testing of Catawba Unit 1 Nuclear Station have been completed in accordance -with the FSAR, ' other docketed commitments, and regulatory requirements, with the excep-indicated in the enclosures. Remaining construction, tion of items ' testing, and inspection items identified in the enclosures have been categorized by recommended completion milestones. As part of our inspection efforts, we have reviewed the licensee's prepara-tions for-implementation of the Quality Assurance Program for Operations. We have found that an organization and procedures are in place to give reasonable assurance that the licensee's Quality Assurance Program
-(Chapter 17 of the FSAR), which was reviewed by the Office of Inspection !
and Enforcement, can be adequately implemented. We recommend a full power license be issued, as conditioned by the items listed in the attached enclosures. 1 J. Nelson Grace Regional Administrator cc: J. Taylor, IE
Enclosures:
., (A separate enclosure should be included for each of the following comple-tion milestones. An assessment of significance should be included for each item.) ,
- 1. Items to be Completed Before Fuel Loading
- 2. Items to be Completed Before Initial Criticality
- 3. Items to be Completed Prior to Exceeding 5% Rated -
Thermal Power
- 4. Items to be Completed Prior to Achieving Full Power Operation ,
Issue Date: 02/14/86 _E2-1
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120555104211 US NR C 1 IMU IE-CIV 0F CHIEF CAT SECINSPECTION PROGRAMS M PERANICH CWS-312A WASHINGTON CC 2C555 4 l l
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APR 11 1983 Oceket Nos. 50-445 \ and 50-446 , Texas Utilities Generating Company ATTN: .Mr. R. J. Gary, Executive Vice President {
)
*, and General Manager 2001 Bryan Tower !
Dallas, Texas 75201 ' l Gentlemen:
SUBJECT:
Construction Appraisal Inspection 50-445/8.3.-18,.50 446/83-12 This refers to the construction appraisal inspection conducted by the Office of ; Inspection and Enforcement (IE) on January 24 - February 4,1983 and February ' 14 - March 3,1983, at the Comanche Peak Steam Electric Station and your Dallas corporate office. The Construction Appraisal Team (CAT) was ecmposed of 1 1 members of IE 'and a number of consultants. The inspection covered construction activities authorized by NRC Construction.fermit CPPR-126/127. This inspection is the second of a series of construction appraisal inspections being planned by the Office of Inspection and Enforcement. The results cf i these inspections will be used to evaluate implementation of management. control of construction activities and the quality of ' construction at nuclear plants. i The enciesed report identifies the areas examined during the insoection. Within these areas, the effort consisted of detailed inspection of selected hardware subsequent to Quality Centrol inspections, a comprehensive review of ycur Quality Assurance Program, examination of procedures and records, cbserva-tien of work activities and interviews with management and other persenrel. ! Appendix A to this letter is an Executive Summary of the results of the ins;ec-tien and of conclusions reached by this Office. Except for the area of the heating, ventilation and air conditioning (HVAC) system, deficiencies noted in installed hardware did not indicate pervasive failures to meet construction .' installation requirements. In the HVAC system, a breakdown in work and cuality centrol was identified. NRC Region IV has discussed this matter with you ard it is our understanding that this matter received immediate action by you and your contractors to evaluate and correct these conditions. NRC Region IV will continue to pursue this issue with you. Prompt management attentien to the resoluticn of other detailed deficiencies identified during the inspection is needed. - I In centrast to the HVAC system, the NRC CAT inspectors found few deficiencies in its inspection of safety system piping. ASME Code radiographs for this piping and samples inspected in this area showed evidence of good workmanship. 4 gyrfflo MF I s
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Texas Utilities Generating Company , Appendix.B to this letter contains a list of potehtial enforcement actions based on NRC CAT inspector observations. These have been referred.to-the Region IV Office for review and necessary action. In accordance with 10 CFR 2.790(a) a copy of this letter and'the enclosures will be placed in .the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter and submit written application to withhold information contained herein within 30 days of the date of this letter. Such applications must be consistent with the requirements of 10CFR2.790(b)(1). No reply to this letter is required at this time. NRC Region IV will address the potential enforcement findin will be addressed at that time. gs at a later date and any. required response Should you have any questions concerning this inspection, please contact us or the NRC Region IV Office. ' i Sincerely,
' ~
i a
' chard C. DeYoung, e fficeofInspectionandEnforcement
Enclosures:
- 1. Appendix A - Executive Summary
- 2. Appendix B - Potential Enforcement Findings
- 3. Inspection Report 50 445/83-18, 50-446/83-12 1
I s
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- k APPENDIX A EXECUTIVE
SUMMARY
An_ announced Construction Appraisal Team (CAT) inspection was performed at the Comanche Peak Steam Electric Station during the period January 24 - February 4, 1983 and February 14 - March 3,1983. OVERALL CONCLUSIONS It is the position of the Construction Appraisal Team that the results of this inspection indicate several construction program weaknesses. NRC Region IV has been rent. made aware of these weaknesses and is pursuing them with licensee manage-The licensee is initiating corrective action and/or continuing his t
' effort to resolve.the identified concerns. Prompt management attention to other deficiencies identified during the inspection is needed. In addition, the NRC CAT' team found few deficiencies in its inspection of safety system oicing and ASME . Code radiography for this piping. Inspection of samples in this area showed evidence of good workmanship.
The identified construction program weakriesses are as follows:
- 1. Results of the inspection indicated a breakdown in fabrication, instal-lation, and inspection in the heating, ventilation, and air conditioning (HVAC) systems.
- 2. A number of examples were identified of failure to meet criteria for '
separation of safety-related cables from mechanical structures and piping, an.d separation of redundant trains of safety systems. This was due in part to the licensee decision to not inspect installations for required separation until installation is essentially complete. The NRC CAT inspectors are concerned whether; (1) the inspections can be effectively conducted after installation, and (2) whether adequate correction actions can be accomplished after installation is completed. Correction of cable separation deficiencies at a later date could require repeating portions of system testing. (Note: This matter is being pursued with the licensee by Region IV, IE and NRR through site review and evaluation.) !
- 3. The licensee's quality assurance program did not ensure that certain hanger, support, electrical and mechanical equipment was installed to the latest design documents, and commensurately that an appropriate inspection was conducted to the latest design documents.
- a. Findings also indicate a number of instances where nonconforming j conditions were identified; however, various methods (e.g., punchlists, i inspection reports, verbal, and other infomal methods) were used to j address and resolve these nonconformances. These methods do not comply j with requirements to identify nonconfaming conditions and provide corrective actions to prevent recurrence. i
- 5. i The licensee's Quality Assurance audit program should have been more (
effective in cetecting and obtaining correction of deficiencies in j A-1
, ,. -. q
< c ',,
s
'l y safety-related work; such as those in the HVAC system, mechanical- '
L p < equipment, and electrical components. - J In: summary, the identified weaknesses require increased dedication by manage- i ment'at all levels to assure completed installations meet design requirements ! and that inspection documentation reflects.that the completed installations have i been adequately' inspected to the latest design document. AREAS INSPECTED AND RESULTS Electrical and Instrumentation Construction: Multiple instances of deviations from requirements were observec rclative to electrical and electrical / mechanical separation criteria. The review of procedures and records asso-ciated with electrical inspection activities indicated inadequate procedures to assure 'r reinspection of modified, previously accepted Class IE components. Mechanical Construction:- l Deviations from design requirements were observed in
- QC. accepted pipe supports / restraints, and HVAC installations. The existing ,
i program..for pipe support / restraints does not appear adequate-to properly verify that final as-built hardware. meets the final design requirement's. QC : inspections of the HVAC system support dimensional features were not performed l and duct / accessory inspection activity _ controls were not defined in procedures, i These deficiencies were reflected in the as-built conditions which did not ' conform to design requirements. --- Piping ~ installation conditions appeared adequate and extensive problems with ' mechanical equipment were not evident. Weldino/ Nondestructive Examination: The welding and NDE appears to be in i accoreance witn requirements except for the HVAC area. The HVAC welding activi- ' ties revealt significant deficiencies. Problems were identified with undersized welds in structural supports, inadequately trained inspection personnel, improperly qualified welding procedur.es, and inadequate welding documentation. The review of radiographic film of approximately 80 field welds, the review of NDE procedures, and the interview of NDE personnel, including demonstration of NDE technique, indicates an adequate NDE program for safety system piping in accordance with requirements. T . Civil and Structural Construction: Documentation reviewed in this area shewed : tnat.in general, work was performed in accordance with site procedural require-
-s ments and the licensee's comitments.
Procurement, Storace, and Material Traceability: Procurement, on-site stcrage in warenouses, ano material traceability were found to be acceptable. Samples ; of storage in outside lay-down areas and in-place storage of safety-related equipment revealed that some equipment was not protected as required. OC Insoector Effectiveness: Sixty-three quality control inspectors were interviewed. Instances of harrassment or intimidation were either properly resolved by .TUGCD or were referred to NRC Region IV to be included in an ongoing investigation. Interviews and certification reviews revealed that scme A-2 __ _._.._L _ _ _ _ _ - . _ - - _ _ _ - - _ - _ - _ _ -
i '. 'o , . inspectors have been certified withcut the required combination of education and experience specified by ANSI N45.2.5,1978. Interviews and document reviews revealed that individuals not certified as Level II were evaluating the validity and acceptability of final inspections contrary to the requirements of ANSI N45.2.6 as committed in the FSAR. Quality Assurance: The licensee's quality assurance program should have been more effective in monitoring and controlling safety-related activities, as exemplified by NRC CAT identified deficiencies in the HVAC-and electrical 1 separation areas.
~0esien Chance Controls and Corrective Action Systems: In the area of certain j nangers, supports, electrical ano mecnanical equipment, the licensee's program ]
during construction has lacked adequate controls to ensure information trans- j mitted from the design organization was provided to the quality control organi- 1 zation for use in perfcrming timely QC inspections. This fact contributed to the licensee's inabiljty to have an adequate program in-place at the time of this inspection to ensure that field installations were constructed to the , latest design document and that an appropriate quality inspection was com-pleted. In addition, .the large number (approximately 70,000 CMCs and 15,000 { DCAs) of design change documents contributed to the difficulty in determining i whether the " final" installation was in accordance with the " final" design. There were instances where nonconformances-were identified, but various methods (seme informal) were used to address and resolve these nonconformances rather than the method specified by site procedures. Evidence of appropriate correc-4 tive action and technical justification could not be determined in some cases. 9 A-3
A .' : . i, '
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APPENDIX B p0TENTIAL ENFORCEMENT FINDINGS As a result of the Construction Appraisal Team (CAT) inspection of January 24 - February 4,1983 and February 14'- March 3,1983, the following items have been referred to NRC Region IV as potential enforcement findings (Section references are to the detailed portion of the Inspection Report).
~
~
Electrical and Instrumentation Construction
- 1. Contrary to 10 CFR-50, Appendix B, Criterion X and FSAR Section 17.1.10, certain inspection activities were not executed to verify installation conformance with procedures including cable spacing in trays,. cable bend i radii, cable fill, cable supports and tray installat, ion hardware (Sections
.II.B.1.a. b, d, and II.B.4.b(1))..
- 2. Contrary to 10 CFR 50, Appendix B, Criterion XVI and FSAR Section 17.1.16, the established inspection program did not provide adequate controls to assure that deviations from electrical and electrical / mechanical separa- ;
tion criteria as defined in the FSAR-were promptly identified and cor- ' rected (Sections II.B.1.f. II.B.4.a and II.B.4.b(2)).
- 3. Contrary to 10 CFR 50, Appendix B, Criterion V, FSAR Section 17.1.5, and IEEE Standard 450, procedures to implement inspection activities relative to certain aspects of battery maintenance have not been developed or implemented'(Section II.B.3.c,.).
Mechanical Construction
- 1. Contrary to 10 CFR 50, Appendix B, Criterion.V, FSAR.Section 17.1.5, and QI-QAP-11.1-28,'certain QC accepted ASME pipe supports / restraints are not installed in accordance with the design document to which the pipe supports / restraints were inspected (Section III.B.2).
- 2. Contrary to 10 CFR 50, Appendix B, Criteria X and XVII, and FSAR 1 Sections 17.1.10 and 17.1.17, an inspection program has not been established to verify and document installation conformance to drawing i requirements in regard to pipe supports / restraints and mechanical equip- i ment installations (Section III.B.2 and 3).
- 3. Contrary to 10 CFR 50, Appendix B, Criteria V and X, and FSAR Sections 17.1.5 and 17.1.10, installed and QC accepted heating ventilation and air conditioning (HVAC) duct, supports and equipment do not conform to design ;
requirements. In addition, inspection procedures have not been established l or executed to verify conformance of HVAC supports to design drawings - (Section III.B.4 ). i B-1 a 1 1
-.r. m .----...- - .
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c . g l Welding and Nondestructive Examination - 1 Contrary to 10 CFR 50, Appendix B, Criterion IX and FSAR Section 17.1.9, certain special processes relative to the HVAC system were not adecuately controlled, including improperly qualified procedures; improperly qualified inspectors; improper certification of NDE personnel (Section IV.B.3).
' Civil and Structural Construction
, Contrary to 10 CFR 50, Appendix B, Criterion V and FSAR Section 15.1.5, civil
- construction test procedures were inadequate to ensure that mixer uniformity tests as required by the ASME-ACI-359 Code were performed at the prescribed ;
frequency (Section V.B.2). ' i Procurement, Storace and Material Traceability Contrary to 10 CFR 50, Appendix B, Criterion XIII, FSAR Section 17.1.13, CP-0AP-8.1, Rev. 5, CP-CPM-8.1, Rev. 1, and MCP-10, Rev. 7, storage of certain safety-related equipment in outside lay-down areas and installed in the plant was not properly controlled (Section VI.B.2). Quality Control Inscector Effectiveness
- 1. Contrary to 10 CFR 50, Appendix B, Cniterion II and FSAR Section 3.8, individuals were certified to levels of capability without the'reouisite experience described in Regulatory Guide 1.58 (Section VII.B.2.a.(2)).
1
- 2. Contrary to 10 CFR 50, Appendix B, Criterion X and FSAR Section 3.8, inspection records were prepared and accepted by L-I inspectors as the ,
" inspector of record" rather than the required' L-II " inspector of record" '
required by ANSI N45.2.6 (Section VII.B.2.b(1)). Cuality Assurance l'
- 1. Contrary to 10 CFR 50, Appendix B, Criterion XVIII and FSAR Section i 17.1.18, OA audits have not been conducted at a frequency or at sufficient depth to identify and correct significant problems in various areas of construction; i.e., HVAC and electrical separation (Section ?
VIII.B.2.b.(5)(c)). i
- 2. Contrary to 10 CFR 50, Appendix 8, Critorion XVI and FSAR Section 17.1.16, audit findings related to maintenance instructions identified in 1979, 1981 and 1982 were not resolved in a timely manner (Section VIII.B.2.b.(5)(c)).
- 3. Contrary to 10 CFR 50, Appendix B, Criterion VI and FSAR Section 17.1.6, drawings with out-of-date revisions and drawings with damaged or unread-l able title blocks were present in construction work areas (Section VIII.B.2.e.).
- l B-2 L-_ _- _
,3 ,.
i l Desien Chance Controls and Corrective Action Systems
.1.
Contrary to 10 CFR 50, Appendix B, Criterion V and FSAR Section 17.1.5, i procedures were not adequate to assure' design changes were properly transmitted to the Quality Control. organization such that an appropriate inspection could be performed (Sections IX.B.4,1.b and. IX.B.1.c). 2.. Contrary to 10 CFR 50, Appendix B, Criteria II and ~XV, and FSAR Sections
' _17.1.2 and 17.1.15, nonconforming conditions identifiec relative to some safety-related hardware installations are not being properly documented, evaluated, and dispositioned through the Corrective Action Program.
(Section III.B 8, IV.B.2 and IX.B.2)). . O e aume . I B-3
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1
7 , UNITED STATES NUCLEAR R'EGULATORY COMMISSSION OFFICE OF INSPECTION AND ENFORCEMENT DIVISION OF QUALITY ASSURANCE, SAFEGUARDS, AND INSPECTION PROGRAMS REACTOR CONSTRUCTION PROGRAMS BRANCH Report No.: 50-445/83-18, 50-446/83-12 Cocket Nos.: 50-445, 50-446 Licensee: Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 - Facility Name: C0manche Peak Steam Electric Station Units 1 and 2 Inspection At: Comanche Peak Steam Electric Station, Glen Rose, Texas and Texas Utilities Generating Company, Dallas, Texas Inspection Conducted: January 24 - February 4,1983 and February 14 - March 3,1983 Inspectors: # Av A. S. 5eacn, Sr. Reactor Construction [N Date Signeo
'/ Engineer Tea Leader) ff , A . 5 d P. I. Kesnisnian, Sr. Reactor Construction D' ate /Signea r
Engiln Sm G. C. Gower, Sr. Reactor Construction 4-8-ta Date Signea Engin e
/ c
,hW.A.Hanson,IspectionSpecialist fd Y?fN Date Signeo kt . kReact r Construction Engineer N. B. e 4-9-8B \
Date Signeo J ? F- ' Nff/ H. W. Phillips, Reactor Construction
,[ Engineer
/
~ Date Signeo Consultants: R. M. Compton, D.C. Ford, E. Y. Martindale, and F. A. Pimentel Approved By:' 4' +' b R. F. Heisnman, Chief Date 51gneo Reactor Construction Programs Branch
.} ()k 10g
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i 1 k k 4 1 q 1 TABLE OF CONTENTS I TOPIC
.SECTION l INSPECTION SCOPE AND OBJECTIVES...................................... I ELECTRICAL'AND INSTRUMENTATION CONSTRUCTION......................... II MECHANICAL CONSTRUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I. II ..............
WELDING AND NONDESTRUCTIVE EXAMINATION.............................. ' IV CIVIL AND STRUCTURAL C0tiSTRUCTION. . . . . . . . . . . . . . . . . . . . . . .7. . . . . . . . . . . . PROCUREMENT, STORAGE AND MATERI AL TRACEABILITY. . . . . . . . . . . . . . . . . . . . . . . . VI
'QC INSPECTOR EFFECTIVENESS............. ............................. 7II 1
QUALITY ASSURANCE .................................................. VIII CESIGN CHANGE CONTROLS AND CORRECTIVE ACTION SYSTEMS................ IX A7.TACHMENT A - PERSONS CONTACTED AND DOCUMENTS REVIEWED l i 1 e
0 I. INSPECTION SCCPE AND OBJECTIVES ; The cbjective of this inspection was to evaluate the adecuacy of construc-tion at the Comanche Peak Steam Electric Station (CPSES). This objective l was accomplished through review of the construction prcgram, the quality assurance program, and the design change program. with emphasis on the installed hardware in the field. i Within the areas examined, the inspection consisted of a detailed examina-tion of selected hardware' subsequent to licensee quality control inspec-
- tions, a selective examination of procedures and representath1 records, and observation of in-process work. Interviewt were conducted witn designated site managers, quality control inspection personnel, t:.3 craft personnel on a routine basis.
For each of the areas inspected, the following was determineo: Is the hardware installed in accordance with the approved design? ! Do individuals with assigned responsibilities in a specific area understand their designated responsibilities? Are quality verifications performed during the construction process with applicable hold points and are quality verifications conducted to adequate inspection acceptance criteria? Do personnel involved with Quality Assurance / Quality Control have the organizational freedom to perform tneir tasks without harassment or intimidation? Are management controls established and implemented to control activities in the subject area? The areas in which a selected sampling inspection was conduc ed include: Electrical and Instrumentation Construction Mechanical Construction
. Welding and Nondestructive Examination Civil and Structural Construction j Procurement, Storage and Material Tracesh.ility
. QC Inspector Effectiveness l l
. Quality Assurance i Design Change Controls and Corrective Action Systems I-1 l
l
4 II. ELECTRICAL AND INSTRUMENTATION C0tGTRUCTION A. OBJECTIVE The objective of the assessment in this area was to determine whether safety-related electrical and instrumentation components were being installed and inspected in accordance with approved engineering designs, regulatory requirements, and the applicant's FSAR commitments. Additional objectives were to determine whether procedures, instructions, and drawings used to accomplish construction activities were adequate and whether quality-related records accurately reflect the completed work and the inspected activities. B. DISCUSSION
- 1. Electrical Cable Installation The NRC Construction Appraisal Team (CAT) inspectors selected a sample of installed electrical cable runs that had been inspected by Quality Control (QC) inspectors. The sample includet! power, control and instrument cables. For each of these cables, physical inspection of cable was made to ascertain compliance with applicable design and installation criteria' relative to size, type, location / routing, bend radius.. protection, separation, identification, pnysical loading and supports.
The following power cables, totaling approximately 1,800 feet, were ' selected from different systems, electrical trains, physical locations and si:es. Cable No. Tyoe From o T,c E01001618
- 1/c 750 MCM W-108 EPSWES01-02 EPMCEB07-06 EG100387A 1/c 750 MCM W-208 EPSWE504-07 EPMCEB04-01 E0100a10 3/c 6 AWG W-120 EPMCEB01-09 TBXCSAPSA01 EG100037 1/c 4/o AWG W-206 EPSWEA02-11 CP1CTAPCSO4 AG100385 4/o TRIPLEX W-812 EPSWEB04-09 Penetration E11 The following instrument cables totaling approximately 1,000 feet were selected and inspected to ccnfirm the previously stated installation attributes.
Cable No. Tyoe From lo, o E0135235 1 SHD Td Pair Cont Spy Pep 02 BOP Intt PNL 01 16 AWG W-165 EG 135262 W-270 Elec Penetration. Term Box E-14 for ILT4781 A sampling of approximately 1,200 feet of installed electrical control cable was selected from various areas of the plant. The inspection was performed by examination of cable segments within selected cable tray sections installed in the Safeguarcs, Auxiliary, Control and Containment buildings. It should be noted that this method of sampling did not confim the specific routing of cables. II-1
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7 x ., .-
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s " ,A detailed explanation of this matter is covered fi ,the following paragraphs under Cable Identification. The NRC CAT dnspectors observed approximately 500 feet.of in-process catile iull activities. This figure represents three control cable pulls, routedjin varicus are.as of the plant. These were cable, numbers E0021928 N/M, E0117573 and.E0221888. O - N t 3.f; 9 s ., The observed in-pres 6s Mle pd1, activities were performed in" accordance with procadusi requirements. y
, a. Cable Scacino in Tray The design ba;is specifies that ampacities for cable instal-1.ed in trays rdquiis derating based on their installed configura-tion. Gibbs & tiill' Specification 2323-ES-100, Rev. 2, Section i 1 4.2.1.4, states;in part, " Power cables run in cable tray shall i j have maintained cable spacing whert/so indicated in the cable and raceway schedule and cable pull a rds,eMaintained spacingi l between cables (edge to edge) shaW6e' a minimum of one quater !
of the diameter of the largest cable".
. 4 Texas Utilities Generating Company (TUGCO) procedurd QI-QP-11.3-26.6, Section3.1.4,statesinpart,"am15imoN >
separation of one quarter of the cable diameter shall be rain-tained between siderail of cable tray ard. atircent cib!e". Thh - NRC CAT inspectors noted the following d ble irays contained improperly spaced medium voltage pewer tables) , g j ., i Tray No. L,' \'
,, i s 3, \ ,t T12GABF27 'i '2*t ,% \' '
' 4)"k T120ABB30 E T123ABP71 f i
/ \$ 4 T11GEA323
?_ l T120ABB10 ' "
l j' 3 T120SBDC6 $ s % l T12GABF14 r> , l T11GSAB06 . p p i- ;
- b. Cable Bend Radius '
4
, s Gibbs & Hill specification E323-ES-100, Rev. 2, Section 4.2.2.3, l states, " Cables shall be trained so,that the minimum bending ]
radius for pertinent plant c/atie training is not exceeded". TUGC0 Procedure QI-QP-11.3-26.6', Revision 16. Section 3.1.1, ! states in part, "The QC inspedor shaW determine the minimum ' bend radius" for the cable being installed or removed, and shall include minimum bend radius inspection during the surveillance. : u f t i
.(
II-2 ,
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4 3
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a y o The NRC CAT inspectors noted electrical cables that were - A s installed with following less than ellowable minimum bend radius in the locations:
' {w ..
Cable Fo. or Tyce Location y E01205:2 Battery Charger No. BCIED1 t o EG102592 1 ' Battery Charger No. BCIED2.2
, (B) Train Type W-216 T12GCBF82 E010?534 T120CB031, T12030560 1/c Type W-206 T11GEAB37, C11G05112 4 c. Able Tray F'ill The Comanche Peak Station (CPSES) FSAR, Section 8.3.3.1, states a
in part, " Cable tray fill criteria generally limit the summation of the cross-sectional areas of control. cables and power cables to a maximum of 40 and 30 percent, respectively, of the useable IL\ cross section of the tray. However, these percentages may be exceeded provided the following conditions are satisfied: (1) Cables do not extend above the side rsils of the cable tray. (2) For power cable the thennal rating of the cable is not
., exceeded, t
(3) Cable tray support design is adequate..."
" During the inspection of installed electrical cable, the NRC CAT inspectors 'dentified cables that extended above the side rails of Cable Tray Nos. T12GSBG22 and T13GACD14 5 d. Cable Succorts Gibbs & Hill Specification 2323-FS-100, page 4-5, paragraph (b.)
states in part, "Where supportr, for cables in vertical cable tray and conduit are not shown on tt.e drawings, top-of-riser supports... and additional supports if required for long vertical Q risers shall be provided by the contractor to meet the follcwing g requirements: (1) Supports shall be Kellem's mesh crips or engineer approved
, equal...
(2) One cable support shall be provided at the top of vertical haceway or as close to'the top as practical. A support shall
$provided for each additional interval as spe ified in the tallowing table: ..."
The NRC CAT inspectors identified several runs of 750 mcm 6.9 kV SHLD ct.ble installed in vertical riser Tray No. T11GSAB01 and
', TIMT/.st5 of over 100 feet, without specified supports.
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- e. Cable Identification i
i The CPSES FSAR requires that all Class IE cables be identified by a nine alphanumeric character tag. Gibbs & Hill Specification 2323-ES-100 further requires that identification tags be placed at the termination point of the cable; for example, in an equipment housing or at a terminal box. During the inspection of the selected sample of Class 1E control cables, it became evident that without a more liberal use of
- identification tags, it would be extremely difficult to trace the
. physical routing of the samples selected. This was due to the quantity of cable installed in the tray, which in some cases completely buried the selected cables for extended distances.
It was decided by the NRC CAT inspectors that the control cable sample would be made by an examination of cable installed in selected tray segments from various areas of the plant. While this method of sampling could 'not confirm the total routing of control cables, it did provide adequate assurance that other quality attributes of cable installation had been met. Discussions with the co'ntractors electrical OC group revealed that further difficulties with cable identification are en-countered when installed class 1E control cables sustain in-sulation damage. The repair procedure requires that the cable to be repaired or replaced must be identified. To accomplish this, the QC inspector may often attempt to trace the cable to its termination point by the " hand-over-hand" method. Where this is not possible, extensive evaluation of raceway schedules are made through the process of elimination to determine which of the cables contained in that tray are of the type, size and reel footage as the one which is damaged. This process has been found to be time-conLuming and not always accurate. An example was given of one damaged cable which was identified and pulled out, only to find that it was not the cable it was thought to be. Although current cable identification methods are in conformance with applicant comitments, the practice of placing r identification tags only at cable ends has hindered the installation and inspection effort.
- f. Electrical Secaration The CPSES FSAR, Section 8.3.1.4, states in part, "The minimum separation distance between redundant Class 1E equipment and circuits internal to the main control boards is maintained at six inches..."
During the inscection of cable terminations within control boards, the flRC CAT inspectors icentified multiple instances j where the six inch separation between redundant train wiring had i not been maintained. Some of these appeared to have been caused ! by improper training of cables within the panel, others were a II-4
result of the location of the terminal point on a device and its proximity to a device of the redundant train. The electrical QC organization has documented many of these conditions by use of the Nonconformance Report (NCR)or as a punchlist item. However, there appear to be instances which have not been addressed and/or corrected. Gibbs & Hill Specification 2323-ES-100, Section 4.2.2.3, states in part, "In the event that the above separation distances are not maintained, barriers shall be installed between redundant Class 1E wiring. For main control boards, Service Air Company stainless steel flexible conduit type SS63 shall be used as.a ba rrier. " The NRC CAT inspectors observed two installed barriers whose configuration provided inadequate protection between redundant wiring as well as barriers installed in the main control boards of a type other than Service Air Company stainless steel flexible conduit type 5563 as required. *
- 2. Electrical Cable Termination An inspection of a selected sample of electrical cable end terminations was performed to determine ccmpliance with the applicable requirements. Inspection attributes included verification of proper lug material and size, proper mounting hardware, accurate location and identification of terminal blocks and points, proper crimp and crimping tool, verification of the calibration status of tool and instruments used, and proper terminating of cable conductors. The NRC CAT inspectors inspected cable end terminations on the following cables.
Cable No. Tyoe Location EG112182 7/c CP1-ECPRTC-05 EG016018 9/c CP1-ECPRTC-05 EG127647 8/c CP1-ECPRTC-05 E0109846 9/c CP1-ECPRCR-03
- E0112867 12/c CP1-ECPRCR-03 E0109811 2/c CP1-ECPRCR-03 E0110070 12/c CP1-ECPRPR-03 E0139235 12/c CPI-ECPRTC-01 A0118460 2/c CPI-ECPRTC-01 A0123795 9/c CP1-ECPRTC-01 EG113353 12/c CPX-ECPRCS-01 <
EG113355 12/c CPX-ECPRCS-01 . EG1130904 2/c CPX-ECPRCB-01 E0113348 12/c CPX-ECPRCB-01 A0016325 2/c CPX-ECPRCS-01 E0113331 12/c CPX-ECPRCB-01 l E0138882 3/c CPX-ECPRCS-01 EG113361 7/c CP1-EPMCEB-02 II-5
- _ _ _. . M M ** 1es *******W8*N P J *"*
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y , l EG113367- 7/c.'[ CP1-EPMCEB-02 EG113368 2/c ' CP1-EPMCEB-02 1 EG113288- 2/c CP1-EPMCES-02 1 EG100474 3/c ' CPI-EPMCEB-02 E0113364 7/c l ! CP1-EPMCEB ! E0113365. 2/c CP1-EPMCEB '! E0113366 2/c: CP1-EPMCEB-01 E01132B5- 2/c CP1-EPMCEB-01 4 E0100414 - 3/c. : CP1-EPMCEB-01 E0115077- 7/c CP1-EPMCEB.-09 E0113274 2/c CP1-EPMCEB-09 ' E0113542 _2/c CP1-EPMCEB-09 E0113865 2/c CP1-EPMCEB-09. .. i E0100890 3/c CP1-EPMCEB-09 , 3/c i E0125664 CP1-EPMCEB-09 EG100701 3/c CP1-EPMCEB EG109259 2/c CPI-EPMCEB-08 . E0106198 2/c CP1-EPMCEB-07 ' E0109253A 7/t - CP1-EPMCEB-07 E0132388 2/c IPT-2327 The'NRC CAT inspectors also observed the in-process termination of four Nuclear Instrument System (NIS) Triax connectors. These were completed in various channels of the Reactor Protection System (RPS) system as
, follows:
Cable No. Channel - EY140790 IV EB140711 III ER140509 I.
.EY140794 IV Two instancec of improperly term'inated conductors were noted in the following locations, t.,d were subsequently documented by OC personnel , on an NCR:
Cable No. Location A0123795 CP1-ECPRTC-01 TB4-94, 96 (Terminal lugs are not properly tightened) E013331 CPX-ECPRCB-01 (Insulation damage to green conductor at terminal point 56)
- 3. Electrical Ecuiement Installation A' sample of thirty-five pieces of installed electrical equipment were inspected. Samples were selected from both Unit 1 and 2, based on system function and safety classification. Components selected included the follcwing:
II-6
..- .. . l i i
- a. Motors -
The installation of four motors and associated hardware was inspected for such items as ' location, anchoring, grounding, identification and protection. Motor Identification
, , Component Cooling Water Pump Motor No. CP1-CCAPCC-O1M RHR Pump Motor No. TBX-RHAPRH-01M RHR Pump Motor No. TBX-RHAPRH-02M Safety Injection Pump Motor No. TBX-51APSI-02M 3 During the inspection of these items, it was noted by the NRC CAT inspectors that in several instances the motor or pump had not been grounced. Discussions with the electrical QC group revealed that grounding was not regarded as a part of Class 1E equipment at CPSES and therefore does not receive QC inspection.
'The NRC CAT inspectors concluded that the installation activities i relative to the above electrical equipment were performed in accordance .vith procedur21 requirements. Grounding for motor or -
' pumo casings, which is required for personnel safety and protec-tion, had not been performed..in several instances.
Reinspection of electrical equipment is discussed in paragraph 8 of this section.
- b. penetrations -
The following installed containment penetration assemblies were inspected: Number Elevation, Feet 1E49 810 1E14 870 1E46 843 2E33 856' The location, type, mounting and identification were compared with the installation drawings. QC records associated with inspection of these items were also reviewed. Activities observed and documentation reviewed indicated werk perfomed in this area was in accordance with requirements.
- c. Motor Control Centers .
i The following 480 V motor control centers (MCCs) in the Auxiliary 1
, and Safeguards buildings were compared to installation drawings relative to location, mounting and identification:
1 II-7 w' i _ , _----m"
* * * * * * * * ~' *
**4*'
v .^ . MCC Identification No. 1EB3-2, CP1-EPMCEB-05 No. 1EB4-2 CP1-EPMCEB-06
.No . 2EB1-l' CP1-EPMCEB-01 The; installations reviewed indicated work was performed in accor-dance'with requirements.
- d. Switchaear The following 6.9KV switchgear was inspected and compared to installation drawings relative to location, mounting, and identification.
Switchcear Identification No. IEA1, CP1-EPSWEA-0 No. 1EA2, CP1-EPSWEA-02' No. 2EA1, CP2-EPSWEA-01 l No. 2EA2, CP2-EPSWEA-02 l Installatierr activities relative to these switchgear were per-famed in accordance with requirements. l e. Station Batteries The Unit'l 125V vital battery rocms were inspected, including the installed batteries, battery racks and associated equipment. The i location, mounting, and environmental control for installation I I No. BT-1EDI, CPI-EPBTED-01 and No. BT-1ED2, CPI-EPSBTED-02 were compared with applicable requirements and QC inspection records. During the inspection of these items, the NRC CAT inspectors identifed that there was a considerable amount of activity in the batte'ry rooms. This was due to preparation for relecation of the- !- vital battery cells so that rework of the _ seismic battery racks could be accomplished. The inspectors observed that although the batteries were charged and in a state of operation, there Were no signs posted to prohibit smoking or open flames. Additionally, concrete chipping activities in the wall above the batteries had left deposits of concrete on the cells themselves. Discussions with the electrical QC group revealed that the 125V batteries had been under the control of TUGC0 since 1979, and had been moved twice since initial installation. During these moves, responsibility for inspection of attributes associated with handling, mounting, protection, and re-energization was given to a contractors QC group. The NRC CAT inspectors observed the activities associated with relocation of the vital battery cells. Curing this activity, two cell casings were camaged and removed from service. 1 II-8 l- _ _ i
- , . : 3 ,
A review of records associated'with ma'intena'nce of the vital batteries was made to cssure that all attributes of the main-
.tenance program had been accomplished and. documented. Items such as cleanliness, cell voltages, specific gravity and electrolyte level had been inspected and documented on a regular basis.
However, the NRC CAT inspectors observed that.the CPSES.FSAR, in Section 8.3.2.1, under " Testing and Inspection," states in part,
" Periodic inspection and testing of DC systems are performed to-monitor the condition of.the equipment.to ensure reliable. '
operation... All maintenance and testing procedures and criteria i for replacement are in accordance with IEEE 450-1975, and Reg. Guide:1.129.. IEEE Standard 450-1975, Section 3.3.3 requires a yearly check and record'of: (1) Cell Condition (Detailed Visual Inspection) (2) Cell-to-Cell and Terminal Detail Connection Resistance-(3) Int.egrity of the Battery Racks . l The NRC CAT, inspectors found that the procedure used to perform- l surveillance of these station batteries (No. ELM-701, Rev. 0) did not implement the requirements for yearly inspection of. ' cell-to-cell detailed terminal resistance, nor was there docu-mented evidence that these attributes had been inspected or verified. -_ Discussions with the TUGC0 Electrical Maintenance Group revealed that the Electric 61 Maintenance Procedure No. ELM-715 was in the process of being issued to control activities associated with inspection of cell-to-cell detail terminal resistance performed to date. f.125 Volt DC System Equipment associated with the. operation of the 125V DC System was inspected to verify compliance with applicable specifications and drawings. The NRC CAT inspectors selected the follcwing sample of equipment. , Identification No.' Eoui; ment BC-1E01-1, CP1-EPBCED-01 ' Battery Charger BC-1ED3-1, CP1-EPBCED-05* Battery Charger BC-1ED2-1, CP1-EPBCED-02 Battery Charger BC-1E04-1. CP1-EPBCED-06* Battery Charger IVIEC-1 CPI-ECIVEC-01 Static Inverter IVIEC-2, CP1-ECIVEC-02 Static Inverter 59/1ED1 Overvoltage Relay 59/1ED2 Overvoltage Relay 270C/1ED1 Undervoltage Relay 27DC/1ED2 Undervoltage Relay 64/IED1 Ground Protection Relay 64/IED2 Ground Protecticn Relay IT-9
- . . . .: . n.-... ;_ . - - - - - . - - - - . . . - - . - - -
c . . 1 e . a
*These items were originally Unit 2 equipment transferred: !
'by, permanent Equipment Transfer (P.E.T.) to Unit 1
- Installation activities reviewed indicated work was performed in accordance with' requirements. >
- g. Emeroency Diesellenerator The electrical. aspects of the Unit 1 emergency diesel generator (A'and B), including control cabinet wiring, were inspected for
, location, mounting, separation, protection and identification. s
' -These reviewed aspects indicated work was performed in accordance
~with installation requirements.
h.. Motor Ooerated Valves A sample of four motor operated valves (MOVs') was selected and inspected for-items such as location, mounting; grounding,
' protection, and proper wiring. The MOVs selected were:
~
MOV Identification No. 1HV4776/28537 _ . . No. 10611/650 No.1HV558/BF270925 No. 1HV4709/16142
' Inspection of. work performed in this area indicated the work was performed in accordance with requirements.
- 4. Electrical Conduit and Cable Tray Installation
- a. Electrical Conduit The NRC CAT inspectors observed 86 runs of installeo electrical conduit, associated pull boxes, fittings, and the associated-conduit supports. Total footage of these conduit runs was !
approximately 1,800 feet. The inspection revealed several discrepancies in the area of electrical conduit installation, including many instances where covers to junction / pull boxes, and condulets were not installed as required. Discrepancies in the identification numbers between installed , conduits and the QC inspection reports in the QA vault were { discovered. Further discussion of this matter is found in J paragraph 7 of this section under procedure. Additionally, work ! performed may not have been inspecteo to the appropriate design
, document; specifically, conduit support installations. Further discussion of this matter is found in paragraph 8 of this section under Inspection procedures.
Relative to NIS conduit installation, the required separation from fluorescent light fixtures was not maintai.ned. The Cp5ES l II-10
r FSAR, Section 8.3.1.4, states in part, "all nuclear instrumentation system (NIS) cables are routed in conduit ! according to their channel assignment... Also, a minimum clear l air separation of two feet is maintained from conduit to electrical noise sources such as power and rod control cables."
.TUGC0 Procedure 01-QP-11.3-29.1, Rev. 8, Section 3.1.2, states, i in pat n "...a minimum separation of 2'-0" must be maintained between NIS conduit systems and fluorescent lighting fixtures and
. lighting system conduits except for conduits crossing at an angle of more than 15 degrees. The NRC CAT inspectors identified the following installed Class IE NIS conduits which do not maintain the required separation from fluorescent light fixtures. These r were as follows:
Conduit No. C16510045 - C16Y10039 JBIA-915Y C16Y10041 ' j
- b. Electrical Cable Tray Eight runs of installed cable-tray, comprising 134 tray segments with an aggregate length of about 1,600 feet, were inspected relative to support location, separation, protection and physical loading. Samples were selected from the Reactor, Auxiliary, Control and Safeguards buildings. A random inspection of an additional 500 feet of cable tray was also completed. -
(1) Cable Tray Attachments The NRC CAT inspectors observed several instances where cable tray segments were not bolted together or properly attaened ' to associated seismic supports. l These instances were identified during the inspection of the I following cable trays: Cable Tray No. ( j T13GRCLOS 1 T13GRCl.09 ' T13GCF019 ' T13GCF020 l T13GACE94 j (2) Cable Tray Seoaration . The NRC CAT inspectors identified instances of cable tray separation that did not meet the CpSES FSAR commitments. These instances reflect a conditions that exist in other areas of the plant. Examples of deviations from requirements were identified in the areas of redundant train separation, internal control panel wiring separation and electrical mechanical separation. II-11
1 q LThe NRC CAT. inspectors noted that actions taken to correct
. separation deficiencies have yet to be implemented. . It .-i s j
understood:that the use of cable tray covers and other acceptable .J j fire barriers will alleviate a number of these problems; however, there appear to be instances : particularly in the category of, electrical mechanical separation, which may not be correctable-without a significant amount of rework to installed components. The.CPSES FSAR, Section 8.3.1.4, states in part, "The cable and raceway separation criteria'are based on preservation of l 1
- independence.of redundant systems... Cables of redundant Class 1E circuits are run in separate cable trays, conduits, ducts and penetrations."
"The raceways of one train are separated from those of the other train by locating them in separate structures or on opposite sides cf large rooms or spaces. .Where this.is not possible, separation is maintained as described below, or by providing barriers. .The Class 1E cables are routed such that any sing e failure-in one train system does .not cause a failure in anot. tr train system."
The CPSES FSAR, Section 8.3.1.4,. continues: "In plant areas which are free from potentialhazards such as missiles, exter.1a' fires, and pipe whip, the minimum separation between redundant l cable trays is three feet between trays separated horizontally. l and five feet between tray separated vertically." The NRC CAT inspectors identified the following installed Class 1E cable tray segments which did not maintain the requireo separation between reduncant trains: Train "A" Train "B" T130ACG51 From T13GACZ79 T130ACG54 From T13GACZ71 T130ACG63 From T13GCF008 T120ABB23 From T23GACD85 T120ABA42 From T23GACD85 Gibbs & Hill Specification 2323-ES-100, Rev. 2, Section 4.3.2 ' states, "... cable tray shall not be placed within 6 inches of- , Class 1 or II piping or component welds unless otherwise approved by the owners field represe'ntative (additional allewance shall be made for pipe insulation). The separation for non-safety related and Class III piping and cable tray is to be a minimum of 1 inch from the cutside, of the pipe or insulation."
~
TUGC0 Procedure QI-QP-11.3-29.1, Rev. 8. Section 3.1.7, states in i part,'" Raceway and supports shall not be located within (6) inches of Class I or Class II piping welds or component welds..." Also, " Cable tray shall be separated from piping or piping insulation by a minimum of (1) inch." II-12 l-L ___ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
i
* ?. :
;eev 4
1 The NRC' CAT inspectors identified' the following installed Class . ! 1E cable tray segments which did not maintain required separation from piping or pipe insulation.. .
' Cable Tray'No.
T13GACE79 T13GACZ92 T130 SCC 77
.T1305CC78 I T1305CC79 T1305CC74 ,
T13GACE79 The NRC CAT inspectors discussed the above findings with the. I applicant's lead electrical. engineer, and learned that the ' applicant is aware of the problems. . The applicant is
' anticipating 'to perform rework where possible, if not, other measures will be evaluated.
NOTEi .NRC Region IV, IE and NRR personnel are meeting with the ) licensee at= the site during the week of April 4,1983, to further evaluate these and other electrical / mechanical i separation conditions. .__ (3) Cable Tray Identification f
' The CPSES FSAR, Section 8.3.1.3, requires that electrical raceway systems be physically. identified by a nine alpha-numeric character tag number and color code system, which is to identify whether or not the given raceway contains safety related cables.
The NRC CAT inspector examined the selected .umple of Class IE cable tray and conduit to verify that identification tags and color coding were present, and properly applied, relative J to location, caterials, and conformance with design drawings. All hardware inspected to these attributes satisfied the identification requirements.
- 5. Instrumentation The NRC CAT inspectors selected a sample of instrumentation components which monitor process variables comprising the Reactor Protection System (RPS), Component Cooling System (CCS), and the Engineered Safety Features Actuation System (ESFAS).
Instrument components were reviewed to determine if installations were accomplished in accordance with design drawings, applicable codes and specifications. Items such as location, mounting, identi-fication and protection were compared with installation drawings for the following components: II-13
. . . l=_ -.
. . . - --- - ,. I
Pressure Transmitter Flow Transmitters 1 PT-544 1 FT-2464 A 1 PT-2138 1 FT-2466 B 1 PT-535 1 FT-2463 A 1 PT-534 1 FT-424 1 PT-4252 1 FT-426 1 FT-2465B 1 FT-414
, Pressure Switch Flow Indicating Switch 1 PS-4519 1 FIS-4650 Level Indicating Switch ,
1 LIS-4754 . The NRC CAT inspectors observed approximately 700 feet of_ installed instrument tubing, supports, and associated hardware. Tubing was
. examined to verify such items as, proper material, slope, mounting, separation, and color coding. The inspectors also examined inspec-tion records associated with the installation of. tubing and tuoing supports. -
During the inspection of instrument tubing, the NRC CAT inspectors noted that in several locations, tubing runs had sustained minor damage; specifically, dents, flattening, and disfigured instal-lation. -It was determined that this damage was due to construction activities which had occurred after QC inspection of the tubing. Damaged areas were recorded by the contractors QC and reporte'd on an NCR. , Other observed activities and reviewed documentation indicated work i performed in this area satisfied the appropriate requirements.
- 6. Calibration The NRC CAT inspectors performed an examination of the on-site Brown
& Root (B&R) Calibration Facility. Included in this examination was ;
a review of procedures and documentation associated with calibration i activities, an inspection of the calibration facility to insure compliance with the environmental conditions specified, and the inspection of a selected sample of calibrated tools and components. The NRC CAT inspector selected the following sample of reference standards, measuring and test equipment, and certified tools. These were inspected to verify properly documented calibration status,
- p. roper storage conditions, current and approved calibration reports on file, and traceability of items associated with the samples i history file.
l II-14
Reference Standards i No. RS-216 Digital Multimeter-No. RS-086 Photographic Step Tablet No. RS-020 Outside Micrometer No. RS-094 "Go-No-Go" Gauge No. RS-067 Decade Resistor 1 Measurino and Test Ecudoment No. M&TE 1432 Dynamometer No. M&TE 1132 Micrometer Depth Gauge No. M&TE 1553 Megger Test Set No. M&TE 0156 Vernier Calipers No. M&TE 1270 Soil & Aggregate Sieve No. M&TE 1961 0xygen Analyzer No. M&TE 2409 Dry Filit Thickness Gauge No M&TE 2388 Current Transformer No. M&TE 1829 Battery Megger Tester i No. M&TE 1995 Ultrasonic Thickness' Gauge Certified Tools No. CT-1365 - Crimping Tool No. CT-0608 Torque Wrench. No. CT-1606 Crimping Tool Items reviewed satisfied applicable requirements. This subject is also discussed in Section VIII of this report.
- 7. procedures The NRC CAT inspectors examined approved TUGC0 documents. to verify that instructions, procedures, and drawings used to. accomplish elec-trical activi:ies affecting quality contain the appropriate ins;ec-tion and/or acceptance criteria.
Electrical QC inspections are being performed in accordance with the TUGC0 Electrical Inspection Manual. During the review of these documents pr:cedural inadequacies were icentified in the following areas: The inspectors observed examples of electrical conduit installations whose identification numbers did not match those indicated on the QC
' inspection reports in the vault. Discussions with Electrical QC personnel revealed that some conduits are installed with a unit identification number. These conduits are inspected and documented in accordance with the applicable QC procedure. Subsequent to the inspection, the identification number may be changed in accordance with EI-EP-1 (E-1) and Item 13(c) of 2323-El-1700, which state that, "The third character denoting plant nutoer 0,1, or 2 is generateo by the computer from the first cable routed through the conduit."
t II-15
'.., 3 _,___.---....-.......
L
.. ./
. ~
These identification changes are incorporated on Field Structural l l Engineering (FSE) drawings and sent to the field for construction l- use. However, the FSE drawings are not controlled by the Document i Control Center (DCC) nor are they used by QC for inspection. As a result of this, the QC inspection records may not indicate the true identification number of the installed conduit; further, there are !
- no procedural, requirements which address reinspection of these items.
A list of over 100 conduits affected by similar changes were
- reviewed by the NRC CAT inspectors. These items were found durin'g random inspections performed by the QC group. In some instances, '
the list indicated changes not only in the unit designator, but in voltage level and redundant train designations as well. Inspection procedures which do not address reinspe: tion of modified, previously accepted components does not appear adequate.
- 8. Insoection' Records The NRC CAT inspectors reviewed records generated for inspections that were perfomed relative to cable tray, conduit, electrical cable installation, cable termination, electrical equipment installation, seismic supports, instrument tubing, and instrument installation. ___
Assessment was performed in this area to determine whether inspection records have been properly prepared, maintained, and contained documented evidence of inspection completion and results. Electrical and instrumentati Jn inspection records were stored in the QA records vault, and were identifiable and retrievable. Inspection records were completed in accordance with the applicable quality control. procedures. The records identified tne QC : inspector, the type of observation by procedural referents, acceptability., and reference to documents pertainirs to identified deficiencies. The NRC' CAT inspectors questioned the adequacy of documentation associated with reinspection of previously accepted items. In the case of some electrical ecuipment records, the reinspection signatures for equipment that was relocated per Design Change Authorization (DCA) were not found in the equipment records package, but were on a traveler initiated by the civil / structural group. j Additionally, attributes verified by the original inspection report were not specifically addressed in this subsequent documentation. ] The NRC CAT inspectors were unable to determine, from the records j available, the extent of the reinspection which was performed. I Similar conditions were observed in the review of records associated with qf which inspection have beenof electrical modified conduitmodification by component and cablechanges tray supports, (CMCs many) with multiple revisions, and whose inspection records indicate inspection dates which do not reflect the dates of the latest revision of the CMC (this matter is discussed in detail in Section IX of this report),
- I-16
t i Additionally, there were examples of documentation of conditions ) which deviate from requirements by use of systems other than the NCR system. Examples -include tne use of Request For. Information l Clarification (RFICs) to document deviations from requirements j relative to electrical separation. The engineerin RFIC was, in effect, a disposition of the problem,g and response in someto the l { instances was used to initiate field rework. ..lhe. use of the RFIC in j this manner is considered contrary to QA program requirements. J Also, the NRC CAT inspectors found that punchlists were used to l document deficiencies. Some of these deficiencies were considered 1 to be nonconforming conditions by the, NRC CAT . inspectors. J Following the review of inspection rei.ords, the NRC CAT inspectors related the following concerns to the LGP QC supervision: That some records do not show the extent nor do they adequately
. reflect the reinspection activities for previously accepted items.
That the method of documenting deviations from requirements relative to electrical separation, and the method of identifying and dispositioning discrepancies through the exclusive use of ! punchlists were not in accotdance with QA procedural requirements. O 5 e 1 l II-U
- . . . - . . .. . .. . , . . . j_ . . . .._ , . , . . . . _ . . . . _ . . . . . . . . . . . . . . _ , 4
e .. .- l
- l 1.
III. MECHANICAL CONSTRUCTION
'A. Objectives The objective of the assessment of mechanical construction was to determine if installed and QC accepted safety-related mechanical items conformed to engineering design, regulatory requirements and licensee commitments. Additional objectives were to determine whether procedures, instructions, and drawings used to accomplish l construction activities were adequate and whether quality-related {
- records accurately reflected the completed work and the completed i activities.
i B. Discussion The specific areas of mechanical construction that were evaluated
- were piping, pipe supports / restraints, mechanical equipment, and heating, ventilating and air conditioning (HVAC) equipment. To accomplish the objectives stated above, the following activities were performed in each of these areas:
A detailed field inspection of a sampling of QC accepted hardware. --- A review of procedures and documentation. Discussion with responsible QC and Engineering personnel to determine overall knowledge of site procedures, inspection and acceptance criteria, and to identify problems with procedures, i design / field engineering /QC interfaces, inspecter qualification, and.QC independence.
- 1. Picino
^
A sarple of piping runs was selected to include v.ffferent systems, building locations, configurations, ant. izes. The following lines, totaling approximately 600 feet, were selected for inspection: System Drawings Size. Diameter Containment Spray BRP-CT-1-SB-027, Rev 3 2" Auxiliary Feedwater BRP-AF-1-SB-006, Rev 11 8" & 10" BRHL-AF-1-SB-006, Rev 2 Containment Spray BRP-CT-1-SB-028, Rev 3 - 2" Residual Heat Removal BRP-RH-1-RB-003, Rev 5 3" , BRHL-RH-1-RB-003, Rev 2 ! Residual Heat Removal BRP-RH-1-RB-001, Rev 13 12"
,. BRHL-RH-1-RB-001, Rev 2 1 Auxiliary Feedwater BRP-AF-1-SB-025, Rev 11 4" l BRHL-AF-1-SB-025, Rev 2 III-1
_____ _ ______.-_--_-_.------.----_------------Q
4s
}
System Drawinos Size, Diameter l Chemical & Yolume BRP-CS-1-RB-028, Rev 7 2" Control BRHL-CS-1-RB-028, Rev 0
, ' Safety Injection BRP-SI-1-AB-002, Rev S 4" BRHL-SI-1-AB-002, Rev 0 The above runs were inspected in the field for proper configura-tion, identification of valves, surface condition, valve orientation, bolted flange connections, interferences and '
support / restraint location, and function. .The following documents provided the basic acceptance criteria for the inspections: QI-QAP-11.1-26, Rev 9, "ASME Pipe Fabrication and Instal-lation Inspections" . - i QI-QAP-11.1-31, Rev 5, " Installation Inspec, tion of Mechani-cal Joints" Applicable piping -isometric drawings (BRPs) 'and hanger location isometric drawings (BRHLs) Pipe Supports / Restraints a3 installed and inspected to detail drawings. The NRC CAT inspectors utilized the BRHL isometric to verify support / restraint function and location as a check that the piping was installed and supported / restrained as analyzed by the designers. Not all supports / restraints had been installed at the time of inspection. -The piping configuration, valve identification, support / restraint location and function, and flanged joint makeup appeared to conform to procedural drawing recui rements. t The Comanche Peak Steam Electric Station (CPSES) pregram addressing IE Bulletin 79-14 (79-14), " Seismic Analysis for As-Built Safety-Related Piping Systems", was reviewed. Procedures governing these activities are as follows:
. CP-EI-4.5-1, Rev 8, " General Program for As-Built Piping Verification"
. CP-QP-11.13, Rev 5, "As-Built Verification"
. QI-QP-11.13-1, Rev 8, "As-Built Piping Verification Instructions" '
The 79-14 program is basically part of a continuing as-built / piping analysis iteration process. The as-built I III-2
t [ survey package for stress problem 1-017 (a portion of tt e Safety Injection System) was examined and the as-built survey deficiency punchlist computer printcut for problev. 1-003, 1-006, 1-007, 1-010A, 1-010C, 1-0198, 1-021 and 1-028 were reviewed. Program details.were discussed with the Texas Utilities Services, Inc. (TUSI) Technical Services Supervisor (responsible for engineering aspects) and the TUSI QA Specialist Supervisor and As-Built Coordinator (responsible for field inspections). As a result of this "As-Built" review, the NRC CAT inspec-tors identified concerns as to the exclusive use of punch-lists to document discrepancies between detail drawings and as-built hardware (versus.a documented / controlled method of identifying, correcting and preventing recurrence of deficiencies). The above procedures do not involve the nonconformance procedure or otherwise involve the quality l ' assurance program in addressing discrepant conditions on QC accepted piping and supports / restraints. Specific examples of this concern are detailed in the support / restraint section of this report. The related program requirements are discussed in this report in Section IX.B.2 " Corrective Action Systems."
- 2. pice Succorts/ Restraints ASME pipe support / restraints are fabricated, installed, and QC inspected to detailed drawings prepared by ITT Grinnel, Nuclear Power Services Industries (NPSI), or TUSI Pipe Support Engineer-ing (pSE) and applicable. Component Modification Cards (CMCs).
Small bore (less than 21" dia.) Class 2, 3 & 5 supports / restraints may be shown on typical drawings or on " engineered" j cetailed drawings. Supports may be " final" inspected several ' times based on subsequent changes to ori the issuance of revised design drawings,ginal design;by and primarily because the of 3 issuance of CMCs by PSE (field engineering).
]
When engineering considers that the " final as-built" stress l analysis has been performed and there is a high probability that l further changes to the support will not be required, a Vendor l Certified Drawing (VCD) for large bore supports and a Design j Review Drawing (DRD) for small bore supports is issued. These j drawings incorporate any "information only" type CMCs and any modifications necessitated by load changes. QC then inspects ] j the supports for those features revised by the VCD/ORD and for obvious missing parts. j j The following sample of 24 installed and QC accepted pipe " supports / restraints were selected for inspection to provide a variety of types, sizes, systems and locations: l l II;-3
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a' n
..- 4 c.. ,
('- l Support / Restraint No. Location Size Class ge_ " RC-1-015-708-C41R Cont. 2" 1 -Strut CC-2-AB-023-002-3 l Aux. 2" 3 Strut 5I-1-58-238-006-2' . Safeguards it" 2 . Box
.SI-1-068-706-C42R Cont. . 2"' 2 Box RH-1-004-007-532R Safeguards 12" 2- Strut CS-1-357-001-522R Safeguards 6" '2 Strut SI-2-031-425-Y32R Yard. 12" 2 Box CS-2-063-413-542R' Safeguards 8" . -2 Strut RC-2-121-401-552R Safeguards 3" 2 Strut -
CS-2-012-403-C42R' Cont. 3" , 2 Strut L CC-1-136-706-E63R Electr. 3" 3 Strut SI-1-037-005-532A Safeguard 8" 2 Anchor FW-1-017-702-C52K Cont. 18" 2 Snubber CC-1-116-037-F43A Fuel 12" 3 . Anchor L CT-1-002-008-532R Safeguards 16". 2 Strut CC-1-116-006-F33R: Fuel 12" 3 Strut RH-1-003-002-542R Safeguards 12" 2 Strut CS-1-063-008-522R Safeguards 8" 2'- Box SI-1-031-046-Y325 Yard 12" 2 Spring-L RH-1-001-001-C415 Cont. 12" 1 Spring SI-1-092-008-C41K Cont. 6" 1 Snubber CS-1-001-016-C42K Cont. _._ 3" 2 Snubber CS-1-055-010-5425 Safeguards 4" 2 Spring. RC-1-075-026-C61R Cont. 4" 1 . Strut Some of these supports had VCDs issued, some did not. The above supports were inspected. against their detail drawings and CMCs
-for configuration, identification, location, fastener / anchor bolt installation, clearances, member size, and damage /protec-tion. In addition, approximately 200 additional supports were observed in the field for obvious deficiencies such as loose or missing fasteners, imp ~ roper clearances or angularity, damage and !
improper expansion anchor spacing. Acceptance criteria for the field inspections are contained in the following documents:
. Detail support / restraint drawings and applicable CMCs Typical drawings including small bore General Notes drawing CP-AA-001
. QI-QAP-11.1-28, Rev.16. " Fabrication, Installation Inspec-tions of ASME Component Supports, Class 1, 2, and 3" 1 l
. QI-QAP-11.1-28A, Rev. O, " Installation Inspection of ASME Class 1, 2 and 3 Snubbers" QI-QP-11.2-3, Rev.11, " Torquing and Spacing of Concrete !
Anchor Bolts" l l 1 I III-4
I 4 l-p l The following discrepancies were identified on-the supports / restraints inspected: I i U-bolt configuration not per drawings: .i CS-1-063a028-532R AF-1-059-001-533R ) i' H-RC-1-RB-039-015-2 H-CS-1-RB-017-001-2 H-RC-1-RB-038-004-2 < l
.- Lug to restraint clearance-excessive:
I DD-2-019-007-F33R (11/32" vs 3/32") 1
. ~ Dimension not per drawing:
3 RC-1-075-026-C61R (2' 4 3/4" vs 2' 10 1/2") i j Richmond insert ancher bolt threads not as require,d: l q C5-1-001-016-C42X f 1
. Snubber load pin missing: ,
FW-1-017-702-C52 L Void in concrete near concrete expansion anchor: SW-1-102-716-Y33R 4 Loose strut locknuts: SW-1-003-C02-A33R SI-1-044-026-532R
. Missing / broken cotter pins:
14 supports
. Class 3 hanger mismarked as Class 2:
H-GH-X-AB-0042-003 Numerous other instances of loose locknuts, U-bolts, and missing or broken cotter pins were observed on Class 5 supports / restraints that were under the TUGC0 OA/QC program. Contri-buting to the problems identified with U-bolt installations are confusing drawings which show U-bolts with 1/16 inch clearance required, but also with double nuts on the outside of the retaining plate. Clear acceptance criteria is needed prior to inspections being performed. , III-5
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7____-_-. re LRC CAT ins;ectors witnessed the CC inspection of fifteen I srail bere succor s and six large bore supports to tFe VCD per
- rececure CP-CAP-12.1. Twelve of the small bore sup;crts were s a ti s f a cto ry. Three were unsatisfactory due to drafting / design err 0rs, primarily d e to incorrectly incorscrated CMCs into the VCD. Three of the large bore supports were unsatisfactory with an improperly welced bracket, two undersired welds, a missing nigh strength pin ar.d an imprcper clamp spacer.
Discussions with the Supervisory Authorized Nuclear Inscector ( NI) indicated that there were deficiencies with the eccepted hangers and difficulties in determining the specific activities performed during the f abrication/ installation phases. The ANI , office has recently been receiving completed ASME support / restraint packages,for review and acceptance for the ASME Code Cata Pecort. Of the initial packages of OC accepted VCD su: ports / restraints that were inspected in the field by the ANI, approxi. cately 10% (13 cf accroximately 130) have been returned to B&R CC cue to undersired or otherwise unacceptable welds. The ANI i was inspecting these installations for basic configuration and welcing cetails only. Of approximately 665 vender certified, CC irspected supports forwarded to the ANI on or before Feorvary 13, 1983, approximately 100 rad been returned for ceficiency correc*iCCs. Ine SEC CAT inspectors reviewed the deficiency punchlists i generatec by CC during the VCD inscection. Six punchlist items
#ce hangers were selected (biased sample) to verify thet noncen-
#or-ing c:rditions were being properly identified and action to revent recurrence was being taken. Two of these items, an ir:rt:erly installed U-bolt (CS-1-C63-046-522K) and ex:ansien ancnor spacing not per drawing (FW-1-098-0C8-C625), are con-sicerec ey tre NRC CAT inspectors to be nonconforming conci-tiens, but were not docurented by OC on NCRs. Subsecuent to tre 50C CAT inspector recuesting an evaluation of these itens ey QC,
'CRs were isscec. ~hree more i'tems concerning unders1:ec, mi s s i ng , o r di sc re:3 nt wel ds (CC-x-032-7CO- A43 R , CC-1-161-CO * -55.'R ,
CC-1-131-013-543R) nad been cocumented on NCRs. However, re. iea of the documentation packages anc applicable revisions to the i suor.crt/restreint drawings and CMCs indicated that none of tnese
.se::s nac :een char;ec by dranings or CMCs since the " final" CC ins:e: tion acceptance of these su;oorts. The fact that tne su: ports were ac:epted originally by CC with deficient -eles ce t9at unauthorized / uncontrolled wcrk had been performec on inese ;
sup?crts was not indicated on the NCRs. ASME NCR for s co not provice for any evaluation or signoff for action necessary to prevent recurrence. Nonconforming conditions, noted carica t9e
'.CD program are accarently not being properly eccumented er icentified to effect action te prevent recurrence.
!::-6
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o i 1 l During the. review of.the 79-14 "as-built" pregram' discussed in ~; Section B.1 above, the NRC CAT inspectors selected eight items from the walkcown survey to determine if discrepancies on OC accepted supports / restraints were being procerly discositioned. At least three items (MS-1-C03-003-C725, SI-039-019-522R and SW-1-025-003-J03R) showed apparent nonconforming canaitions for I which no changes had been specified (on drawings or CMCs) since !
'QC acceptance of the, support / restraint. In addition, the as-built survey team had identified at one point in time 33 OC accepted supports that had been disassembled or completely <
removed without authorization. These conditions were net doe w ented in any system that would provide long term corrective ! action, but were referred to the construction organization via
-memo. It is recognized that the as-built survey team may not be using the latest CMC issued against the supports they are inspecting, which may make tne determination of a nonconforming condition difficult. However, it appears that nonconforming conditions noted curing this program are not being properly identified, cocumented or evaluated to effect action to prevent recurrence. ;
The insoection of' Class 5, seismic supports was a part of the TUGC0 0A/0C program as delineated in procedure 01-0P-11.le-1, Rev.14, " Installation Inspections of NNS Seismic Category II Supports for Class y piping". Paragraph 3.16.3 of this proce-dure permits documentation of discrepancies found during inspec-tions eitner on Inspection Reports (irs) or Nonconformance Re: orts as directed by the QA/0C Civil Mechanical Suoervisor. The QA/0C Civil Mechanical Supervisor has issued a memorandum directing CC supervisors that discrepancies are to be documented cn irs only. This procedure and memorandum have thus overriccen tne nonconforming conditions and corrective action requirements cf rececure CP-Cp-16.0, "Nccconformances" and the TUGC0 CA ranual. Although irs related to base metcl defects are input to the " trend analysis" and corrective action system, other ty:es of unsatisfactory irs (location, angularity, nemoer size, orientation, etc.), whicn may represent nonconforming conditiens are not. Therefore, this action is another case where noncon-foeming concitions are rot identified such that root causes anc actions to crevent recurrence can be determined and appro-criately aispositioned. A review of procedures governing safety-related pipe supports / restraints indicated that there are procedures covering many ascects of the program (fabrication, inspection, VCD walkcewns, Ore-hyoro alkdowns, pre-turnover walkdowns) and tnat some are ouite comprehensive and provice detailed information anc accep-tance criteria. However, tne procedures related to inspection of succorts are somewhat Confusing and unclear as to the s ecific attributes recuiring inscection. For example, the written instructions /cnecklist for VCD ins;ections recuire a verification of support " configuration". The intent of this item was not clear. The interpretations by CA/0C management, CC supervisors, anc OC ins;:ectors of fered . curing discussions witn l III "
)
. .. .. 4 hRC CAT members varied from a detailed inspection of many attributes to a verification that in fact a snubber is installed when a snubber is indicated as . required. Walkdcwn procecures also do not provide sufficient specific inspection attributes j and checklist / markup controls for identification and correction j of the large number of loose and missing cotter pins and fasteners.
A review of the documentation packages for the 24 supports / r,estraints list'depreviously w&s performed. The packages are oifficult to follow due to the large number of changes involved with an average of over five CMCs per support and as many as 16 on ore support. Previous inspections are not voided. It was : observed that from a total of 55 inspection reports, covering ! approximately 410 total att'ibutes, r there was only one indica-tion of an unsatisfactory IR and only one NCR was written. For non-ASME supports, QC rejects 20 percent of the supports sub-mitted for final inspection in addition to recuiring immediate correction of minor hardware items (loose bolts, etc.). The near perfect record in the ASME program indicate's that problems are being turned back to construction for resolution (through ; imeediate correction or issuance of CMCs). This practice when ! conducted for all . types of deficiencies circumvents the Correc-tive Action Program to identify and prevent recurrence of 'j significant deficiencies. s a Review of 14 of,these packages indicated the following discrep- )j ancies that reinforce this concern. Although tne Multiple Weld Data Card (MWDC) has a CMC log block, in numerous instances the { leg indicates CMC revisions and entry dates muen later than tne { CC inspection signoff dates (some entries over one year after l ins:ection). As the coversheet InsDection Reoort dces ret list i CN revisions, it is not possible in most cases to icentify unich CMC (design document) was used to perform the inspection. Further, the "QC Checklist for Snubber Installation" does not soecify tne drawing or CMC revision. In 10 of tne 14 packages, CMC revisions wore issueo after the date tnat construction ; signed off on the MWDC that the installation was complete, and ' on or shortly before the date of the QC inspection. Most of tnese CMC revisions were not "information enly" or clarifica-tien, but pertained to important design features such as diren-i l siens, raterial changes, baseplate configuration, etc. In one l instance, three CMC revisions were issued between construction i coroletion and QC inspection. In one case, the IR was sigred off indicating inspection completed the cay before the A*kCC with the cetailed checklist items was signed. In cre instance, tne center-to-center oimension on a snubber was enanged on a CMC revision to " meet as-builL conditions", but had been QC inspec-ted satisfactorily twice before. the following statements sum arue the assessment of pi.ne support / restraint activities: III-8
13p.: .* i
'a, ilumerous cases of GC accepted' installed hardwar'e not conforming to drawings and CMCs were identified by the 'mC -)
j CAT inspectors, ANI, anc B&R QC curing VCD inspections, and " by TUSI "as-built" personnel.
- b. These conditions indicate poor inspection work, unclear /
l errcneous draf ting, and/or unauthorized, uncontrolled-alteration of completed work, f l c.- Numerous instances exist where nonconforming conditions l l
.have not been properly identified to provide the input to
!< the OA Corrective Action Program for determining root causes and preventing recurrence.
- c. Frem discussions with site personnel and the obviously large number of CMCs, it appears original design drawings were used only as guides to construction, and the actual design / analysis was performed after construction and i ins:ection.. This may have resulted from the many changes recuired due.to relocated piping, interferences, and the CMC program itself.
i
- e. The. acceptability.of the installed hardware to meet design requirements based en a series of partial inspections (versus a final complete inscection after work is ccepleted) is questionable based on the following points:
Numbers of " design" changes (CMCs) Somewhat unspecific inspection procedures Amount of engoing construction activities and the apparent lack of ciscipline regarding construction personnel tampering with QC acceptec harcware. Orafting and design discrepancies noted in initial crawings, CMCs and '/CDs. The number'of discrepancies noted on supports presi-cusly accepted by GC. Inspection documentation not indicating tne " design" cccument (drawing and/or CMC) revision that was used for the inspection. In cenclusion, althougn extensive major technical problems were not icentified in the pipe su: cort / restraint hardware, ;rcrc* acticn is recuired to accress the above program concerns. Specifically, attantion must be focussed in the areas of the
. nonconfor .ance/ corrective action program, comprehensive final ins:ecticns anc inspection cc:grentatien in creer to provide ccnficence in :ne acceptability of installed pipe supports /
restraints. { 1 4
2 1
. 3.. Mechanical Ecuiement The following sample of installed and QC accepted mechanical
- equipment was selected and -inspected for proper location, identification, foundation /suoport configuration and conoition, in-place storage conditions and damage.
TBX-GHATGD-01, Waste Gas Decay Tank' i TBX-GHATGD-07, Waste Gas Decay Tank TBX-GHATGO-10, Waste Ges Cecay Tank TPX-TRAHLC-01 Letdown Chiller Heat Exchanger CP1-00APRM-01, Reactor Makeup Water Pump
~
CP2-CDAPRM-01, Reactor Makeup Water Pump CPX-DDAPRM-01, Reactor Makeup Water Pump' CPX-CSATBA-01, Boric Acid- Tank * , CPX-CSATBA-02, Boric Acid Tank CPX-BRATRH-01, Boric Acid Tank TCX-CSAHLO-01, Letdown Heat . Exchanger TBX-TRAHMH-01, Moderating Heat Exchanger Acceptance criteria for the field inspections were taken from vendor drawings and technical manuals, and site structural /
. foundation drawings.
The Operations Travelers detailing the installation and acceo-tance of Reactor Makeup Water Tank-01, Moderating Heat Exchanger-01, Beric Acid Tank-01, and Letdown Heat Exchanger-01 were examined. No problems were identified relative to the location, icentifi-cation, in-place storage, or damage to mechanical ecuioment. All foundation nuts were insta11ec and appeared tignt. However, the makeup of the foundation bolt / nut assemolies was inconsis-tent, and in some cases, the conformance with vendor require-ments was in question. For the tanks and heat exchangers inspected, some bolts had single nuts, scme had double nuts, ar.c scme nad a mixture of single and double configurations. '.' encor and site fcundation drawings incicated sincie nuts. The Opera-tions Tra eiers and site structural.colting procadures do not require or adcress double nutting. The Westinghouse tecnnical manual for the above heat ex:nangers soecif'es that the nuts on ;
- ne slottec end of these units be backed.of f slightly to allow movement curing thermal expansion. Most of the bolts on the slicing encs of all of the heat excnangers inspected were coable nutted and appeared to be drawn down tight. The sliding end of tne Letcown Chiller Feat Exc"enger aopearec to have hac greut between the succort bracket and the foundation red. Tre Opera-tions Travelers did not address the technical manual require-ment; tney stated only that t9e units were to be installed in 4 j
accordance witn applicable crawings, i l 11!-10 ' l \
i a. Featino Ventilation and Air Ccnditionina (HVAC) i H'/AC systems on Unit 1 and Ccmmen are essentially 1005 Ccmpleta I and turned over to TUGCO. Mary portiens are operatirg. Unit 2 i installations are approximately 80% ccmolete. 1 i in general, HVAC duct and equipment suoports are f abricated and installed by the Bahnsen Service Co. (BSC) in accercance with ; typical drawings and procedure DFP-TUSI-003. ESC CC inspects expansion anchor. installation and the fitup and welding of duct supports. Af ter installation, the support as-built configura-tion is sketched by draf tsmen. This unsigned, unreviewed sketch is sent offsite to Corporate Consulting and Development Co. (CCL) for seismic analysis. If analysis indicates that modifi-j cations are requirec, the supports are mocified, OC inspecteo ; for new expansion anchors and welds, and the draftsmen prepare a i final and formal "as-built" drawing. This drawing is checked, and aporoved and then reviewed by BSC Site Quality Assurance. This "as-built" is resubmitted to CCL for final review and analysis. Because the typical drawings provide no axial bracing, most duct su:;crts are nodified. Nowhere in this j orecess coes BSC OC inspect the supports for proper locatien, - pro:er configuration or memoer size and length. No CA/0C verification or audit of the drafting department's as-built ef# orts is performed. t Eight duct supports and one fan support were inspected in tne fiele for proper location, configuration and conformance to crawing, design and procedural requirements. Five cf tnese nine supports cid not conform to the configuration and dirensions shewn on the as-built sketches or crawings. Following is a list of the supports inspected anc the discrepancies noted: Su cort Diferecancv
- A -C S -E ~ 4- 1 N-; K None A-C5-35?J2N-1AK None A-C E-2 5 '-2N-C5 3 cimens. (discrepancies o' 3i", 2 3/8", ai" f rom cesign) 1-C3-854-4-2N-C12 None
' 5Gi-552-10-10-01 1 cimen. (6i" variance) 531-552-1J-23 1 eemoer size smaller than i shown (3x3x3/8 vs 4x4xi)
- :t sucocrts with " final" as-cuilt crawings have the "A" prefix, the re nining tnree nad only the fiele sketen used for initial seismic analysis at tre time of tnis inspection.
1 III-11 l
Suecort Discreo g i CB-807-2N-A ' 1 dimen. (1") CB-807-2N-B None SKPfC-701402 (Fan Support) 2 dimens. (2 3/8", 2 3/8") and Hilti location spacing (2 . missing, 2 in error) i Ducting is inspected for proper installation during the system turnover walkdown. No checklists are used and acceptance documentation for as many as 38 segments were observed on ene general Inspection Report. BSC personnel stated that deficien-cies noted during the walkdewn were noted on a punchlist, corrected and reinspected. However, these punchli;ts are not a controlled er a retained document, and OC reinspection and closecut are not addressed by site procedu es. SSC ;ersonnel could not provide an example of a completed / closed cut punch-list. ' Turnover oackage 3601, in the final stages of completion *, was examined in the BSC office. This package centained 36 Inspection Reports, accepting 495 duct seg ents, which were all ; signed by one QC inspector en one day. The insoection J ectivities to verify proper makeup of 495 jcints acid d ap:roximately 200 support locations would take several weeks anc require controls over the prccess to assure that all requirec inspections are performed. ESC procecures do not provide instructier.s to OC personnel on how to docurent/ control the in-crocess walkcown activities ano ESC personnel coulc provice r.c evicence that the incividual inspections includec in this cackage were recorded on log books, marked up crawings, or sirilar centrol mecnan1sms. T e felicwing duct segments anc in-line ecuipment were ins;ected in tne fiele for confornance to drewing anc procecural recuire-ents: CRKE-1, EMD-7, Segments 6 tnrough 12 Fan CPX-VAFNID-01 Fan CPI-VAft.ID-07 Fan CP1-VAF"!D-10 Car:er CFX-VADFMV-05
!sciation Valve CP2-VAD-PSC-CS l a ccroxinstely 25 cuct segrents adjacent to the su p r s inspec-tec were aisc examined.
1 111-12 ' _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ - - _ _ _ - m
7
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a s j f v - ('t (
-I i Five of eight joints in the CRKE-1, E.".C-7 line.had one or,more'i lecse bolts. Numerous other joints coserved during the succort inspection also had loose "
lockwasners (for example ) or missing fasteners and missing f0ur loose bolts on th*/ joint acja./ centtosupportA-5G1-85d-1J-1C-01). The flance colts fr-J. containment isolation damper CP2-VCPSC-05 and a similar camper'c on Unit 1 dic not properly fit the noles and were not fully installed. On damper CPX-VADPMV-05, the gasket on one side was partially missing and the other side had no gasket at all, toits were loose and lockwashers were missing. Theboltingrequire-/
' mant of BSC procedure DEP-TUSI-008 that requires additional ,
corner bolting on duct accessories was not met on the damper on the discnarge side of Fan CF1-VAFNID-07. $ 7 Tne BSC program to inspect and document the installation of HILTI concrete expansion anchors., however, appears to nave tsen thorough and effective. ' i
\ '
In surrary, the nucer and variety of discrepancies ne'eI by the NRC
' CAT inspec* rs oetween installed hardaare concitions and drawing /
procecure requirements indicates that the (Clinspec+ ion recuirerents a-: controls have not been sufficiently detailed inforocedures, nor nas the CC ins:ector performance in the field baen 1(.ecuate to assure t n.8 HVAC system.s are installed as required. Tbare was an apoarent failure of the BSC Corporate, Brown and Root anc TUGC0 QA organiza-ti:ns to identify and correct the observed program deficiencies curing their audit / surveillance activities. i l l (* f
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W< a > ,, IV. ELil'ir,j '. DESTRUCTIVE EXAMINATION V
. t }/
V A. Objective
'J -
)
I Determine by direct cbse.rvation and independent evaluation of work f,; performance, work in progress, and completec work, whether field .. y 6* welding activities associated with piping, hangers / supports, steel l f h'
' #f structures, and heating, ventilation and air conditioning (HVAC) systems, e m controlled and performed in accorcance with fiRC require-
-ments, AR cc.tmitments, and applicable codes'and specifications, i
k (in addition, determine by' direct observation and review of records
$' Pthat welders and nondestructive examination (NDE) personnel are adecuately trained and qualified in accordance with established q, per#ormance standards and applicable code requirements.
. ,) .
~
S. Discursion k ">' ~ V f , 4) . 1. 00rts/Hancers ' j@' gSu: ('
~~5 *,
s
',Twa9ty ystven pipe supports were selected for inspection cf weldin). All of the hanger welds had been previously cuality 3' centros A listinho(CC)inspectedandacceptedbyBrown&
f'the hangers follows: Root (B&R).
/ P1pe unit A5.%
y
, Tyce Si:e. in. No. Svstem* Class Hancer No. .
s , ,,- Box 1.5~ SI ' a 1 2 SI-1-SB-238-006-2 Strut - 6.0 1 CVC 2** CS-1-357-001-522R Bor 12.0 2 SI 2 SI-2-031 425-Y32R Strut 5.0 2 CS 2 CS-2-063-413 542R o St ru t- 3.0 2 2 RC RC-2-121-401-552R Ancher 5.0 1 SI 2 SI-1-037-005-532A S t ru t *6.0 1 CS i
. 2 CT-1-002-008-532R 1 Stru- 12.0 1 CC 2 CC-1-116-006-F32R Eox 3.0 1 CVC 1 C5-1-063-008-522R Spring 12.0 1 51 2 SI-1-031-046-Y325 )
Stru t 12.0 1 EH 2 RM-1-004-007-532R S t ru t ' 12.0 1 SI 2 SI-1-031-024-Y32R
' S t r' u t 3.0 1 CVC 2 CS-1-063-037-A42R 53x 3.0 1 CC 3 CC-1-136-706-E63R Sirut 2.0 2 CC 2 CC-2-AB-023-002-3 Strut 3.0 2 RH 2 CS-2-012 403-Ca2R Strut 12.0 1 CC 3*** CC-1-116-037-Fa3A Snubber 13.0 1 FW 2 FW-1-017-702-C52K Snuober 3.0 1 CV 2 CS-1-001-016-C42K Inubcer 6.0 1 SI 1 SI-1-092-008-C41K <
Spring 12.0 1 RH 1 RH-1-001-001-C;15 l
!V '
s ____---__-------.----a- - . - - - - - - . - - - - . - - - .
a 4 g 4 Pipe unit ASME Ty:e Size in. No. System
- Class Hancer No.
Spring 4.0 1 RC 1 RC-1-075-026-C61R Spring 4.0 1 CV 2 CS-1-055-010-542S Strut 18.0 1 FW 1 FW-1-017-001-562K Strut 2.0 1 RC 1 RC-1-015-708-C41R , Strut 12.0 1 RH 2 RH-1-003-002-542R ! Box 1.0 1 CVC 2 CS-1-SB-059-003-2 <
'51= safety injection; CVC = chemical anc voiume controi; CS = containment spray; RC = reactor coolant; RHR = residual heat removal; FW = feedwater ,
** Undersize Weld
***0verlap, Improper Contour The majority of hangers inspected utilized fillet welds for joining hanger ccmoonents and details.,
T.vo of 27 hangers exhibited unacceptable welds. Hanger CS 357-001-522R exhipited one uncersize fillet weld. The weld was . I 1/15-in. to 1/8-in, uncer the specified requirement. Hanger CC -l-116-037-F43A exhibited overlap and improper weld cor. tour. Thirteen of 27 hangers had been inspected to vendor certified crawings (VCD). The welds, for the most part, exhibited good workmanship. Some of tre nangers inspected were painted and NRC CAT inspec-ion of 19ese hangers was mainly #0r weld size. I. Safety Related Succorts/Hancers for Electrical Conduit anc instrumentation
- a. Electrical Concuit Sue: orts /Hancers These concuit sur: orts / hangers are fabricated :n-site teth in the shop anc in tre fieic. The following ccccuit sunports/nangers were being fabricated in the en-site snc:.
The NRC CAT inspection v:es performed on the sut;ect nangers refore tne hangers were painted. C03GC9160-1 C12GC6431 26 C04G?1038-2 CC3G09160-2 C12G10452-3 C'.2G21174-2 CC2G09460-3 C12G10652-4 C23HlC674-6 C12021194-4 C12G10455-23 l l \ l 1 1 IV-2 i
a . , , . . . All welcs en the above supports / hangers were visually
- inspected by the I;RC CAT inspectors for acceptance to F 01-QP-11.10 4 which invcke AWS 01.1, " Structural- Welding Code." The liRC CAT inspectors examined the on-site shop facilities, and reviewed fabrication procedures, inspection records, and in-process activities relating to material identification, marking, cutting, cleaning, and welcing.
The NRC CAT inspectors cbserved the arc-stud welding process being requalified. Requalification was performec-for 1/4-in. , 3/8-in. , and 1/2-in. studs. Two studs for each of the indicated sizes were welded for requalifi-cation. Welding was performed in accordance with AWS D1.1.
.The welded studs passed the bend test in accorcance with AWS D1.1, and therefore the welding process was judged acceptable.
The fiRC CAT inspectors-examired field installed and OC accepted supports / hangers. The inspected hangers were constructed for the m.ost part af 6-in. x 6 'in, square tubing. The supports / hangers were relatively ccmplex as evidenced by the numerous seccndary supports attached to the primary structure. The subject supports / hangers inspected. (listed below) were partially fabricated in en-site shops and completec curing field installation: C03G18046-7 C22K06857-1 C12K15116-1 C03G18046-8 C22K06902-1 CO2030179-1 C03G18046-9 C12012705-6 CC2030179-2 C03G18006-10 C12012705-7 SH-IN-CrM-50 C12KC6108-2 C12012705-11 SH-IN-chm-5c C13G13999-2 C12015077-7 Sii-IN-CHM-Se CO2G18046-11 C11C04797-1 SH-IN-CFM-5f Sh-IN-CMI'-5; The identifieo hanger /su; port welcs that were inspectec ( otn shop fabricated ar.d field installed) were visually acce:tacle. Review of the sncp activities revealed that tne work was being cencucted with proper controls and the cuality of the workmanship appeared consistent with geoc industry practice.
- b. Instrumentation Hencers/seccorts The majority of instrumentation and control (!&C) non- SME (safety-relatec) hangers are faericated in shops on-site.
S&R field construction installs them by bolting or welding the hanger assembly to tuilding structures. Both field and shop inspections were teing performed by the licensee. IV-3
The NRC CAT inspectors cbserved shop fabrication of six hangers at various stages of manufacturing. In-process activities reviewed were material traceability and identi-fication marking, application, cutting and cleaning of materials, welding, filler material control, and hanger identification markings. Review of documentation for the shop fabricated hangers included review of material records, engineering drawings for configuration, inspection records for welding, material
- verification, visual inspection of welds, inspection report number, and verification of surface preparation for painting. Documentation indicated inspections were performed according to QC document QI-QP-11.8-2.
Ten field installed and OC accepted hangers were also reviewed by the NRC CAT inspectors. The inspectec hancers are identified by the following numbers: S-la67 S-2729 S-ISC6 S-2723 5-2244 S-2724 S-2250 S-2726 5-2292 S-2762 The identified field installed hangers were inspected for visual weld acceptance in accordance with AWS D1.1 anc no deficiencies were icentified.
- 3. Festing Ventilation, and Air Conditioning (HVAC)
T"e NRC CAT inspectors cerforced field inspection of FVAC veles cn hangers, ducting accessories sucn as ficw control devices, air dancers , and containre.nt isolation valves. All of the items irs ectec by the fRC CAT inspectors had been previously accepted by Bahnson QA/CC,
- a. HVAC Sur:0rts/ Hangers Structural steel hangers supporting cutting runs were visually inspected to cetermine if welcing met tne recuire- )
cents of AWS DI.1. Typically hangers are field ferricatec
'r:m 4-in. x 4-in. x 1/2-in, structural steel ar gie it on.
Mangers inspected and results are as follows: IV 4
No. of No. of Welds Unacceptable No. Hancer No. Inscected Welds 1 CB-807-2N-A 21 11 2 CB-807-2N-B 21 10 3 SGI-852-1J-15 12 11 4 SGI-852-1J-1C-01 12 3 5 SGI-852-1J-28 12 10 6 SGI-852-1J-16A 18 6 7 DG-844-2K-1AR 14 8 8 OG-844-2K-1AT 14 5 e 9 DG-844-2K-1AQ 14 2 10 DG-844-2K-1AR 14 3 11 DG-844-2K-130 6 3 12 DG-844-2K-1BC 6 3 13 RB-1A-C1 3 2 14 RB-1A-C2 3 1 TOTAL 170 78 Thus, a rejection rate cf approximately 45" was exhibited for welds en structural steel hangers. The majority of those welds that were urtCCeptacle were rejected because of uncersi:e welds. The si:e of welc s ecified on mest of tne crawings was 1/2-in. These welds usually measured approxi-mately 3/8-in. The rest of tne welcs were unacceptable because of insufficient length, undercut, and improper aele contour. 5ahrsen QA/QC personnel observed and acknowledged mest of tne acove weld deficiencies. It was reported after tne .'iRC CAT ir.s:ection that on February 28, 1953 the licensee's aucit of tne installed .'AC system confirmed tre ceficien-cies and a 10 CFR 50.55(e) report was filed by tre licensee.
- b. C:n a n ent Isolation Ct rer The Unit 1 HVAC centairrent isolation camper connection flange cetaileo on Bannsen sketch, 150-001, shows a 48 in.
circular flange made frca 2-in. X 3-in. X i-in. angle iron. Inspection of this flange in the field revealed that it is actually fabricated frem two pieces of flat stock joinec Oy fillet welding to form a rignt angle flange. This is contrary to tne sketch. The drawing is also in error in that it fails to scecify a fillet weld joining the two pieces of material. Furthermore, the fillet weld uocn inspection was found to Oe unacceptable in a numcer of areas. 17-5
Because of limited. access to the full circumference of the weld,.only a 120-degree segment was inspected. Approxi-mately 40% of the 180-des Je segment of the weld was visually acceptable in 'acwordance with AWS 01.1. The rest of.the weld exhibited areas of undersize welding, linear surface indications, arc strikes, undercut, overlap, and in general, 'a poor level of workmanship,
- c. HVAC Welder aid Procedure Qualifications I Bannson procedure QCI-CPSES-009, specifies that welders shall be cualified to ASME Section IX. Gibbs and hill
. specification 2323-MS-85 (Bahnson contract requirements) specifies that welding procedures and welders may be cualified IX, in accordance with AWS D1.1 or with ASME Section Actual field fabrication is perferrred to the recuire-ments of AWS D1.1, Structural Weloing Code," and AWS D19.0, .
, "Weiding Zinc-Coated Steel".
The NRC CAT inspectors reviewea welding procedure specifications and welder performance qualifications. This review revealec the following discrepancies. WPS No. Process Comments ESC-12.1 GMAW AWS D1.1, 5.5.2.3 specifies that the cover gas ficw rate be :25% of the rate qualified; however, WPS BSC-12.1 fa(1s to specify the actual rate useo curing qualification. AWS 01.1, 5.5.2.3 specifies :1C% for amperage, :M for voltage, but ESC-12.1 fails to specify a range; specific values are given for amps ano volts, but no tolerance. is permitted by WPS 35C-12.1. ,
]
SSC-15 GMAW The v. eld procedure qualification sheet 3SC-la* for 35C-15 soecifies unicue values fer BSC-14.1* .I amps volts, travel speed, anc gas flow. 1 The hPS BSC-15 specifies 30 40 ft3/hr ! gas flow, 90-170 arps, 12-25 volts, 5-12 in./ min travel. The ranges are outside of the tolerances permitted by AWS 01.1. ESC-13 GMAW WPS BSC-13 specifies ranges for amperage, voltage and travel. No weld {' precedure qualification reccrd was available for WPS ESC-13 that states what values were used during the cuali-fication test. IV-6
. 1 1
l ESC-20 SMAW 95 amps is indicated on Welding - 1 i Procedure Qua'lification Record Sheet f for tnis procedure. LPS BSC-20 s:eci- j fies a range of 7C-160 emp. This r3nge ; exceeds the :255 tolerance permitted by ' AW5_D1.1. (71-119).
- Same comments apply to these procedures as for ESC-15 Bahnson specification 2323-MS-85 paragraph 2.14b Welding, j (codified by Cesign Change Authorization 9898) specifies 3 that all weldina shall be in acccedance with AWS 019.0-72.
Paragraph 2.14(a), of specification 2223-MS-85 s;ecifies that welding precedures and welders shall be qualified in accordance witn AWS D1.1 Section 5 g ASME Section IX. All of Bahnson welding orocedures have been qualified in accordance with ASPE Section IX. Qualification in acc r-dance with'ASME Section IX is permitted previding tne requirements of Section IX meet or exceed all of the requirements of AWS Dl.l. As noted above, weld procedures BSC-13, SSC-14., BSC-14.1, 25C-15, and 55C-20 fail to reet all the requirements of AWS D1.1, and are not cualified procedures. The balance of Bahnson's welding procedures were not reviewed by the NRC CAT inspectors and their status of qualification, was not deteraired,
- d. HVAC Weldina Occumentation A review of Bahnscn cuality control records and precedures reveals a failure to icentify what weld prececure was employed for a specific hanger weld. The v.eicing material issue slip, usec to centrol tre issue of welding rods, has a space to enter ne HVAC system identification. However, as determinec by review of welding material issue slips, tre spac's Orovided for system icentificaticn only incicates tne plant elevaticn, buildinc and reactor unit nurber.
A1:c, traceerility of the aelc,ing caterial utili:ec anc tre welcers er;icyed on scecific welcs cannot :e cetermirec. Sanrson fiele irscection reports, altr:ugn :rovicing for acceptance of welcing, fail to icentifj the welder, tne aelding rocedure, and tne welcing materials used. ty-7
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- e. HVAC OC Insoector's Qualification HVAC QC inspector qualifications, both past and present, were reviewed. Training records, experience, anc educa-tional requirements were compared with the requirements of A!4SI 45.2.6 and Regulatcry Guide 1.58. On the basis of this review, the supporting documentation appears to meet i the minimum requirements of ANSI 45.2.6; however, QC !
trair,ing appears to have been based on review of OC proce- ! dures. Little evidence was available that reflected
, technical training of substance.
The QC inspectors informed the NRC CAT inspectors that up to 1 year ago BSC inspectors were not using fillet gauges, or other similar tools for measuring Weld sizes. Fu r the r-more, during the NRC review some inspectors exhibited limited knowledge of welding inspection. QC inspector qualification records accear to meet the letter of the ANSI requirement but it was apparent that the QC inspectors lackea proficiency in the inspection of welds. Visual Examination of Pioine Welds Seven piping iscmetrics were preselected for visual inspection of piping welcs. Nine additional piping isometrics were selected at random for visual inspection of welds. All of the pi:ing ru,ns had been inspected and accepted by S&R QC before NRC CAT -inspection. The inspected piping runs and other system
;arameters are as follows:
Picinc Samoie Fian Pipe Ft. No. L'r i t Isometric dia. of ASME of No. Svster* Nc. (in.) Dice Class Valves Wel:s 1 CS CT-1-SB-028 2.0 55 2 2 26 i CS CT-1-SB-027 2.0 50 2 2 29 1 5* SI-1-52-004 6.0 85 1&2 2 12 1 SI SI-1-AB-002 4.0 130 2 2 12 2 51 SI-2-AB-001 4.0 65 2 0 12 1 AFW AF-1-SB-006 10.0 62 2 2 11 1 AFW AF-1-SB-025 4.0 105 3 2 11 TOTAL WELDS 113 IV-8 !
L 1.
.l ? .. .
o sanccmiy 5eiecceo Picina Runs
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Unit No. System
- Iscretric No. No. of Welds 1 SI SI-1-RB-037 1- '
1 SI S1-1-58-042 11 1 'SI SI-1-RB-053 1 1 SI SI-1-RB-052 1 1 SI SI-1-RB-033 6 i 1 SI SI-1-RB-043 7 i CS 'CT-1-RB-017. 3 1 CS CT-1-RB-019 8
-1 RHR RH-1-SB-003
-1 TOTAL WELOS 39~
"C5 = containment spray; Si = safety injection; AFW = auxiilary feecwater; RHR = residual heat removal The welds inspected (identified by 16 pipir.g isometrics) are ASME Ill Class:1, 2, and 3 welds. The size of the piping ranged frem 2.0 to 24.0 in, in diameter; approximately 1400 ft of piping was involved in the sample. A total of 152 piping welds were visually inspected in accordance with ASME III-74'for undercut, overlap, lack of fusion, surface porosity, and other anomalies related to surface conditions. Both vendor and field fabricated welds were part of the sample.
Three of the 152 welds exhibited undesirable surface conditiens: Weld F-11B (reference SI-1-SB-004,-safety injection systemi exribited insufficient weld-in that the face of the weld was below tne acjacent pipe surface. This weld was also improcerly located on the isometric drawing (150) presided. The ISO for weid F-118 s:ecified that the.welc shoulc Pave been lccated at a given position frcm a wall. Actual fiela location was en the c::csite side of the wall, acproxirately B 't frem tne lccation s own on the 150. A nonconformance recort (NCR) was preparec by tne 'feensee for.both the surface concition of the weld and for
..islocation.
Cne weld icentified on 150 RH-1-SB-003, Res. 9, joins a section of 12.0 in. pipe to a section of B.0-in. pipe. The transition, recucing elbow was vendor fabricated. The neld joining tne B.0-in. pipe sections exnibits a taper or slope of approximately 4: 1. The slope permitted by ASPE III is 3:1 maximum. This concition was discussed with B&R QC personrel, and at the end of tre NRC CAT inscettion~, the matter was still uncer review. l l
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IV-9 !
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r -. _ _ - - - - _ - _ . - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ m . . . . - A weld-o-let (vendor installec) identified"en ISO CT-1-RS-019,
'Rev. 1 (adjacent to field' weld FW-4) has insufficient weld reinforcerrent on~the weld joining the weld-o-let to the pipe. ' ,
The subject weld exhibits less than full' weld reinforcement, This condition is readily apparent by noting that portions of j= the weld preparation on the weld-o-let side are cbservable.* A review of cuality control procedures and engineering and con- ; struction specifications for vendor and field installed weld-o-lets or sock-o-lets reveals a lack of criteria for.specifying the required size of weld reinforcement for less than full re-enforcement welds. Typically, weld-o-lets can be installed on several sizes or diameters of piping and wall thicknesses. .On the basis of the engineering requirements (temperature and i pressure) for a given system, the size of the welc reinforcement needs to be specified for those cases where the weld is less than full reinforcement.
- 5. Review of Radiocraohs Radiographs for a total of 81 B&R welds, SS ft of Chicaco I Bricge & Iron (CB&I) containment liner plate welds, nine j Southwest Welding Co. welds and ten ITT Grinnell welds, involv-ing 1254 film were reviewed for compliance to applicable recuiretrents. All weld' radiographs had been previously reviewed.
and accepted by the licensee or his authorized. representative. j One hundred twenty-five additional film were also reviewed in
- ne radiogra: hic interpretation room for the purpose of evalua-ting three interpreters' aDility to follow.5&R procedures and j
- neir abi.lity to properly interpret radiographic film. -
Concitions were disclosed by the NRC CAT inspectors in six welds
.that recuire attention and correction (See Table IV-1). These conditions were discussed witn the licensee representative.
~nese ccnditions are sur:mari:ec below:
- a. Brown ind Root weld radiographic film =24555-CS-1-RS-30 revealed an indication of insufficient fusion (IF) wnich
' was rejected on the original film by,the S&R interpreter but was not identified on a subsquent repair snet. This ceficiency was identified by the fiRC CAT inspector. Brown and Root prepared a nonconformance report (hCR) and the new radiograph that resulted from this f4CR confirmed the IF.
The new radiograph also revealed that the angle of the repair shot had been taken 180' from the original shot,
- w urtersi:e weld was found (not part af pipe sample) on a 2-in, a v eter scck-e-let on piping locatec in CC puma room 01. This sock-o-let is welcec to a 3-in, line snown on 150 CC-2-AB-016.
IV-10
5 ... ..,;
.thus changing the . appearance of the IF on the film and reducing the likebood of its being icentified,
- b. The NRC CAT inspector review of B&R raciogra hic film
=4162-MS-1-RB-081 revealed an area on the fi; , that coin-cided with the pipe weld zone, vhich was more dense J(thinner material) than that part of the film shewing the parent material.
B&R prepared an NCR and later confirmed a thin wall section by.taking an' ult-asenic thickness
- reading. The area was approximately 0.014-in, under, minimum wall thickness. This radicgraph had been accepted by B&R OC. B&R stated that weld repa. irs to this area would be made.
.c. B&R film =29030-FW-RB-020 revealed an area of IF and l'
aligned enlongated porosity in excess of 1-in. that had been accepted oy B&R. An NCR was prepared and new radiographs were taken. The new radiographs revealed the same condition and the wela was rejected. The licensee representative stated this weld will be repaired. d. B&R film 726669-CC-AB-018 revealed an indication of IF :na was not marked by the interpreter (the same interpreter involved in film 29030). This incication was hcwever, icentified by anotner. B&R interpreter when a subsecuent repair shot was evaluated. . The NRC CAT inspector's review of the original film for the sucject weld revealed indica-tiens of incomplete fusion similiar tc the repair weld radicgraph. Both film evaulations were made within a short period of time. This ceficiency in film interpretation was referred to the licensee representative for folicwuo and Corrective action. *
- e. During the NRC CAT inspectors review cf radiography film (2C519-CS-lRB-02B, 29018-CS-2-AB-091) two welds were cbserved to have censities that are telow minimum in tre area of interest or are outside tne -3C' - 15% for peretra- 8 meter requirements in the ASPE Code anc B&R precedure. As a f:liewup to the above, it was learne: that B&R hac cr.angea tre three-view RT technique to a four-view tecn-nicue approx 1matel censity problems. yB&R two is years new ago in tnetoOrocess correct of icw-film reviewing radiographs of welds shot before that time with three-view 1 technicue. The NRC CAT inspector was informed by the i licenseee that any radiographs fcund that co not meet code requirements will be re-radiographer, f.
Initial review of approximately 10-ft of' radiographic film taken of containment linear weld seams revealed linear inoicaticns. Subsecuent visual examination cf the liner
- late, in the area of interest, reveaiec that tne liner plate c:ntainec grinding marks adjacen to tne weld. On l
- ne basis of a correlation of the grinding marks on *he ;
IV-ll
. o .
i i liner with marks on the; radiographic film, .the NRC CAT inspector agrees that' the welds are acceptable. No. deficiencies were identified in. the ' review of Southwest Welding and ITT Grinnell sample of radiographs.
- 6. Review of NDE Procedures, Practices, and Personnel-Qualifications
- a. Review of Brown and Root NDE Procedures
-' A total of 19 procedures were reviewed by the NRC CAT inspector.. It was observed that most of the procedures had been revised within the preceeding five months. With-the exception of QI-QAP-2.1-1 and QI-QAP-10.2-3, the procedures i appear to be adequate and in good order. Coments on these' procedures. follow: l (1) 01-0AP-2.1-1, Nondestructive Examination Personnel Certification This procedure does not detail specific requirements for work experience and 'how the. NDE Level ill makes his determination for qualification before certification as. required by SNT-TC-1A, 1975 edition.
(2) 01-0AP-10.2-3, Radicorachic Examination This paragraph allows the use of Ir 192 on steel as thin as 0.125 without explanation. Review of records disclosed that this procedure requirement was based on' a' qualification film using two flat pieces of raterial in the center of the film. This set of ccnditions is not representative of the geometric concitions.that would be encountered on.an actual raciograph of piping welds. The qualification film revealed a arginal 1T s ensi ti vi ty,
- b. Certification Records Decords of 63 separate certifications involving 22 persons were reviewed. There was .one certified ultrasenic record for a Level II that centained no evidence of ex:erience in angle beam, shear, wave examination. A subsecuent inter-view with this persort and a signed document confirm that he had no experience with shear wave techniques. The person stated that this information was made known to the Level III before he was certified. The requirements of ANST-TC-1A were not met in the case of this individuai. The NRC CAT inspector was informed by the licensee that this person had not performed any ultrasonic work for B&R.
IV-12
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- s. .. y 1
- c. Incerviews Twenty persons were interviewed for determining their It understanding of :rocecures, and their' ability to perform tne operations for which they were certified. Each person interviewed appeared to have a good attitude toward renage-ment and procedures. They all had a current copy of procedures and were very open and willing to ciscuss their assignments,
- d. Work in Procress (Method Demonstration)
- Observations of 21 separate nondestructive examinations were performed. Of the 21, nine were radiographic, one i ultrasonic, and eleven liquid penetrant. Of the nine ceronstrations in raciograpny, two were field setups, three were for welders' qualification, one for darkroom proce-cures, and three for in-process film viewing.
(1) P.adiocrachy ' In all cases, the personnel demonstrated a gooc understanding of how to use the ecu.ipment, and how to perform the nondestructive examinations. (2) Ultrasonic One person certified at Level II was asked to conduct a calibration procedure for 3/4-in. plate. The calibration was performed satisfactorily. (3) Licuid Penetrant All personnel performed in a satisfactory manner except in tneir understanding for contamination of tre penetrant a: plication by brush. This is not considered a major problem,
- e. 'CE Ecuicment Calibration ard Material Verification Over 47 items of ecuipment and materials were cnecked for calibration, certification and compliance witn established requirements. They incluceo:
8 ultrasonic instruments a densitometers 15 cassetts 3 survey instruments a censity strips 3 Ir192 decay cnarts
~he items reviewee satisfiec :ne specification anc procedural requirements.
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- 7. Review of: Welder 00alification From the .s_ ample' piping . runs inspected, welder identifica tion numbers noted on piping' welds were. selected and the welder performance qualifications recoros reviewed for compliance to WES-031, " Specification for the Qualification of Welcers and J Operators".
The welders whose qualifications were reviewed are identified below by their assigned symbols:
. l nFK AWJ AIM
' AWD; AUA BIG AHX APL .AHK AHF' ' A F0 ARP AGM BCO BGU zAga A review of WES-016, " Schedule of Standard Test Welder Qualification Matrix and Welder Performance Qualification Log" was. conducted. WES-016 specifies the various weld tests for qualification and requalification of. welders. A review of.the welcer qualification matrix, listing the cross-matrix of the welcing procecures applicable to each welder, was also concucted ;
to ensure that tne essential varihbles for welder qualification in accordance witn ASME Section IX, were not violated. No deficiencies were cbserved in the welder qualifications reviewec. S. "eview of 51R Welder Qualification Procram I
.S$R has irstituted a prograni whereby the weld engineering unit utilizes welding' technicians in the field to oversee und assist
~
welders in the cerduct.of their work. Additionally, tests for qualification, (both the types of tests administered to newly nired welders and to welders being upgraded) exceed the require-cents of ASME Section IX. Furthermore, B&R has implemented a progran to cualify welders by radiographic testing rather than teenanical testing per ASME Section IX. Section IX of tne ASME Ccce ;ermits either radiographic or mechanical testing. Radiographic testing normally is more difficult to pass, tnus requiring a higher skill level. No discrepancies were observed during the review of this program.
- 9. Summarv - Weldino and NDE Activitiej, Overall, the'S&R program for welding, welders qualification, NDE I and general training activities appears to be effective anc well )
administered. This coservat1on is supported by visual i examinations, coserved NDE results ano practices, witnessing ' field welos in process and the general level of workmanship demonstrated. IV-14
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'V. CP/IL AND STRUCTURAL ' CONSTRUCTION A. C.e ECT:vs d 1
Cetermine by' review of documentation and by independent evaluatien of l comple*ed work, wnether work, inspection anc test activities relative' i
'to the civil engineering area were accomp,lished in accordance with pr:fect specifications and procecures. - -
]
The specific areas evaluated included concrete placement, ccncrete testing, soil inspection, protective coating, containment liner, and structural ~ steel installation activities. B. DISCUSSION
- 1. Concrete Placement This area of inspection was initiated by a review of the procedures.
delineated in the project concrete specification and the " Civil Ins;ecticn Manual." As tnere was little or no work being perforced in tnis area, the evaluation of tne concrete placement program was limited to a document review of completed work activities. Five concrete placement record packages were reviewed. The place-ments reviewed were as folicws: PL AC E!'.ENT DATE 201-2305-01 9/13/79 201 48S5-018 7/12/80 CO2-E778-052 5/C5/80 201 4523-008 9/21/79 105-9E55-002 9/15/80 "e N;; cat ins:ector at ecotec t: correle*e all relatec t::amentation reviewed to tne abcve concrete placecent recorcs. r 's related documentation incluced tre following inspection and test recercs: Cadwele Inspecticn Records Cacaeld Sleeve Inspection Receres i Cadweld Splicer Qualifications Cacweld Splice Testing Reports V-1 b
l
^
i 4
.c Reinforcing Steel Inspection Reports .
Miscellaneous Steel /Embecment Inspection Reports
, Concrete Inspection _ Records.
' Curing Inspectio'n Reports-li In-Process Test' Records
- Additionally, records involving associated grout and pressure grout placement, were reviewed, Five " Compressive Strength of Cores" and:
five " Defective Concrete Placement" recorcs were reviewed and com- i pared to the applicable Nonconformance Report (NCR). l In general .the. records reviewed reflected that concrete placement -' l activities were performed in accordance with the site procedural requirements- and the licensee's FSAR commitments. ;
- 2. Concrete Testing A review of the procedures included ~in the " Civil Testing' Laboratory Manual" was performed. The evaluation of the concrete testing program was limited to a review of completed testing activity docu-ments.
Semples of.various civil testing laboratory' inspection records were l selectec. These samples included: Mix Design Data (Two Mixes) Compressive Strength Tests Selected Aggregate Tests Selected Water Tests Related Nonconformance Reports Acciticnally, certifications for cement, air entrainment, aggregate, anc ecoxy grout were reviewed. Reinforcing steel and miscellaneous steel certifications were simili6rly reviewed. , During the review of these various test reports, it was discovered that no mix uniformity tests had been performed to the commitments contained in Section 3.B.1.6 of the FSAR. Paragraph 5 of this section,
" Construction of Concrete" requires that concrete construction, including mixing, be in accordance with CC-4200 of ASME-ACI-359.
S'ection CC-4223.2 of this document, " Operation of Mixers" states, "The range of mixing capacities and corresponding mixing times for all mixers shall be determined by the performance of mixer uniformity tests as specified in ASTM C94, " Specification of Reacy-Mixed Concrete". Table CC-5200-1 cefines the testing "2
4 3; ? g
-frecuency for these recuired tests. The licensee could provide no evidence that these tests had been performed. Thus, tests to verify proper cperation of the. concrete mixers were not performed during concrete construction.
3.' Soil Inscecticn Ten ' soil inspection test records were reviewed and found to have been performed in accordance with site procedural requirements. It
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Was noted tnat a number of these tests required several retests, but acceptance criteria and test performance were noted to be in accor- 1 i dance with program requirements. . 4 Protective Coatino i Three protective coating application inspection records and the associated acnesien tests were reviewed. One in-process prctective c:ating application .was cbserved. Curing this corti:n of the review, NCR C-650 was rev'iewed relevant
.to protective.ccating applications. This NCR documented deficiencies relevant to a safety-related concrete placement. The latest revision of the-NCR recuired the application of protective c: stings over the concrete repairs, but deleted the requirements for the applicaDie achesion test. Licensee representatives indicated'
~
this area would be' reviewed under an inspection "back-fit" program
'cr protective coating application. Hewever, since this program had r:t :een initiated at the time of this inspection, ifcensee representatives assured the NRC CAT inspector that this matter would receive apprecriate review.
- 5. ::ntairrent Liner Installation Pr:cedures for the installation of the containment liner are de#ined
- y ne " Chicago Eridge and Iron (CB&I) Hancbook"; S ecifically, 3cck
- 2. Secti:n 11:a arc Section I!!b (Contract 74-2427/25U). Three separate traveler packages were reviewed t these procecures.
Sar:les were also selected from the .following files: Verder Material Certifications Visual Ins:ection Reports LPT Examination Reports MPT Examination Reports . UT Examination Reports
' Radiographic Inspection Reports
'Ac:ual rac;cgra:hs were reviewed arc are cccumented in the Welding /NCE l secticn Secticn IV of tnis report. I
.-3
7 ' 1
- The "CBI Monconformance Control List", and the reference to the applicable repair checklists were compared.- "CSI Request for Acceptance of Nonconformity as a Deviation" was also reviewed.
- The records reviewed reflected that the containment liner installa-tien activities were performed in accordance with the site procedural . requirements.
- 6. Structural Steel Installation
, Proc'edures delineated in the "Non-ASME Mechanical Inspection Manual" related to structural steel installation activities were reviewed. i Four structural and miscellaneous-steel installation inspection records were reviewed.
One portion of an ' installation was observed in the field. Applica-tion of traceability, where applicable, was noted. Documentation
. reviewed included a selected sample'of:
Receiving Inspection Reports Material Requisition Requests Applicable Certified Mill Test Reports Applicable Certificates of Compliance Fabrication Traveler Summaries Apolicable Design Changes and Nonconformances
- ocurentation reviewed and the activity observed reflected that structural related activities were performed to the site prccecural requirements and the licensee's commitments.
l V4 l 1
1
.c . . j s a p ~j l
'. ! . ROCUFEMENT.' STORAGE A!;D MATERIAL TRACEABILITY A.' Objective; The objective of this portion of the inspection was to examine on-site procurement, receipt, storage, maintenance and traceability of safety- '
related equipment and. material to cetermine the adequacy of the licen-see's program relative to these activities. ,
'B. Discussion '
The -approach used to perform this part'of the inspection was to tour ne site and observe construction activities in progress. Various site personnel were-. interviewed and samples from different disciplines at various-stages of work were selected. Delivered equipment and material at locations 'in ' storage or installed in the plant were also inspected. t: Applicable documentation relative to these activities was also
~ reviewed.
Organi:ational' charts and precedures were reviewed and t!iscussed with site personnel. Offices and otner site facilities were toured and examined, including tem;orary offices,-warehouses, outsice lay-down areas, and tne plant' areas of Units 1 and 2. A selection of 71 samples was made for procurement and storage consi-ceration from mechanical; electrical; civil / structural; instrumentation and control; heating, ventilation and air conditioning (HVAC); welcing and miscellaneous categories. In addition, 73 samples were selected specifically for material traceability, including 58 Weld joints, each involving two materials to be welded with one or more weld filler aterials.
~be following describe the results of inspection in the areas listec.
- 1. ? :curement and Receivine 1
a total of 71 Our: nase orcer files for safety-related ecuipment ano 2terial aere examined, a detailed ins;ection was mace of 35 1 51rf.es. Referenced engineering specifications, cuality recLicements, sucmittals, approved-vendor status, revisions, ano trer aspects were reviewee. 1 ality Centrol (CC) authorizations to ship from vendors' plants anc on-site CC receiving inspection documentation were examined. The recei:t of recuired material certifications was examined.
- ecords reviewed reflect that procurement and receiving activities l were performee in accordance with procedural requirements. It was noted that the computeri:ed system implemented at the site provicec idecuate control of vendor suomit:als and engineering approval of test reports and data, i
VI-1 4
g> H' .. , ! ? .. u - h ;-c.:, e
+ .
- 2. Storage and Maintenance
- a. Storace Facilities - General 4
Warehouses and lay-down areas for Class A, B, C,:0 and'E storage levels were examined. The~ClassLA storage space recuiring temperature and humidity control:was found to be within-control limits. Discussions with warehouse personnel revealed'back-up provisions to. maintain control in event of a site power outage. .
' Weld . rod storage areas'in Warehouse A and ovens in Field Weld. Rod Room #2 were' examined and found-to be. maintained within~ required temperature limits.
Storage facilities observed and records reviewed reflected that the identified storage facilities comply with site procedural-requirements. . However, a lack of control over two unmarked areas apparently used as; scrap yards was discovered. These areas and contents
' therein: were as. follows:
'(1) Numerous piping, valves and other items were identified on -
the ground in a fenced area with-the gate' removed on the East
' side of'the Pipe Shop. No' signs identifying this area were observed.
l (2) Numerous cables, motors:and other items were found on the i
. ground in an area with no enclosure on the North side of the Electrical Lay-down Area, No signs identifying this area were observed.
l The observed ~1ack of control of these.two areas does not ee ~NRC l or site proc'edural requirements for the control of ecuipment and { material I d
- b. Storace'in Warehcuse Buildincs ,
1 The storage of equipment and material in storage bins anc lay-down areas within warehouse builcings was examined. Activities observed and recorcs reviewed reflected that storage activities in warehouse builcings were performed in accorcance l witn site procecural requirements. I
- c. Storage in Outside Lay-Down Areas The storage of equipment and material in outsioe lay-down areas was examined.
- 1 Corrosion, dust and cirt were noted on a numoer of safety-related items oue to the lack of covers and/or protective coatings. For example, 128 ITT-Grinrel hanger struts and approximately 400 l VI-2 1
NPSI hanger struts, with associated bolts and nuts, v.ere noted in outside lay-down areas north of Warehouse A. Nuts, bolts and bearing pins were noted to be very rusty. Bearings were noted to ! be corroded and dirty. Specific samples inspected v.ere: (1) The nut and threaced portion of the strut was corroded relative to ITT-Grinnel Hanger Strut, Serial No. E3473, ID No. E-TZ-040, Class 2. Bearing pins and retainer rings nere corroded. Searings were dry and corroded. (2) The bolts, the nuts and the bearing pin for NPSI-Hanger I Strut, CP-0046A, ID No. SI 2045418542R . Class 2 were ! corroded. The bearing was cry, corroded, and covered with dust.
~, , ., I D (3) Corrosion was noted on outside of the Joseph Oat Corp. .
Automatic Nuclear Strainer, CP-0029A, Serial No. 23080, 1977, ,pt', Zurn Tag No. CP2-SWSRAU-02, Zurn Serial No. 6250. Corrosion was also noted on similar equipment stored in a nearby ?-
'>L' location. '
d) i These examples indicate a failure of the licensee to satisfy tne FSAR commitments and to properly follow site procedural requirements for protection of material and equipment in storage,
- c. In-Place Storace of Ecuioment
he storage of ecuipment in place in the CPSES plant was inspec-ted. Corrosion was noted, and some wood, metal and pacer trash aere noted adjacent to safety-related equiprent. Specific examples noted were:
9.m < (1) The Motor Operated '/alve, Serial No. 43554, Tag No. GGC3025GMO, Safeguards Bldg.-2, Elevatien 790 ft. was ,,g..Phk
?
coserved to be witnout a protective cover. The crive 'r# ' rechanism was r.oted to be dry. ,, (2) The Auxiliary Peecwater Pump and Motor, Puro CP2 AFA:,0-02, d' and Motor CP2 AFAP.0-02, were not coverec. Cerrosion .;as neted on tae base and wood, retal and pacer trasn were nctec W/ . on anc around tne case. l3) The intake filter of the Component Cooling Water Pump Motors CFA-CCAPCC-01M, and CP!-CCAPCC-02M were clogged with foreign materials and cebris, thus restricting tne air flow to the motor. (a' Construction materials were present on the Residual Heat Pemoval (RHR) Pump Motors, TBX-RHAPRH-01M anc T3X OHA RH-02M. 011 was observec to be crioping from the inside of one RHR
-'otor casing.
The examoles of imorecer storage of installed ecuioment centioned above represent the licensee's failure to satisfy tre site storage requirements, VI-3
,f.
- e. Maintenance The activities to control and perform maintenance by the mill-wrights for mechanical equipment, and by the' electricians for electrical equictent were reviewed. A centrali' zed card record system is used by each group. Generic maintenance schedules are applied where applicable, and additional instructions are obtained from the appropriate discipline engineer when needed..
For each piece of equipment requiring maintenance, a card listing !
'the maintenance work and schedule is used. A QC representative verifies the work and siens after each maintenance activity has been completed on the equipment. A number of maintenance record cards were reviewed, and.no deviations were noted. .
I The informal manner (often by telephone) of identifying equipment requiring maintenance, particularly special maintenance to comply with vendors' instructions, was questioned by the NRC CAT
-inspector. The actual maintenance work and schedule are specified by discipline engineers' for use by the crafts, but there was concern that required maintenance may be omitted from items in storage at the plant without a more formal system of control. Similar concerns identified by the licensee relative to maintenance requirements and scheduling of. maintenance are discussed in' the Quality Assurance section (Section VIII) of this report.. All maintenance records reviewed indicated reintenance was :erformed to the requirements in accordance with the specified schedule.
In addition, a lack of adequate maintenance procedures to protect safety-related equipment from corrosion and/or other damage af ter installation and before turnover to TUGC0 for operation was icentified. During a teur of the plant, extensive cerrosion was noted on the tube support / spacer plates of a Unit-1 Containment Spray Heat Exhanger that had the outer shell removed for an internal modification. Discussions revealed that the licensee was aware of the corrosion condition. There had been a time delay between tne installation of the heat exchanger and the turnover to TUGCO. Thus, the Nitrogen blanket required prior to piping installation hookuo hao been deleted at the time of piping ncokup, and no protection against internal corrosion had been applied after oiping hookup. This problem lec to an examination of the two heat exchangers for Unit 2 by tne f3C CAT inspector. The Unit 2 Containment Spray Heat Exchangers Purchase Order (P.O.) CP-0050, Joseph Oat & Sons, Inc. vender storage and installation instructions were reviewed. It was ncted that a Nitregen blanket on the shell side (safety-related Class 3) was specified at 10 psig, to be checked monthly, for roisture prevention. No instructions were provideo for protection after installation hookup to piping. Site maintenance cares maintaineo by the millwrights called for checking the Nitrogen blanket weekly, out no instructions were provided for protection after installation hookup. Maintenance cards for the two Unit 2 neat exchangers revealed the following: VI-4
*,; 5. , *.
(1). For heat exchanger CP2-CTAHCS-02, site maintenance of Nitrogen blanket was deleted 4/6/80 at installation when opened for piping installation hookup. Thus, this heat
-exchanger has not been under a nitrogen purge or any other protection for over 21 years.
(2) For heat exchanger CP2-CT'HCS-01, site maintenance oi' Nitrogen blanket was deleted 11/5/81 when opened for piping installation hookup. Thus, this heat exchanger has not been under . Nitrogen blanket or any other' protection for' over 1 year. Licensee personnel are aware of this problem and are investi-gating corrective actions to remove any corrosion and present
~
future corrosion as the heat exchangers are. tested and pit.ceo in operation by adding a rust creventive to the liquid involved, anc
;:ossibly applying a chemical cleaning process. Consultat'ons ,#
with chemical engineering personnel of Dow Chemical Comoany and' ,t'2 Westinghouse (the NSSS vendor) are in progress to resolve this F prcblem. The licensee stated that a solution is'hntic;:ated'af ter t tne forthcoming Hot-Functional Test on Unit I has been ccroleted, and the internal corrosion condition of the Unit I heat exchangers is better cefined.
- 3. Traceability Significant effort was devoted to discussions and examinations of sa?ples anc recorcs pertaining to traceability of in-place material
- ack to engineering drawings and specifications and to procurement scurces and neat numbers. Generally, it was noted that the liter.see 9as claced a high cegree of emenasis on traceability. A total of'73 samoles t.ere examineo for traceability, including:
55 Safety-related piping weld joints, each involving two r L aterials and one to three weld filler materials 1 Class 1, safety-related structural neld joint
? Lots of raterials for safety related nangers ,
1 Lct of HVAC structural suoport material 2 Lots cf -VAC ouct material
- L it;-let saroles of weld filler material 1 Lot o# safety-related fastening cevices 2 L:ts of miscellaneous shim stock, anc hanger strut hareware S;ecific results of the inspecticn regarding the traceability area are as follows:
- a. Sa'ety-Related Picine Weld Jcints
- A total of 58 piping weld joints were selected for traceability.
Cf these, 42 aere selected by observation of ccmoletec werk in tne olant, an0 tne balance incluced aelcs 1centified oy other CAT team mercers in the acclicaole sections of this recort. VI-5 I r - - - - - - - - - - --
During early examination of 27 sample weld joints in the plant, 4 heat numbers could not be found on the pipe, but records were found to be complete. Further examination of the joints in the plant resulted in locating the 4 heat numbers that were not readily located. Discussions with licensee personnel revealed that CA reviewed spool pieces at the fit-up stage and checkeo all materials for correctness and traceability to heat nurr:ers prior to weloing, and again' after'welcing before QC signatures were applied to the records.
- Also, during the examination of records for sample weld joints, record discrepancies were noted for two weld joints. A review of the welds anc records involved revealed that design changes had been made, and that, while the actual welds were correct, the documentation had not been accurately changed. The two recotd discrepancies were corrected by a Component Modification Card (CMC) change, Serial No. 87228, initiated 2/1/83, and a Manufacturing Record Sheet (PRS) change, Serial No. MI 612, dated 2/22/83.
SLele results of traceability examinations of weld jcirts are as follows: j (1) Weld No.: W-21-1 (shop weld - pipe to valve) Welder: BYL System: Service Water ! Drawing: SW1AS14, Spool 703 Class: 3 p1 e: Peat No. N5294 Valve: Heat No. AJ330
, Weld Roes: Heat Nos. 746100 and 762550 (2) Weld No.: W-8-1 (shop weld - pipe to pipe)
Welder: AMA System: Chemical Volure Centrol ! Crewing: CSIAE003, Spool 302 Class: 2 pice: Heat No. 713876 Fire: Heat No. 28970 Weld Rocs: neat Nos. 42S2R3C8L anc 463628 (3} Xeld "o.: FW-1A (field weld - pipe to weld-o-let) Welter: AST Syster: Containment Scray Crawing: CT15E023, Spool 102 Class: 2 pice: Heat No. 280325 kel d-o-l e t: Heat No. 320J Weld
. Roes: 463638 'anc 546506 VI-6
i 1 i (4) Weld No.: W-1 (shop weld - pipe to flange) Welder: AGZ System: Safety Injection Drawing: 5I15B11. Spool 102 i Class: 2 ' Pipe: Heat No. SWL16M Flange: Heat No 54J2L Wela Rod: Heat No. C3220E
- l (5) Weld No.: W4-1A (Shop weld - pipe to pipe)
Welder: AXP, aTX System: Chemical Volume Control Drawing: CS1AB005, Spool 1202 C' ass: 2 Pipe: Feat No. 51891 Pipe: Heat No. M-2253 Weld Rods: Heat Nos. 4282R and 463628 i (6) Weld No.: FW-16B (pipe to 45' elbow) r Welder: BCJ, ATZ ' ' System: Safety Injection
- t. Drawing:
I 5I15B004, Spool 1902 Class: 2 Pipe: Heat No. 28970 i 45' Elbew: Heat No. U4LLH4 Weld Rocs: Heat Nos. 463552, 463638,/S46505 (7' Welo No.: FW-12A (pipe to pipe) Welder: AGR System: Sa'ety Injectien Crawing: S!!55C04, Spcol 4C2 Class: 2 Pipe: Feat No. M0635 Pipe: heat No. M0623 Weld Reds: Heat Nos. Consumable insert ;252R30EL are roc 46363S (3) Wel: No.: FW-ISA (pipe to valse) i Leicer: SCJ, 43R - 5;s:er: Sa'ety :njecti:n O rawi ng .: S!1SE004, Speci 6Q2 Class: 2 Pi;e: Heat No. M0623
s h e :
Heat No. (S/N) 657aCC35 Weld Reds: Feet Nos. Censumable insert E3047T316 and roc 746100 (9) ,;elo No.: FW-10 (field w.ela - pipe to 26' elbow) Welter: AGN System: Certainment Spray Crawing: CT155C23, Spool 702 Class: 2 Pi:e: Weat *;o. MC624 45' Eltcw: rest No. U4KCH
' ele R:c: Heat No. C322CE VI-7
p... y s
- n. . .
, .j
- .j
' /
.(10) . Weld No.: FW-7A (' field ield - pipe to 45* elbow)
' Welder: AFN,;ABT
. System: Containment Spray.
'Crawing:. CT158023, Spool 802 Class: 2' Pipe: ; . Heat No. M0624 l
45' Elbow: Heat No. U4LLH4 { Wele Reds: Consumabl.e insert 2526T308 and rod 463730 . NOTEt Certifications verifying heat numbers for these samples were'in the central files.
- b. Class 1 Structural Weld Joint
\ g
-One weli on a large structural' support furnished by Westinghouse s and fabricated by Teledyne Brown Engineering was examinea for ,
traceability, with satisfactory results as follows: 4 Weld: Mounting Plate to Shim Plate (no number assigned) Welders: 50A, BKX, CEA, BXV ' Item: Whip Restraint for Safety Injection System Crawing: Elv-0527-0508-2, Loop-3 Class: ASME III, Class 1 Plate: Heat No. E180514, Mtl. ASTM-A588
- Plate (Shim): Heat No. 1G0200, Mtl. ASTM-SA-36 -
)
Weld Rods: Heat Nos. 431L245, 52592, L21580 and 421P5'32 1 Certs: Chemical and physical certifications for Dhte I c:aterials and weld rods were in the recorcs~ fiQ.- M
- c. HVAC Structural Support Material ;/
4 3* #
?>
,1
' One lot of angle iron purchased uncer Purchase Orcer Yo.1 TUSI-1148 for Bahnson Service Company (HVAC contractor)lwas examinec for traceability, with the following satisfactory results: Itam: Ic0 pieces of galvanized angle iron 4"xx4"xi"x20 r
}
Spec.: f4tl. ASTM A-35; Galvanizing ASTM-A-123-78 e, Heat No.: 425340 ' M" i + C:ler Cece applied by Bahnson: Fed-Orange t- I Cer s: 05ysical, chemical and galvanizing certifications 4 were in records file, ,t i
/-
- d. HVAC Cuct Material f, .
Two lots cf retal sheets purchased under Purch'ase Orcer No. ' 1
't TUSI-0776 for Bannsen Service Company (HVAC contractor) were t '
' examineo for traceability, with the folicwing satisfactory V results: , <
b }
,)
VI.8 'i
~
{ r (1) Item: 149 pieces of galvanized sheet metal 48"x120"x10 GA Spec: ASTM A-526, G-90 coating i Heat No.: 500H3480 { Color Code applied by Bahnson: Caution Yellow l Certs: Physical, chemical and ccating certifications were in records file. ; i (2) ltem: 28 pieces of galvanized sheet metal 48"x120"x10 GA j Spec: ASTM A-526, G-90 coating ' Heat No.: 516N1509 Color Code applied by Bahnson: Flare Red Certs: Physical, chemical and coating certifications were in records file.
- e. Weld Filler Material Three purchase orders (P0s) fer large quantities of weld filler ma:erials were examined for traceability as follows: ..
1 (1) PO 20725 to Sandvik, Inc. - Examination of records showed traceability to specifications, CC Receiving Inspection Reports, and certifications for enemical analysis and physical tests for various lots. (2) P0 CPF-1049-S to Purex Welding Products, Agent for Airco Welding Products. Examination cf record shcwed traceability to specifications, > CC Receiving Inspection Reports, and material certifications for chemical analysis and physical tests for various lots. (3) 70 14920 to Arcos Corporation. Examir.ation of records shev.ed traceability to specifications, ja , 1C iieceiving Inspection Recorts, and certifications for
't ) : ; cremical analysis and pnysical tests.
f ' ,1 9 ,(
#. Safety-Related Fastening Device (Stud) f t ) - sa' cie frcm the field was randcmly selected. In forma tion
'g
- -cvicec was that the item was a stainless steel stud with netatior.s CF60, 660T and VA.
t
~be sample satisfactory inspecticn results were as follows:
*i ,
'(
'l j .
a t
% \ ,
4
, 1 7
b - System: Heating and Ventilating System (VA) Drawing: VA-X AB-004C, Rev. 6 P.,0.: 130228,' Item 20-Item: 7/8"x5" Stainless Steel Stud, Spec.: ASME'SA453, Grade 660 Vencor: Texas -Solt Co. (on approved' vendor list) CC Receiving Inspection Report: .RIR 13847 Certifications: Chemical and physical tests'in file Heat (Trace) No.: DF60 Ccde Class: 2 Material. Requisition: MR-154401' ' Application: To attach flange of piping from Hydrogen Purge Exhaust; Filter Package to flange of heating and Ventilating System. NOTE: "T" af ter 660 d' esignates the vendor -(Texas Bolt Co. )
.g. Miscellaneous
'(1) Two purcha e orders' for safety . ,iated shim stock were examined, with the folicwing satisfactory results: 4 '
(a) P.O.: CPF-1648-S, Stainless Steel ~ Shim Stock Receiving Inspection Report: RIR-19319 Certifications: Received with shipment. (b) P.O.: CPF-1725-5, Stainless Steel Shim Stock Receiving Inspection Reports: RIR-IS899, RIR-18900 anc RIR-19633 Certifications: Received with shipment (2) Harcware and materials for a sample Fanger Strut were examined. Results are as follows: NPSI suppliec nanger. OWG. No.: .CT-2-001 406-532R, Rev 1 Drawing Item No.: a-Aigic' Sway Strut Harcware and Meterial Identification Control Numbers ( raceable to heat numbers):
. Pipe - NP 288 . Eye Rod - NH 631 Nut - NR204 Eye Rod - NH 631 j Nut - NR 236 Bracket - nF 1287
' Hex Nut - NB 230 Pin - hH E46-tctivi*ies observed and records reviewed reflected that the traceability activities were performed in accor:ance with site arccedural requirements. Empnasis on the necessity for good traceability was apparent throughout the site crganizaticns.
V!-10 1
~
VII. CUALITY CCNTRCL !N5pECTOR EFFECTIVENESS A. Objective The cbjective of this portion of the inscection was to determire if cuality control inspectors function freely in perf rming tneir tasks, witncut intimidation by craft personnel er supervision; and if inspe: tion persennel are cualified, trained and have the organi:aticral freedom to perform their tasks. B. Discussion
- 1. Procram Pecuirements The Quality Control Program is defined and impleme ted by the Cor-porate Ouality Assurance Manual, and by more detailed Quality Assurance procedures and instructions whicn are endorsed by management directive. Management and supervisor responsibilities nave been described in these procedures.
The Final Safety Analysis Report (FSAR) contairs implementing statements for 10 CFR 50 Appendix 9 and provide cceritment statements to regulatory guides including NRC Pegulatory Guide 1.58 > ( A!;51 fia5.2.5), which cefine Quality Program requirements. Quality Assurance procedures were developed to implerent these ccmitments. For example, CAP-2.1 defines the requirements fcr the training anc certification of mechanical inspection persennel.
- 2. h :; ram molementation Ir:ierentation of tnis porticn of the program was cetermined fect
- 1scussions with Cuality Control personnel and their su;ervisors, 1
'r:m a review of inspector training, from a review of certification Ortcecares and tne ins ector verification files, an: f r: a review cf tne secuence of recording and permanently filing ne results of j J
ins;ecticns.
)i
- ctarviews were held with 63 instectors randcmly selected frc- Texas l miities Generating Company (TLEO) and contre: tor organi:stiens l
- erf:rminc irs:ectices en site (Brcwn & Root, Bahnsen Services, and l
^:r ir ell). These discussion included the ins:ector's area cf assignment, background, training and educatice, perception of h0w tn r:ugnly ins;e: tors were trained and precared to perform inspections, and involvement relative to construction craf t interfaces, including the presence of'any form of intimidation.
Cccents c:ncerning inspecter qualifications in the area of n:ncestructive examination (Secticn IV) and s ecific ccm ents ' icncerning electrical (Section II) anc mechanical (Section III', irs;ection procecures are sresented in the accli:acie secticrs #
!".i s reco rt.
1 VI:-1
.. . = ~
j (
- a. Insrecter Qualification / Certification (1) Inspectors were recuired to attend training sessiens, perform independent reading of standards relative to their inspection area, and were tested with regard to this training ma.terial.
Inspectors were reovired to participate in on-the-joo training (0JT) which was verified by a senior ins;ectcr designated in writing to verify this training. Appropriate forms and certificates were on file, in
' accordance with ANSI N45.2.6 requirements, attesting to the inspector's background, experience, education and training and certifying an inspection capability in particula'r construction activities.
(2) During the review of the training records and from interviews with supervisors, it was found that some OC inspectors were certified with less experience than required. For example:
- a. Three individuals were certified Level II (L-II) as mechanical inspectors having authority to witness pumo or component disassembly and reassembly with cualifying experience only in welding and nondestructive examination.
- b. One individual was certified L-II as mechanical ins:ector having authority to witness rump or component disassembly anc reassembly using ecucation as a factor in the qualification process when the education was frcm a non-technical, unrelated college cegree.
- c. One indivicual was certified Level I (L-I) electrical inspector after only 3 weeks of electrical ins;ection ex;erience,
- d. Two individuals were certified L-I anchor bolt ins:ect:rs witn less than 1 montn ins;ection execrience.
Af451.N45.2.6 requires a minimum of 6 months experience for L-! when a candicate has a hign school cicloma or ecu1 valent ecucatien, and 3 years experience for L-II when a cancicate has a high school diploma or ecuivalent ecucation,
- b. Recercinc :ns:ec-icn Results (1) The Inspection Report (IR) form was the docurent prirarily used to record inspection results. A review was race of ine recorcing, reviewing, and filing of inspection reports witn the follcwing results:
- a. The FSAR and the TUGC0 resconse to NRR Generic letter 81-01 state tnat TUGC0 is in compliance witn Regulatory Guice 1.58, which encorses AN5! Nd5.2.6, " Qualifications cf Ins;ection, 5xaminatier are Testing Persenrel f0r Nuclear Pcwer Plants." 35: M5.2.6, Section 3 anc Taole 1 VII-2
i i l I I provides the levels of capability for project functions { and defines them as:
. L-1 capable of recording inspection, examination, anc testing data and implementing inspection, examir.ation, and testing procedure.
. L-11 capable of performing as a L-1 plus; Planning inspections ....
Evtluating the validity and acceptability of inspection .... results Peporting inspection, examination .... results Supervising equivalent .... personnel Qualifying lower level personnel The requisite qualification for these capability lesels is provided within Section 3 of the standard.
- b. The NRC CAT inspectors found during interview and cocurent review tnat:
With a few exceptions, as stated above, inspectors were experienced. In the areas reviewec, QC inspectors completed anc sigred irs. L-11 certified inspectors in the electrical and , instrument areas of ins;ection reviewec the irs, bt.t did not dccument tneir review. In scme inspecticn discicli-nes, sucn as mechanical (non ASME) and conduit supcorts experienced lead inspecters (cesignated L-1) reviewed the IR before it was sent to file. In other inspection disciplines, such as Civil CC, there were no routine reviews per#crmed by an experienced lead inspector. In eacn of :nese cases, the re; orts were cet signed by the reviewer. Cccurent reviews revealed that inspection instructions and ins:ection re; orts were cetailed and inclusive. Licensee representatives indicated tnat the reascn for these ceisiled instructions anc re;crts was Inat they ccu'.d te conoletec oy ins;ectors with no accitional reviews by cther inspectors or supervisors. The intent of ANSI N45.2.6 is that a L-11 be tne inspecter of reccrd. The practices in place at the site did not ensure tnat this requirement was satisfied.
'. : I I - 3
~
j l l l
- c. Inscector Intimidation During discussions with inspectors it was revealed that in ene section of the inspection organi:ation threats and intimidatiers ,
had been made. This information was transmitted to iJC Regior. IV since an investigation in this area was currently in progress, i j An inspector from.a cifferent inspection area reportec previous l threats, which resulted in the craf t person taking the threats being removed from the project. )1
- Aside from the engoing investigation, it was revealed that agressive action ,:as taken by ranagement to prevent inspector intimidation.
Inspectors from one section reported that they were informed not to prepare noncenformance reports. This instruction was issued by memorandum and is discussed in Section III and Section IX of this report. VI:-4 i
F. 4 . .- , V!::..CUALITY. ASSURANCE A. Ctfective e .. The objective of this_ review was te determine the adequacy of the licensee's.Cuality Assurance (CA) Program. The program was reviewed to cetermine if it was appropriately established in instructions and maruals; and if the construction and quality assurance effort was monitored through aucits and other management act.icns. In addition, a sampling review of specific steps taken by the licensee regarging the eversight cf contractors, control of measuring and test ecuipment, cocument control, and control of QA records was made to determine if specific parts of tne program were implemented. S. Ciscussion
- 1. Fr: cram Requirements -
The OA program is defined by a management endorsed hierarchy of general directives and implemented by procedures at the corporate j anc site levels to control construction activities. These pr cecures were icolemented to satisfy the licensee's Final Safety Analysis Report (FSAR) commitments.
- 2. Or:c-am ! :lerentation .
- : lamentation of this portion of the program was determined based n reviewing -he organizational structure, input from other NRC CAT ins:ectors, tre construction audit program, samoling crawing revi-sicns in :ne construction work areas, and reviewing the contrei cf measuring and test ecuipment.
- a. Or anizatien !
T"e CA orgar4:ation includes the site construction cuality cuntrol Organi:ation wnich is incepencent fr0m tne site ccnstruc-ti:n ana;ement. The cuality assurance organization reports to tre " ice ; resident for Nuclear Operations, nhose responsibilities ircluce tne construction and c;eration of the Comancre ceak Steam Electric Station (CPSES). The autnerity and duties of :ne
;0sitions involved were described in the FSAR and corporate marcals. The audit organization was located at the Corporate Headquarters in Dallas. The CA organization was found to be in accorcance witn NRC requirements and the descr.iption contairec in tre FSAR. Crcanizational Charts incicated that a num er of staff
;csitions were vacant and hao been for an extended period.
I l VI:I-1
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- b. Audits The licensee's audit program was reviewed. At least 18 audits out.of 60, performed between 1978 and 1983, were selected and i reviewed with emphasis on the following major areas: auditor qualifications and certifications; audit planning and scheduling; audit instructions and check sheets; audit reports; audit results
, .and fol.lowup; and the overall effectiveness of the audit program.
(1) Auditor Qualifications and Certifications (a) The licensee qualification and certification program for i auditors and lead auditors was established in QA Procedure DG1-QA-2.1 " Qualification of Audit Personnel". (b) The certification records for ten lead auditors were reviewed. The lead auditors met the TUGC0 and ANSI N45.2.23 requirements. , The review revealed, bewever, that auditors not meeting the experience requirements for the lead auditor position had been assigned as " Acting Lead Auditor", but the limits of an acting lead auditor's authority and the guidance provided was not defined. (2) Aucit Plannino and Schedulino (a) Occument reviews and interviews revealed that aucit plans were developed and a system of check sheets were used as guides to the auditors to ensure that specific points were reviewed. Open audit findings were also reviewed during the audit. it was revealed that the check sheets were developed by the auditor assigned the audit c'* by l the audit group supervisor but were not approved by the CA Services Manager. Interviews revealed that audit schedules were developed I using previous audit findings, schedules, experience, arc discussions with construction site supervisors concerning l construction problems. There were no treno analyses or construction scheoules provided to the QA organi::stien :y the site; therefore, these ieportant sources of in-formation were not used in ceveloping the audit schedule. Also, there was no OA procedure to describe the eethod to be used to develop audit schedules or what management approvals the schedule should receive.
. (3) Audit Recorts Aucit reports provided a description of the audit scoce; identification of auditors; persons contacted; a summary of .
results and a description of any deficiencies or fincings. VIII-2
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(4) Audit Deficiency Recortino and Follow-uo i Audit deficiencies were clearly written and recuired timely respense by the management of the audited organization. The completed deficiencies were reviewed by the audit team leader for adequacy. Deficiencies were reviewed in subsecuent audits for completeness. prompt corrective action was not always staken on audit findings (See Paragraph B.2.b.(5) i below). (5) procram Effectiveness Although the audit program was in place, there were several 1 weaknesses in the program that decreased its effectiveness. (a)AuditEffort The aucit organization is located at the TUGC0 offices in Dallas. All audits are performed from that location. , There are eight auditors in the audit section. Although { audit teams are sometimes supplemented oy personnel from other sections of the QA organization, the eight member { audit section is assigned to perform audits of suopliers, subcontractors at tne construction site, construction 1 activities and startup. Of the eight auditors in the audit organization, four had technician background and fcur had a genersi nontechnical background. .;one of che ' auditors assigned to the group had engineering background or experience. Interviews revealed that approximately 1200 man cays were spent preparing for, conducting anc reporting audits at the site in 1982. A review of tne 32 ! aucits perfor~ed in 1982 revealed that about 330 e.an cays were scent on site performing these audits. TFis ascears to be a small cercentage of the total audit effort censicering ne level of effort ongoing at the site. Interviews revealeo that five accitinnal auditor , scsitices nad oeen autnorized for more than ene year ht i tre postrions were still vacant. (o; h :it Frecuency Interviews and document reviews revealed that: Twelve audits of construction activities were performed in 1981. Of these, six were of engineering and adminis-trative areas sucn an audits of IE Sulletins, and pro-curerent and six were of construction field activities. l "hirty-two audits were perfcered in 1982. Only nine of tne audits ere of cor.struction field acti ities, the
- - i j
1
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- other 23 audits were performed of engineering activities and 'other support areas. Of- the audits of construction field activities: one audit was cerformed of mechanical piping activities, one of restraint and snubber instal-laticns, two of electrical work, one of civil work, one of instrument and controls, and three of protective coatings application.
The frequency of audits of construction activities has been very low and may have contributed to the problems in the technical disciplines identified in Sections II, III, and IV of this report, (c) Aucit Effectiveness 4 Areas of the construction activity were audited; however, the audits did not identify major construction program problems, f or example:
. Bahnson Services was aucited yearly since 1980. The last audit was in April 1982. Although fabrication and installation activities and personnel cualificatiens were in the scope of the 1982 audit, such NRC CAT identified items as undersized v. elds, out of tolerance dimensional characteristics, and an inadequate struc-tural welding inspection program were not identified and resolved.
The electrical area of construction was aucited only four times since 1980. The audits did not identify tne cable smration issue as discussed in the Electrical Construction Section (Section II) of this report. Ineffective corrective action has been taken as a result of audit findings; for example: Ecuipment maintenance was auditse in August 1979 (aucit nuroer (TCP-5)). An audit fincing icentified that vencer instructions 'were not being incor: orated into engeing ma1ntenance instructions. The 'uly, 1981 QA aucit of startup activities (TUG-5) and the June 1982 Oua11ty Surveillance Surmary, QSR-82-023, icentified additional problems with ensuring tnat manufacturers requirements and qualification report requiren,ents had been incer-perated into the maintenance program. An Octooer 1982 ,
. aucit (TUG-14) identified the concern that ecuipment qualification reports were not reviewed during the 1 process of establishing maintenance requirements. The I j
VIII d 1
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, p.' o. - problem was identified in 1979, and it has not been resolved as evidenced by the 1982 audit. Thus, the effectiveness of the corrective action system for aucits is not effective.. The NRC CAT inspector's conclusion is that weaknesses exist in the established audit program. These weaknesses ! include the scheduling and frecuency of audits, the lack of effective construction program monitoring, and in lack of. effective resolution of some aucit fincings.
- c. CA procram Interfaces The NRC CAT inspector reviewed the QA organizations' overview of cocuments that prescribe actions taken by engineering, construc-tien, and cuality assurance personnel. A planned and systematic program is in place with one aspect being procedure review.
Interviews and docugent reviews revealed that: (1) The CA/QC manager or a senior representative reviews all inscection procedures. (2) The CA/QC manager or a senice representative reviews con-struction centrol procedures to ensure the precer construc-tien-inspection interface exists. (3) Engineering centrol procecures are not reviewed by the CA/0C mar.ager or a representative of the QA organization. The '.ack of proper interface with engineering may have contri-
- stec te the issues ciscussec in Sections I:, III, and IX of this rec:rt. These issues relate to tne final engineering cesign and the final inspection reports act being reflectec in the harcware.
- t. : rstructien Monitorino a :regran of construction monitoring was established. The c c;rar censisted of: nonitoring the ASME construction and installation activities performec by Brown anc Root (ESR), anc surveillance of concrete ancnor bolt installations.
The monitoring of ASME construction activities censisted of a j systematic review by two inoivicuals of B&Rs ccepliance to ; a::rovec instructions, precedures and/or drawings that imolement ! the requirements of the S&R ASME QA manual. The monitcring was l scheculed in acvance and proviced a review, altncugn less formal tnan aucit, of engoing ASME work activities. The surveillance of arcnor colt installation was performed in accordance with TUGC0 l Sr cecure CP-Cp-11.2 Rev, c. unicn indicates nat 10
!1 1
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P ' installations should be monitored each shift for each discipline. 1 A review of the monitoring record since September '1982 revealed ! that net nearly that many installations were monitoreo. In j September 1982, 35 to 40 installations were monitored. F rcm October 1982 througn January 1983, 30-40 installations were monitored each month. This is an average of monitoring one installation each day instead of ten each day. Interviews revealed that, although the installation activity had decreased, inspectors were assigned to inspect completed work and that the surveillance requirements of the procedure were not being met. The anchor bolt monitoring program is not being performed as required by the implementing procedure.
- e. Document Control n
ocument control includes the control of all documents associated with the design and construction program. This includes I drawings, procedures, specifications and manuals. Drawing control was selected for review as an indication of the implementation of document control. Controls had been established to fonnally Icg drawing and revi-sion. numbers into a card system and subsequently into the Compu-ter. Document control group personnel reproduce the drawings and revisions for distribution. Distribution is mace to a central pickuo area. Eacn major construction organi:at1on has assigned perscnnel to distribute the drawings from the pickup point to crawing control points and to work areas througnout toe site. A master drawing revision list is issued every three months and each organization is required to audit their areas to determine tnat all drawings are of the correct revision.
~he control of orawings was revle m e 6 the control and distri-bution centers for the pipe shop, welding engineering and the electric shoo. In addition to these office areas, drawing control was reviewed in construction work areas of tne auxiliary
- uilcing, the cable spreading room and the control recm.
Thest reviews revealed that: (1) The drawings in the control and distribution centers were of the latest revision. 1 (2) On February 3 and 15,1953, in construction work areas, out l of 70 drawings enecked by the NRC CAT inspector,15 were not i of the latest revision. l l (3) On February 22, 1983 construction areas were toured by the N:C CAT inspector. It was fcund tnct irorovecents nec ceen , race in crawing cont-cis. One crawing to an cut-of-cate MII-6
.,.y .s.
I revision was found during the tour, howeser there were still crawings in.the areas that had damaged or missing title blocks. Interviews with TUGC0 personnel revealed that ' drawing control had oeen' an ongoing proolem that required frequent attention. Based on this sample, document control still is weak.
- f. - Control of Measurine and Test Ecuicment ,
The system of control of measuring and test equipment was reviewed. The revi=w included equipment calibration, issue, and recall. Durirg a .tcur of the calibration facility the following areas were reviewed; the use of certified equipment during the cali- . bration process and the relationship of the certified equipment to national standards; the storage and separatien of calibrated 1 ecuiorent from equipment out of calibration or defective; and the general ccndition of the facility. It was found that the equipment used during calibration was
' traceable to national standards and that equipment was properly stereo. Ctner comments concerning the facility and some specific instruments ' checked are contained in the Electrical Construction Section (Secticn II) of this report.
The methods' of control and issue of el.ectrical cable crimoing
'tcols in tne-storage area, and condition of tools in-the electri-cal construction tool issue station was reviewed. The storage' area anc tne control ~of termination equipment was satisfactory.
The ecui ment' recall was-computeri:ed which allowed prompt ratification of craftsmen and ins:ectors when the teol calibra-tien cue date'was 3:proached.
~he centrol of eessuring and testing ecuipment aopeared satis-
' a c to ry .
'l:!!-7 i.
e
.IX. CESI N CHANGE CONTROLS AND CCRRECTIVE ACTION SYSTEMS '
A. CBJECTIVE The ;:urpo~se of this. assessment was to review program irclementation-with emphasis on actual safety-related hardware installed in tne field,
.as well as records including design change controls and any icentifiec n: unconforming conditions. related to installed hardware.
Samples were sele'cted-in the technical disciplines- to check program 1
- i plementation, as well as to ensure design control, design interface, l and: design verification' procedures satisfy NRC requirements and licensee commitments. Additionally, a sample of records were reviewed to cetermine'how nonconforming conditions were identified, disposi- i tienec, and the' extent to wnich corrective actions were taken.
l, B. CISCUSSION ' t
- 1. Cesien Change Control Procram
- a. Organization The organi:ation of the general site engineering, construction, and rocurement efforts were defined in peccedure CP-EP-3.0, Pev.
- 5. By this procedure, the Engineering and Construction Manager
.is responsible for the Comanene Peak Steam Electric Station (CPSES) design, engineering, and procurement. These activities are normally delegated to Gibbs & Hill, Westinghouse, and other contractors / vendors, however, Texas Utilities Services, Inc.
(TUSI) has been designated by Texas Utilities Generating Comcany { (TUGCO), the licensee, to retain ~overall responsibility for tnese activities and to perform design functions as necessary. The TUSI Project Engineering Manager is responsible for the general direction of engineering activities. These cuties arc res sensibilities were imolementec througn the Comanche Peak Prcject Engineering (CPPE) staff and organi:stier.al structure j anaged by the Comanche Peak Project (CPP) Disci:line Engineers. '
~he CPP Discipline Engineers were responsible "to administer an creeriv cesign enange program wnich complements construction and issures cesign acecuacy".
- . '.,iscicline Engineering Reviews (i) Civil Encineerine Mest of the design changes in this area were :rocessed via Cesign Change Authori:ation (DCA). Previous design changes .I processed prior to the current procedural requirements were j rocesseo via the Cesign Change /Cesign Deviation Authori:a-tien (DC/DDA). A tctal of thirty of both of these ty;es of cesign cnanges were reviewec. Ten, initiated as a result of a nerecnforming condition, and were reviewed and compared to the associated norconfermance report (NCR). Ten were tracec i
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by:the NRC CAT inspector to the latest drawing and/or specification. The final ten were initiated based on a licensee field inspection. effort. These last ten were compared by the NRC CAT inspector to the drawing and/or specification in effect at the time of the' inspection. Design. changes reviewed in this area were found to be processed in'accordance with procedural requirements' ,
~
The NRC CAT inspector noted th>c some original designs. in. this area'were processed via Component Modification Card s (CMC). The CMC, which is a design change document, was. processed in accordance with design change control procedure CP-EP-4.6, Rev. 7. However, these CMCs showed no evidence of Gibbs and Hill review, which is necessary to satisfy ANSI ! N45.2.11 requirements. ANSI N45.2.11, " Quality Assurance ; Requirements for the Design of Nuclear Power Plants" requires ' that field changes be justified and subjected to design controls cor:mensurate with the original design. The-respon-sible licensee engineering representative indicated these CMCs would be treated as a field change, and hence, would receive Gibbs & H111 review to satisfy ANSI N45.2.11. 1 A selected sample of Engineering Evaluation of Spacing. Variance Reports.(EESV), used in pipe support base plete installations, was reviewed. The expansion anchor bolt installation program was reviewed to the requirements of NRC ! Bulletin 79-02, Rev. 2, " Anchor Bolt Base Plate flexibility Analysis." It was found, from the samples reviewed, thut the licensee's program satisfies the Bulletin's requirements. (2) Field Structural Engineering Mnst of the engineering effort in the TUSI Field Structural Engineering Group at the time of this inspection involved L design of conduit supports. The original design of these sucoorts wes performed by Gibos & Hill to Revision 8 of the 2.323-5-910 drawing " package". From this point, the design effort was delegated to the TUSI organization at the site. . Installation was coordinated between engineering and con- I struction, witn installation performed to the 2323-5-910
" packages". After installation, the support design was then sent to Gicos & Hill for review to satisfy ANSI Nc5.2.11 j requirements. TUSI personnel prepared no DCAs to the "S-910" crawings, only CMCs where design or design changes were neces sa ry.
Location of conduit supports were determined by the use of criteria established from " Location of Support" (LS) crawings and the requirements of the. site Electrical Specification ES-100. Cable raceway supports were installed to Gibbs & Hill ori-ginal design drawings. ~USI p .sonnel issued DCAs to the support drawings for generic design changes, such as the IX-2
i M3- s , , c . 1 addition of a hange'r to tre raceway configuration. They. issued CMCs for design changes affecting an individual support. l The t;RC CAT inspector reviewed two structural calculations for. cable tray and conduit supports with the rescorsible
' licensee's representative. The design input, verification, {
1 and output (information proviced by the Field Structural Engineering Design Review Log) were reviewed. Stress levels, as defined in FSAR Section 3.8.3.3.3.1 and FSAR Section
* - 3.8.4.3.3.1. were properly incorporated into the support designs reviewed.
The.NRC CAT inspector sampled and reviewed sixty CMCs and fifteen DCAs. About thirty of.the CMCs and DCAs reviewed bad not received'the appropriate review and' approval by the-original designer, Gibbs & Hill as required by ANSI N45.2.11. Installations to the design document had been performed or were~in-process, but the design document had not been ' final' reviewed. ~ A review of the Gibbs & Will " CMC Master Incex" (structural) . indicated there were on the order of four-to-five thousand of such changes that had been generated but had not yet been " final" reviewed by Gibbs & Hill. It was determined that prcper verification of such changes mignt ultimately be accomplished. However, the volume of CMCs and CCAs remaining to be reviewed by the original designer, as well as those designs that have as yet to be performed in the structural area, is of concern to the NRC CAT inspector. The concern involves the adequacy of review wnich will be provided considering the approachin; Septemter, 1953 Fuel Lead Date. During this same review of CMCs and DCAs, there was evicence of a crotilem relevant to what revision of the design accurent a com enent or an activity has been inspected. CP-CPM-6.10, Rev. 6. " Ins;ection Item Removal Notice Form" adoresses subse:uent inscection following removal of an item, but not for accition of an item to a component. Furthermore, con- - struct1:n and/or engineering rather than quality control ceter .ine when an item is to be reinspected or when some type of inspection is recuired. l The "FC CAT inspector cetermined that inspections performed ; ano completed were not always to the latest issueo design ' cocument. For example, supports for twenty cable tray and concuit installations were examined. Of these twenty, twelve ; were not " final" inspected to the latest issued cesign
, cocument, even though records in the CA vault inoicated "f f.nal" inspection had been performed. Later CMCs covering design changes existed for all twelve of these installations.
In acditien, the licensee's CC i'nspections were performed in six instances to CMCs witn earlier revisions than the latest revision issued and in effect g the time the inseecticn was lx-3
c, , ., b
;i cerformed [Similar conditions were disecvered and discussed i in. tne Electrical and Instrumentation Construction Section of the report Section'II)]. y ANSI.N45.2.11, Section 8, states'that precedures shall be l
provided which " assure that the imoact of the change is"
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carefully considered ...and;information concerning the change is transmitted to all affected persons and organi-l2ations." As a result of the procedures' and records.. reviewed relative to this' area,'tne NRC CAT inspector considers existing procedures have not assured that the' information concerning the change is transmitted to .the appropriate organization; i.e. , the- Quality, Control organization . _ ' responsible for.the inspection ~of the cable tray 4 and conduit supports.-'This was substantiated by records in the QA' vault.
.(3) Electrical Engineering-
- a. Program Review Original design in the electrical area was performed by .
, LGibbs and. Hill. Design changes were processed via the DCA in this area.
The NRC CAT; inspector reviewed approximately thirty:DCAs in the electrical discipline. As was the: case in Fiela
- Structural Engineering, reviews to be completed by the '
original designer in accordance with' ANSI N46.2.11 are usually.only performed 'af ter construction or installation has been performed. DCAs reviewed were processed in accordance with CP-EP-4.7, Rev 7. During this same review, the, NRC CAT inspector also noted a;prcblem similar to that in the Field Structural Engineering relevant to what revision of the design document a ccmponent or activ-
~
. ity has been inspected. As a result,.the NRC' CAT inspec-ter proceeded with a review cf the site "Cesign Change Verification Group".
a
- b. Design Change Verification Grouc Review in tne Electrical Area
- P-CP-15.4, Rev. 3, "Cesign Change Verification" provided criteria. . . (for) review of oesign anc inspection documents to assure incorporation of design charges into the pnysi-cal plant.
This procedure' required that design documents be revieveed by tne TUGC0 Design Change Verification Grcup (DCVG) to ascertain whether or not incorporation of the latest cesign document had taken place, and if furtner inspection was required the DCVG "shall perform" it. Alsc, per procedure, the DCVG was recuired to select a representative sample of design changes per crawing IX-4 i
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l (thirty percent or tnree design changes, minimum, which- l ever is greater) for verification. i 1 A review by the NRC CAT inspector of the "CCA Verification Leg" indicated that of some fcur-hundred eleven design j changes verifieo, fifty-three had not been incorporated I into the actual design documents used for OC inspection, i Due to the nigh num::er of unincorporated changes, licensee i l represent 1cives indicated that the procedure would be { changed irom the current thirty percent sample to a
, one-hunc ed percent sample.
I However, the NRC CAT inspector had other additional concerns with the licensee's program at the time of this assessment. These were as follows: With the approaching Fuel Load Date, and the numbers of DCAs to be verified, the thoroughness of the review by DCVG may be jeopardized due to pressures from the con-struction ccmpletion schedule. Procedures for the DCVG in some cases recuired physical verification by inscection of design incorporation. It was unclear as to who was to perform the required inspec-tien, a DCVG incivicual or a QC inspector. Additionally, licensee representatives could not assure the NRC CAT inscector that the incividual who would perform the inspection function wculd satisfy the acplicable qualifi-cation requirements as defined in ANSI N45.2.6, "Qualifi-cation of Nuclear Power Plant Inspection, Examination, and Testing Personnel" in accordance with the licensee's F5AR C0mmitments. . L'nsatisfactcry conditions discovered during the verifica-tien process were not cccumented on an NCR Dut rather on a
" Request for Information of Clarification" (:F!C) form since conditions were considered to be only ";otential" nonconformances. As tne com enent or activity may net have received tne " final" inspection, the licensee stated:
"it was not c::nsiderec to be a nonconformance."
Docurented deficiencies relative to installation were not cocumentec en the Master Punchlist for " turnover", as the licensee representatives inoicated only NCR items were referenced on the master punchlist. These deficiencies were applied to a separate "ceficiency" list, and then were tracked by the DCVG. It appeared from this review that the CCVG cid not, incluce in their review electrical systems "turnec over" rer test or electrical systems unich have been energized. The NRC CAT inspector coulc cetermine no basis wny these systems should be excluced in :ne sample for cesign verifica:icn. IX-5
o .- The responsible licensee representatives, during the discus-sion of these inadequacies, commited to revise the program - by the addition of a tracking system which would correlate the affected inspection documentation to the latest related design change document. They further reiterated their intent to ensure that all safety-related compor.ents and/or activi-ties have been or will be inspected to the latest design document to satisfy NRC requirements. At the time of this inspection, as no work ha's been essen-tially fully completed from the design and construction stancooint for these areas, the NRC CAT. inspector cannot. determine from a sampling review whether or not the activity or installation was performed to the approved design and ,that an adequate inspection was performed to this approved design. However, from a sampling review of documentation from the program in-place, including the " final" quality inspections and the latest design documents, the existing design verification program would not satisfy the licensee's FSAR commitments [Further discussion of inspection' documentation is in the Electrical Construction section of this report (SectionII.B.8)]. Whether or not the licensee's proposed revisions to the program are adequate to accomplish the desired objective in the alloted time span cannot be determined. (4) Instrumentation Encineerino Instrumentation installation activities and documentation reviewed by the NRC CAT inspector indicated that tnese installations had received an appropriate inspection to tne latest design document. Supports for instrumentation were usually designed in-place. From a review of fifteen design change documents, the numbers of design changes as compared l to the installations comoleted were considerably less than those in other discipline areas reviewec. ; However, adecuate engineering reviews to the design changes were usually made after installation, similar to the process cescribed relative to other installation activities discussed thus f ar in :ne report. ; (5) Picin Succort Encineerin: ' l
- Two contract pipe design groups (ITT-Grinnel and NPSI), and the site Pipe Support Engineering (PSE) Group, were respon-sible for the design of large bore pipe supeorts. These three groups prepare a cesign for each pipe su
- purt. This cesign is then incorporated into the " Brown and Roct Hanger Drawings (30.Hl.s)", which are the drawings used for installation purposes. If the pipe suoport installation personnel deter-mine that a support cannot be installed as designea, PSE
#ield engineers are notified and cake changes as recessary to orocuce a design that can be installed.
!X-6
.t a . i I I When tne pipe and some of its supports have been installed, the Quality Control program starts its "as-built" inspection, documenting the as-built cimensions of the pipe and installed pipe supports. The drawicgs for the pice and pice su:perts are revised to reflect the as-built configurations, and are } i sta-ped "as-built verifiec." When a significant portien of l the supports on the length of pice have been "as-built j verified," a package is assembled and fonvarded for a preli-minary stress analysis. { ( i
' A stress analysis is performed to determine new stresses in the pipe and new loads on pipe supports. If the design requirements are appropriately satisfied, the drawings are then stamped " vendor certified" (VCD).
For small bore piping designs, the pipe support design activity commences when small bore piping is installed and is designed on location. PSE then issues the small bore su;; ort drawing. Installation then proceeds, with necessary cnanges performed as required. After incorporation of these cnanges, the drawing is "as-built" reviewed and a Cesign Review Orawing (DRD) is then issued. Class V hangers are " vendor certified" only when a stress problem becomes evident in the performance of the stress analysis. Otherwise, Class V hangers receive a review ecuivalent to the original cesign and incorporation of the latest change to the cesign. Cesign changes mace to any of these designs are processed via CMCs. Approximately seventy-five CMCs were reviewed to program requirements by the NRC CAT inspector. The review of these CMCs and inspection documentation in the ASME area by the ';PC CAT inspector also revealed that des.ign cnanges are apparently initiated as a result of the ;erfor-marce of QC inspecticn. These changes are then processec to accept the "as-built" configuration, rather than mocify the suc; ort to actually satisfy the design cocument in effect at the tire of the inspection. These practices co rot :rovice incentives to tne crafts to properly corstruct in strict ac:Orcance with tre cesign document. (a) V : Bulletin 79-11 Encineerinc Walkdown Jhis CPSES program was ccm;ared to the requirements a: dressed in the NRC Bulletin 79-14. " Seismic Analysis for As-Euilt ] datety-Related Piping Systems." CPSES engineering pr:: ram l
, requirements were also defined in CP-EI-4.5-1, Rev. 8,' l
, 9eneral rrogram for As-Euilt Piping Verification." :iscus-l siens altn tne responsible licensee engineering personnel I indicated that a detailed "as-built" insoection is beinc l e#*cr-ed anc is :eing analy:ed in acc0rdance with the l engineering requirements of tne bulletin. '
IX-7
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i ' ll i~f , t p, lThe responsible engineering representative for the "79-14" . s program was~. interviewed..and the actual mechanics-of the walkdown were discussed in detail. Basically the program requirements.regarding large bore hangers were, discussed. Also, ten. selected calculation packages'were reviewed rela-tive to this type of pipe support. Approximately fifty-five percent of the "79-14". verification program'was completed for ,CPSES Unit l'. A very small number of " packages" have completed the required reviews and are. l considered " final . Thus,-it was'not possible for the NRC CAT inspector to determine from a sampljng review whether or
- not the activity or installation was performed to the ep-proved " final" design and that an adequate inspection was performed to tnis approved " final" design. -
-(b) VCD Procram Walkdown by OC Inspectors-From.this review, it was difficult for the NRC CAT inspector u to determine the thoroughness.and adequacy of'this walkdown and/or inspection. Interpretations of the procedural requirements by licensee personnel ranged from a detailed inspection of many attributes' to a " location-only" walkdown.
Additionally, the NRC CAT inspector could not determine when a component was " final" inspected. The NRC CAT inspector considers that these inspections do not necessarily provide adeovate assurance that the elements / ccmconents nave been installed to requirs"ents. As incicated in the Meenanical Construction Section (Section Ill.S.2) of this report, numerous examples of hareware accepted by VCD walkeewn were fcund not to comf)rm-to design by the NRC CAT
-inspectors, the ASME Authorized Nuclear inspector (ANI), and QC curing subsequent inspections.
Fewever, the VCD crawing oces define a stopping peint in the iterative design process, a control not present in the otner disciplines reviewed. Licensee representatives again stated their intent to satisfy the necessary NRC requirements, and also expressed confidence in their VCD program, f f } Picino and Mechanical Engineering To review the d5 sign change control process in this area,. ! accroximately fifty DCAs/CMCs were reviewed. Several trave-ler and installation packages were compared to the program requirements for piping installations. As. referenced in this report, few deficiencies in the review cf safety system piping and ASME Code radiography for this piping were found by the NRC CAT inspectors within the hardware areas. Few design changes were found relevant to this area. ' Several traveler and installation packages were reviewed to the program requirements for mecnanical installation. IX-8
pvh , L . Similar observations relevant to the processing of design changes and documentation of nonconferr'ances were made. These were discussec in previous paragraphs of this section of the report as to electrical ecuipment, electrical sup-ports, and pipe. hanger /su; port installations. Discrepancies relevant to inspection peccedures are discussed .in the Mechanical Construction Section (Section III) of this report,
- c. Su=ary Comments Concernino the Desien Chance Process
' The design change process at CPSES is complex, and at times, cumbersome. The NRC CAT inspector's review of design change pro-cesses in the various disciplines revealed'a design change program with controls incorporated under a " design-construct-
' design review" philosophy. This philosophy resulted in a large number of design changes and a repetitive inspection process. (NCTE: There are accroximately 70,000 CMCs and 15,000 DCAs that nave been issued. 'This number does not' include revisions). 1 i Although this design change process may be difficult, there is { nothing in NRC requirements to discourage or prohibit the use of such a system. In general, design change controls at CPSES satisfied the applicant's FSAR commit'ments and the ANSI standard requi rements . However, with this type of system in-place, actual verification of hanger, support, electrical, and mechanical ecuipment installations to the aporoariate cesign requirements cannot be performed until " work. activities" have been completed. Few,'if any, installations could be verified as. few have been designated as completed under the licensee's context of "ccmpletion." .Thus,'the final acequacy of these controls could not be cetermined by the NRC CAT inspector. j E. Ccreective Action Svstems ne' CPSES FSAR recuires a nonconfermance report be " utilized'for tre identification, documentation, cisocsitioning, and verification of ce#iciencies in characteristics, documentation, or procedures whicn
'ercer tne Gality of an item unacceptable or indeterminate". The l
- SA: also recaires procedures for trencing of nonconformance reports tc 'dentify trends acverse to quality and for :re initiation cf ,
l ccr'ective action requests for significant and repetitive nonconfor-ances. CP-EP-16.1, " Processing Nonconformance Reports" and the applicable references were implemented at the site to meet these requirements to satisfy the licensee's FSAR commitments. A review Of accroximately one-hundred selected nonconfor ance reports (NCRs) indicatec that icertified nonconformaning conditions (cocumentec On NCRs) were cispositioned anc processec in accordance witn procecural requirements.
'X-9
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a; , 1 i As discusse'd in Sections ~ II, III, and. IX of this report, overall findings indicate. numerous. instances in the electrical and
< mechanical areas where nonconformances. were identified. Howeve r,'
various methods (e.g. .' i { other informal methods)punchlists, inspection reports, verbal, and were useo to address and resolve these nonconformances, providing no collective evidence of appenpriate . corrective action and/or justification.. ' Additionally, the !;RC CAT inspectors discovered that the Mechanical / Civil QA/QC Su;ervisor directed his supervisors to document nonconforming. conditions on an unsatisfactory Inspection Report:(IR)'only, contrary to the licensee's- FSAR commitments' and QA program requirements. ; 4 e t e IX-10 ;
u',q.. c ATTACr MENT A A. Perscrs Contacted The following list icer,tifies by title, the -individuals contactd curing tnis inspection. Cercorate Office:
- Vice President, Nuclear Operations Manager cf Cuality Assurance Cuality Assurance Audits Supervisor Regulatory Interface, Program Review, and Training Supervisor Comanc*e Peak' Site:
h ' lice, President, TUSI Cers t ructi'on : Manager, TUSI' . Resident Construction Manager,-TUSI Projec: Construction -Manager B&R Projec: Engineer, TUSI-Profect Discipline Engineers (a), TUS! Engineering Unit Supervisors (8),.TUSI Startu; Manager, TUGC0
.:Lality Assurance Supervisor, TUGC0 C a'.i:y Assurance /Cuality Centrol Inspection Supervisors (3), TUSCO Cuality Assurance Manager, 5&R C ality Centroi Inspector Supervisors (3), 5&R Uekir; Engineering Unit Superviser, ESR
?r: cure. ment anc Control Manager,.TUSI
-::vct Centrel and ',,arenouse Manager, EiR 4:ncri:ed .'uclear Inspector (2)
':~E: In tr'e course of the ins:ecticr, rueerous craftsren, ins:ecters engineers anc supervisory perscnnel were also.intervie,,ed ano are ret specifically listec.
- 3. ::: rects :eviewed
' Tne :::Jents listec below were reviewec by the inspection team reecers to e ecer: necessary :o satisfy tre inscection of objectives statec in
. ie::': ! cf this report. The specific ;-Ocedures in the report are listed
- y titie anc revisien number, if applicable, wnen they first aLpear.
- 1. Firal Safety Analysis Repcrt (FSAR)
- 2. Cuality Assurance Program Policy
- 2. Cuality. Assurance Procecures
- a. Quality Control Procecures
- 5. Ge eral Construction Specifications
- 5. Cuality Assurance Procedures 7 Engineering Procecures
- 5. :recurement, 5tcrage, anc Material Traceability ? ececures
- 9. Aucit Reports
'. 0 . Trend Analysis Re; orts 1
l [
',' "'o UNITED STATES F o NUCLEAR REGULATORY COMMISSION ~/ ~_
y s j cAsum: ton, D. C,20555 {/g]s C w i g*.eaj
*" JAN ,21 1986 - '
Docket Nos.: 50-445 50-446 Mr. W. G. Counsil
. Executive Vice President Texas Utilities Generating Company 400 North Olive Street, L.B. 81 Dallas, TX 75201
Dear Mr. Counsil:
SUBJECT:
INSPECTIONS'0F COMANCHE PEAK DESIGN ADEQUACY PROGRAM SCOPE VALIDATION PROCESS AND REVIEW CHECKLIST DEVELOPMENT 445/85-17, 50-446/85-14 This letter conveys the results and conclusions of the inspection of the Comanche
. Peak Design Adequacy Program (DAP) scope validation process and review checklist i development. The inspection was conducted by the NRC's Office of Inspection and Enforcement (IE). The inspection team was composed of NRC personnel from IE and the Office of Nuclear Reactor Regulation (NRR), as well as consultants. The inspection took place at TERA Corporation, Bethesda, Maryland during the period from October 28 to November 1, 1985.
j. The inspection focused on the Comanche Peak Response Team (CPRT) Program Plan, Revision 2, dated June 28, 1985, specifically Appendix A (Design Adequacy Program) and Discipline Specific Action Plans (DSAPs) VIII through XI. DSAPs VIII through XI cover the civil / structural, piping / supports, mechanical systems / components,.and ' electrical /I&C disciplines, respsictively. A substantial portion of the inspection involved evaluation of TERA responses to scope-related NRC comments pertinent to ' Appendix A and DSAPs VIII through XI, which were provided in letters dated August 9 and September 30, 1985. TERA's verbal responses during the inspection have been compared with formal responses to the same comments in TUGC0 letter CPRT-113 dated November 22, 1985, and any discrepancies have been highlighted in Appendix 11 to l the enclosed inspection report. The team did not address programmatic comments in the NRC letters. ; Section 1 of the report provides a summary of the results of the inspection and the conclusions reached by the inspection team. In general, the team found.that the NRC scope-related comments are addressed in the existing DAP review chuk11sts or will be included in checklists to be developed as a result of the Phase 3 scope ! validation process. This finding was on specific scope-related comments. The team did not evaluate the DAP scope in general, which NRR is addressing relative to its review of homogeneous design activities (HDAs). The report identifies the need to expand or clarify some existing checklists. In a future inspection, th. l team will followup with respect to these checklists and will review the Phase 3 ; checklists. j OMMNL N _- - .-
~
W. G. Counsil 3 JAN 211986 5 Should you. have any. Questions concerning this inspection, please contact me or Mr. Donald Norkin (301-492-4533) of this office.
~
Sincerely, vi r, Director
'fi c f Inspection and Enforcement
Enclosures:
As stated .. l d e e
'1 l
l l
i JAN 211986 W.lG. Counsil , Comanche Peak Steam Electric Station
. Texas Utilities: Generating Company Units 1 and 2
'cc:
Nicholas S. Reynolds, Esq. Resident Inspector / Comanche Peak Bishop, Liberman, Cook. - Purcell:& Reynolds Nucle'ar Power Station c/o U.S... Nuclear Regulatory Commission 1200 Seventeenth Street, N. W. P.O. Box 38
. Washington, D. C. 20036 Glen Rose, Texas 76043 Robert A. Wooldridge, Esq. Regional Administrator, Region IV Worsham, Forsythe, Sampels & U. S. Nuclear Regulatory Commission '
.Wooldridge 611 Ryan Plaza Drive Suite 1000 2001 Bryan Tower, Suite 2500 Arlington, Texas 76011 Dallas, Texas Mr. Robert.E. Ballard, Jr. Larry A. Sinkin Director of Pro Christic Institue GibbsandHill, ject Inc.3 1324 North Capitol Street 11 Pen Plaza' Washington, D..C. 20002 New York, New York 1,0001 Mr. R. S. Hokard - Ns. Billie Pirner Garde j Westinghouse Electric' Corporation Citizens Clinic Director P.O. Box 355. Government Accountability Project Pittsburgh, Pennsylvania 15230 1901 Que Street, N. W.
Washington, D. C. 20009 Renea Hicks, Esq. David R. Pigott, Esq. Assistant Attorney-General Orrick, Herrington, & Sutcliffe Environmental Protection Division 600 Montgomery Street P.O. Box 12548, Capitol Station San Francisco, California 94111
. Austin, Texas 78711 Mrs. Juanita Ellis, President Anthony Z. Roisman, Esq.
Citizens Association for Sound Energy Trial Lawyers for Public Justice 1426 South Polk i 2000 P Street, N. W. ' Dallas, Texas 75224 Suite 611 Washington, D. C. 20036 Ms. Nancy H. Williams Nancy E. Wiegers CYGNA, Spiegel & McDiarmed 101 California Street 1350 New York Avenue, N. W. San Francisco, California 94111 Washington, D. C. 20005-4798 Robert F. Lessy, Jr. Morgan, Lewis & Bokius 1800 M Street, N. W. Suite 700, North Tower Washington, D. C. 20036 ___-_-_______-____-_-________________a
1
- r. .
, r,
. . U.S. NUCLEAR REGULATORY CCNMISSION - OFFICE OF INSPECTION AND Ef7FORCEMENT , Division of Quality Assurance, Vendor, and , j Technical Training Center Programs Quality Assurance Branch > Report Nos.: 50-445/85-17, 50-446/85-14 , Docket Nos.: 50-445, 50-446 t l Licensee: Texas Utilities Generating Company Skyway Tower ' 400 Narth Olive St., L.B.81 Dallas, Texas 75201 ,
/
Facility Name: ComanchePeakSteamElectriestation(CPSES) , Inspection At: <- TERA Corycration, Bethe3da, Maryland J
. Inspection Conducted: October TG r November 1,1985 J '
Inspection Team Members: e - Team Leader D. P. No.-kin, Senior Inspection Speciilist, IE Civil / Structural R. E. Shewmaker, Senior Civil Engineer. IE K. P. Buchert, Consultant, WESTEC Services ' J. Blackman, Consultant, WESTEC Services Piping / Supports D. Terno, Mechanical Engineer, hRR 3
,W. P. Chen, Consultant, ETEC 'Rockwell i
International ' Mechanical Systems / 'l S. M. Klein, Consultant, WESTEC Services Components ' J. Fevshemal, Contultant, WESTEC Services Electrical /I&C G. C Mor.ris, Consultant, 'JESTEC Sery,1ces L.Stanien. Consul, tant,Ifter,Inc. S. V. Athavale, Inspection Specialist, IE J. L. Knox, Senior Electrica'FEngineer, NRR ,
/
M */ , { Uonald P. Norkin Et'e 4 Team Leader, IE
]
a r Approved by uN , l. ~ z % .y.-
~
F"le l[f/96 ( / 2me: L. Milhoarr - a ! l ( ection Chief, Assurance Quality Branch l 1 f
7 4 . 2... - ' a q. t
, 1 j
,t;pQ'tf.
&,a i J[y [ Table of Contents, J (Q ,, Inspection of Comanche Peak Design I
' 'q i ri y Adecua'cy Prg[ ram Scope Validation Process and Checklist Development 1
a c
+
)
1 1 h re h P,, age, 3 h Table of Contents , i P k
. List of Acronyms 11 ,
!:. ' @$roduction" and Sumery < 1-1 !
) 3
; : 2.
Personnel contacted - Attendees at Entrance and/or Exit Meeting s 2-1 hendicesy i j llih 1 1: ? Phsd 3 Scope Validation Process A-1 )Y , : Resolutidn of Comments in 8/9/85 NRC Letter, A-4 ; Civil / Structural i A-6 - gl 3:\ Resolution Mechanical Systems of Coments in 8/9/85 NRC Letter, and Components i i !3 .. o /- A 4: Resolution of Comants in 8/9/85 NRC Letter,
- A-13 1 Ed .
JJ ' t Table 2 I&C Matrix ) '
, ,: +
t u i' 5: Resolution of Coments in 8/9/85 NRC Letter, A-19 i Table 3,. Electric Powdr Matrix , i 6: Resolution of Coments in 9/30/G5 NRC Letter,
- A-22'. l Design Adeqacy Program Plan'(Appendix A) < !
t 7:' Resolutien of Comments in 9/30/85 NRC Letter, A-26 . I DSAP VIII Civil / Structural 8: . Resolution 6f Comments in 9/30/85 NRC Letter, A-28 t DSAP IX Piping and Supports l
, 9: Resolution of Coments in 9/30/85 NRC Letter, A-31 DSAP X Mechanical Systems and Components l 10: Resolution of Coments in 9/30/85 NRC Letter, A-34 }
DSAP XI Electrical /I&C Systems and Components i 11: Discrepancies between Appendices 2-10 and A-45 . CPRT-113 dated November 22, 1985 l 12: Coments on Review Checklists A-47 Table 1 Listing of Review Checklists T-1 l 1
- t
- 1. INTRODUCTION AND
SUMMARY
1.1 BACKGROUND
Texas Utilities Generating Company (TUGCO) letter dated June 28, 1985 to the NRC transmitted the Comanche Peak Response Team (CPRT) Program Plan, Revi-sien 2 dated June 28, 1985. Appendix A to the Program Plan describes the Design Adequacy Program (DAP). The DAP is comprised of four Discipline Specific Action Plans (DSAPs) covering the following design disciplines: Civil / Structural; Piping / Supports; Mechanical Systems and Components; and : Electrical / Instrumentation and Control Systems and Components. These DSAPs (VIII through XI) are to be executed by TERA Corporation, and provide for third-party reviews of CPSES architect-engineer act.ivities performed by Gibbs and Hill, Stone and Webster, and Ebasco. NRC letters dated August 9, and September
- 30, 1985 from V. S. Noonan to W. G. Counsil commented on the CPRT Program Plan.
l 1.2 OBJECTIVES I The Office of Inspqction and Enforcement (IE) is responsible for inspecting the third-party reviews conducted by TERA in accordance with DSAPs VIII through XI. (The scope of the DAP will be reviewed and approved by the Office of Nuclear Reactor Regulation, with input from IE). IE inspections will be pha' sed to cover the various phases of TERA work; e.g., checklist development, DSAP implementation, final report preparation, and corrective action imple-mentation. IE inspection reports will be issued at each phase. In addition. IE will prepare Safety Evaluation Report input evaluating the DAP execution. This current inspection covered the Phase 1-3 TERA scope validation process, review checklists, and evaluation of the qualifications of TERA reviewers. i 1.3 SCOPE VALIDATION PROCESS The DAP addresses both external source issues, such as those identified by the Cygna Independent Assessment Program, and self-initiated issues, which are identified in an expanded " vertical slice" review of areas where there - have previously been no external source issues. Identification of external source issues is accomplished by a systematic review of documents containing these issues for concerns questioning either the CPSES design or design process. TERA procedure DAP-2, " Documentation and Tracking of Issues and Discrepancies," covers a computer tracking system for ensuring that current and future external source issues potentially af-fecting design are resolved. One method of resolution is to investigate further through one of the DSAPs. Accordingly, the DSAP scopes cover external source issues. IE plans to review the computer tracking system during its implementation inspection to evaluate the completeness of identified issues and the manner for ensuring that issues are resolved. Except for DSAP IX, " Piping and Supports," the major portion of DSAP scope is "self-initiated," i.e., unrelated to existing issues. This scope is determined in a four phase process. Revision 2 of CPRT Program Plan reflects completion of Phase 1 and 2. Phase I was based on a systematic review of past Integrated Design Inspections and Independent Design Verification Programs to identify typical scopes for such reviews. Based on this, TERA selected a
" vertical slice" of the balance of plant design effort within the entire class 1E onsite electric power system and the auxiliary feedwater (AFW) system, 1-1
The Office of Nuclear Reactor Regulation will address the "given" concept in conjunction with final DAP scope approval. l DAP-E-FM-001* stated that there are four remaining activities to be completed to confirm / finalize the DAP self-initiated evaluation scope. These are as
)
i follows: (1) Review the background of the preliminary unique vendors to confirm if their services were unique to CPSES. (2) Complete the review of lists of recent TUGC0 Nuclear Engineering (TNE) design to finalize the THE scope of design. (3) Confirm, through review of G&H des'ign control procedures, that changes did not occur over time in the design process that ! would create new HDAs. l (4) Perform sufficient review to confirm or deny the " candidate given.",,,
'IE will inspect these confirmatory actions in future inspections to evaluate their relevance to the defined Phase 3 scope.
The IE inspection of Phase 3 focused on the validity of identified HDAs, omission of design activities which apparently should be covered by HDAS and correspondence of Phase 1/2 checklists to the HDAs. The inspection team generally agreed with TERA conclusions that certain checklists adequately covered HDAs. Exceptions to this are addressed in Appendix 12. " Comments on Review Checklists." Team conclusions were predicated on confirming the homo-geneity of HDAs. Failure to confirm this will result in additional HDAs and new or revised checklists. Appendix 1, to this report, addresses a fundamental problem with the HDA criter'ia for homogeneity. TERA was unable to provide to the team Gibbs and Hill docu-mentation covering guidance to designers / analysts on design considerations, . approach and methodology, which would be needed to substantiate the sample selection based on the HDA rationale alene. Specifically, the inspection team used the civil / structural discipline as an example. The team was unable to . conclude that the problem identified for civil / structural is restricted to that discipline. It is understood that, since the inspection, TERA has identified design methodology guidance pertinent to some HDAs. Design criteria pertinent to the DAP were documented for Phase 2 scope in ac-cordance with procedure DAP-1, " Preparation and Review of Criteria Lists." This will be accomplished for Phase 3 scope as well. The team did not review the extent to which these have been identified with specific HDAs. Section 1.4 indicates that design criteria are listed in review checklists. In future inspections, IE plans to determine whether calculations and other design products reviewed by TERA are representative of the design process and the degree to which the HDAs are representative of the design process. To the degree that TEPA relies on the HDA rationale to justify that the sample selected is representative TERA needs to confirm the validity of the HDA process with respect to its review sample, and provide a documented trail of its confirmation. i I 1-3
The team found that Attachment C checklists provide no more than a listing of commitments. The " Description of Verification" column is of ten not ; completed, and, when completed, does not iniicate the various steps in
, confirming the design criteria are met. The team expected the checklist to be prescriptive with respect to all the design considerations that need to l be addressed in ensuring the design criterion is met. While a successful review can be conducted with less prescriptive checklists, the lack of this detail puts a burden on experienced reviewers to closely follow the activities of less experienced reviewers.
1.5 PERSONNEL 0, QUALIFICATIONS The team evaluated TERA personnel with respect to their qualifications to perform the tasks identified by the Phase 1-3 scope and the review check-lists. The team performed this review primarily based on reviewing resumes and to a lesser extent based on our discussions with TERA personnel during the inspection. Since less than 20% of TERA personnel were available for , these discussions, our review of personnel will be continued through the I next phase of the IE review activities, i.e., evaluating DSAP implementation. Nevertheless, thisilimited review did indicate potential problems with respect to having personnel with architect-engineer design experience in the areas covered by. Phases 1-3 scope. For civil / structural, there is a discipline leader and three subgroup leaders. Of the four, only the subgroup leader for the self-initiated review had architect-engineer nuclear experience. However, this experience is analysis rather than design oriented. Of the remaining personnel (17) who will apparently review self-initiated scope items, only four have had architect-engineer experience. In general, the 17 personnel have experience more related to analysis than design (as relevant to the DAP design review effort). For mechanical systems and components, only two reviewers appear to have design experience as necessary to implement the scope indicated in existing review checklists. Two additional reviewers have design experience which appears to match Phase 3 topics. Other reviewers have experience which , appears to be irrelevant to the design review scope, e.g. licensing, construction, maintenance, and welding. The team understands that the scope expansion realized by Phase 3 will be significant and will result in obtaining additional review personnel. In some cases, the review personnel on hand were never intended for some of the areas of Phase 3 scope expansions. TEPA indicated to the NRC inspection team that, for design areas unique to a nuclear power plant, reviewers will be assigned to review work which they have personally perfonned in a previous capacity in the design of a commercial nuclear power plant. If this comitment is met and the experienced reviewers include an adequate number with experience in the full A-E design process, then the team's concerns with review checklists and TERA review team qualifications should be adequately addressed. It is noted that, subsequent to the inspection, TERA took action to add approximately 25 personnel from an A-E organization (Gilbert / Commonwealth) to the DAP review team. , IE will follow up during the implementation inspection to ensure that the balance ' between reviewer experience and the prescriptiveness of review checklists 15 l appropriate. ; 1 1 1-5
l l
- 2. PERSONNEL CONTACTED- l l
Attendees at Entrance and/or Exit Meeting
- l Name Affiliation T4 Ankrum NRC/IE '
A. Vietti-Cook NRC/NRR/DL C. Trammell - NRC/NRR/DL J. A. Calvo NRC/NRR/DSI !
- 5. Hou NRC/NRR/DE i B. Grimes NRC/IE/DQAVT I D. Davis TERA L. Shao -
NRC E. Marinos NRC/NRR V. S. Noonan NRC/ Director Comanche Peak Project J. L. Milhoan *', NRC/IE/QAB R. G. Bachmann NRC/0 ELD D. F. Landers Teledyne Eng. Services E. A. Solla. Teledyne Eng. Services J..Redding TUGC0 S. Karpyak TUGC0 H. Levin Design Adequacy RTL F. A. Dougherty DAP Manager E. B. Blackwood DAP/ Discipline Coordinator C. Mortgat DAP Civil / Structural Coordinator T. F. Snyder DAP Piping / Supports Discipline Coordinator R. F. Schofer DAP Mechanical Discipline Coordinator B. M. Rice DAP Electrical, Instrumentation &. Control Design Coordinator D. C. Timmins DAP Project Management Coordinator R. T. Boyd DAP/ Mechanical Engineer . L. D. Bates DAP/I&C R. E. Levline DAP - Mechanical Support j W. H. Hendrix DAP/I&C M. J. Shah DAP/I&C L. C. Fernandez DAP - Mechanical Support S. Wrona DAP - Pipe Supports P. Streeter DAP - Piping Analysis R. Srinivasan DAP - Civil / Structural D. Goodyear DAP - Civil / structural G. E. Setka DAP - Electrical Q. R. Miller DAP - Electrical J. D. Voss DAP - Electrical K. C. Majumdar Delian Corporation / Electrical
- This list does not include IE team members. DAP personnel listed were contacted by the team during the inspection.
2-1
l APPEND 2X 1 PHASE 3 SCOPE VALIDATION PROCESS The team reviewed.the Phase 3 scope validation with respect to the validity of identified Homogeneous Design Activities (HDAs) and design activities not hpparently enveloped by the HDAs.
- 1. Civil / Structural HDAs are requir%d to have common design or analysis approach / methodology or me-cha. des in design implementation such that meaningfully different complexities or considerations are not contained within that design activity. However, TERA had not obtained formal documentation pertinent to the Gibbs and Hill design /
analysis methodology and approach. Such documentation (instructions and pro-cedures) is noma 11y utilized to establish design process control and thereby i establish uniformity of technical approach in the execution of engineering for a project.
.c The Civil / Structural Phase 3 Scope Validation document, including the HDAs identified within, is based on such items as the plant engineering documents available at' Gibbs and Hill, TERA interviews with project personnel, and the engineering experience of TERA personnel in nuclear power plant design.
i DAP-E-FM-001 dated October 27, 1985 states that, on a programmatic level, (1) organizational and design control process changes within Gibbs and Hill have not affected the identified HDAs and (2) there have been no changes to design methodology over time at Gibbs and Hill such as to affect the identified HDAs. These TERA conclusions are based on discussions with Gibbs and Hill rather than review of design control procedures, design methodology, etc. TERA apparently recogrtizes that other homogeneous design activities (HDAs) may exist and that some currently so defined may in fact not be homogeneous since it has been stated in DAP-E-C/S 001 dated October 27, 1985, " Phase 3 Scope Vali-dation, Civil / Structural" that in the review effort there will remain an open',
"... search for substantive differences in criteria category, design considerations, approach ,or methodology in the design process."
The team identified potential HDAs not identified by TERA, such as the design ~ of the annular structural steel normally inside the containment, the auxiliary l l building structural steel, foundation overturning design, the design of walls for tornado missiles and the effect of Category II buildings on Category I buildings. , Due to the above uncertainty as to documented design methodology, there is a related question on sample sizes. In the area of concrete design, TERA has indicated that for the auxiliary building and the fuel building a total of five. (5) slab and five (S) wall calculations will be selected at random for design review. Then another set of ten (10) calculations will be selected either ran-domly or based on any findings from the previous ten (10). Such a sample may not be valid if all these calculations were by one individual, if there were fifteen (15) individuals doing independent designs for slabs and walls without i any design process / methodology guidance beyond the FSAR criteria. If there l were no controls within the Gibbs and Hill organization, for establishing homogeneity in design approach and methodology, one must compare individual t A-1
l (3) HDA 3.a. for local and remote indication circuit design will be revised to address both normal operation and accident monitoring indication. (4) The review of' vendor' technical data submittals by TERA will be revised to be more specific in the checklist as to which vendor dicuments will be reviewed. . .
'(5) A review of interaction among protection and control systems will be )
added to the checklists, and should be identified as a unique HDA. (6) The r view of Regulatory Guide 1.97 accident monitoring variables will be expanded to include Type D. qualification category 2 variables , in revised checklists, and should be identified as a unique HDA. ; (7) A review of instrument response time requirements and characteristics will be added to the revised checklists, and should be identified as a unique HDA. (8) A review'of high pressure to low pressure system interlocks will be
-- ' - ~ - - - 'added to the revised checklists, and should be identified as a unique HDA. -
9 e
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4 0 t A-3
APPENDIX 2f b . RESOLUTION OF COMMENTS IN 8/9/85 NRC LETTER, N . CIVIL / STRUCTURAL. The following NRC comments correspond with scope related coments in the Civil /- Structural Section (3.1.B) of NRC letter dated 8/9/85. The NRC questioned
'whether the DAP scope would include specific design activities. The team evaluation found the TERA response acceptable if it indicated that the specific -
design activity was, enveloped by either Phase.2 or 3 scope. 1 1.. NRC COMMENT: First, the' basis for selection of the major c'oncrete and steel structures to be reviewed is not provided. TERA RESPONSE: No specific basis was used. The containment, the auxiliary ; building, and the fuel building were selected randomly out of the five major Category I. buildings. The TERA effort will also review portions of other major Category I buildings as indicated on checklists. TEAM EVALUATION: The Team believes this complement of Category I buildings provides a representative sample for review of concrete and steel structure design, based on currently available-information. -
- 2. NRC COMMENT: Another concern is that the review scope for Category I structures .as proposed in the Plan, is not an adequate representation of .
CPSES Category I structures. A number of external source issues exist on supports which range from loading to structural attachment. Based on this, it may be appropriate to select a concrete structure that is heavily loaded by supports in concentrated areas. The shield wall or a steam generator compartment structure might be an appropriate selection since they both have a significant number of attachments. The containment liner ~is the largest ; steel structu}}