ML20246C936
| ML20246C936 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Nine Mile Point |
| Issue date: | 05/20/1987 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20246C819 | List: |
| References | |
| FOIA-89-226 NUDOCS 8908250184 | |
| Download: ML20246C936 (3) | |
Text
. _ - _
May 20, 1987 Docket No. 50-410 MEMORANDUM FOR:
Thomas E. Murley, Director, Office of Nuclear Reactor Regulation FROM:
William T. Russell, Regional Administrator
SUBJECT:
Nine Mile Point Unit 2 Initial Criticality Recommendation This memorandum updates the Region I October 29, 1986 Murley to Denton recommendation regarding initial licensing of Nine Mile Point Unit 2 (NMP2) and provides the Region I assessment and recommendation for Unit 2 to proceed with initial criticality.
~Since the issuance of the NMP Unit 2 Operating License on October 31, 1986, Niagara Mohawk Power Corporation (NMPC) has completed initial fuel loading and open vessel testing.
Further testing was postponed until final resolution of Main Steam Isolation Valve (MSIV) leakage problems. After MSIV prototype testing failed to produce acceptable results, NMPC decided, on March 11, 1987, to replace'the ball-type MSIVs with standard air-operated wye pattern globe valves.
l
.The MSIV replacement and support systems installation was completed on May 4, 1987.
Inspections of various MSIV replacement activities were conducted by region-based and resident inspectors. These inspections included: field observations of electrical and mechanical installations;' observation of welding and fabrication activities; nondestructive examination reviews; quality control and' quality assurance activity reviews; documentation reviews; personnel quali-fication verifications; and observation and results review of preoperational testing. No significant deficiencies were noted. The inspections concluded I
that the MSIV replacement activities were well coordinated and executed. The 1
MSIV preoperational testing and the satisfactory Type C leak rate test results were further evidence of NMPC's effective control of the MSIV replacement.
The Region I staff has completed their review of the three systems granted I
schedular exemptions for operability prior to initial criticality (i.e. DBA Recombiner System, Containment Atmosphere Monitoring System, and Reactor j
Coolant and ECCS Leak Detection System). The licensee has declared these
)
' systems operable.
No deficiencies were noted in our review and observation of i
preoperational testing.
In addition, the staff has reviewed the Unit 2 Out-standing Items List and identified no items requiring closeout prior to initial criticality. All 10CFR50.55(e). Construction Deficiency Reports have been closed out by NMPC and were subsequently reviewed and determined acceptable by L
the Region I staff.
0FFICIAL RECORD COPY JOHNSON-NMP2/ICR - 0001.0.0 11/29/80 m*E8) sha
?
F
~
Thomas E. Murley 2
There has been some recent activity involving an allegation (No. RI-85-A-65) which was received in 1985 regarding improper installation of neutron monitoring cables.
Region I Inspection Report No. 50-410/85-42 substantiated that the cables were not installed in accordance with licensee procedures and resulted in a notice of violation. However, the Region I staff concluded that the cables were technically acceptable based on a licensee demonstration of the installation technique used. Additional questions regarding the licensee's review of this matter are the subject of a separate allegation (No. RI-85-A-0100) and an Office of Investigation Report (I-85-020) which was sent to you by V. Stello on May 14, 1987 and which was also forwarded to the Department of Justice on May 8, 1987 for their review. No additional technical issues were disclosed from our review of the OI Investigation Report.
Inspections specified in IE Manual Chapter 2514 for initial criticality have been satisfactorily completed. A specialist inspection completed on May 15, 1987 reviewed the available Power Ascension Program test procedures and found them acceptable.
The Unit 2 control room environment continues to be closely monitored by the resident and region-based inspectors.
Traffic through the control room during the MSIV replacement period was heavy and appeared to have been minimally con-trolled. Since issuance of the license, the noise level in the control room has been reduced.
The Region I staff plans to provide twenty-four hour coverage for initial criticality and the first few days of testing. During the first two weeks of June 1987, a team inspection led by the responsible Section Chief will be con-ducted to evaluate NMPC operational performance.
In conclusion, I believe that Unit 2 may proceed with initial criticality and heatup testing.
Original Signed By liTILLIAM T. EUSSI.IJ, William T. Russell Regional Administrator CC" V. Stello, E00 J. Taylor, DEDRO J. Sniezek, NRR H. Thompson, NMSS l
R. Starostecki, NRR i
F. Miraglia, NRR S. Varga, NRR B. Boger, NRR R. Capra, NRR J. Neighbors, NRR l
1 i
0FFICIAL RECORD C0pY JOHNSON-NMP2/ICR - 0001.1.0 1
11/29/80 l
r k-.,.
Thomas E. Murley 3
bec:
W. Kane, DRP'
-S. Collins, DRP W. Johnston, DRS R. Gallo, DRP L. Bettenhausen, DRS J. Johnson, DRP P. Eselgroth, DRS G. Meyer, DRP W. Cook, SRI /NMP1&2 bN' y
/
)
RI:DRP R. RP RI: R fl h2RA R)I:RA
~
Johnson /rh1 Gallo
.Johnston K.
ANan Russell 5 / 11 / 8 7 5/
87 5/If /87 5/4 /87 5/[h/87 5/q87 0FFICIAL RECORD COPY JOHNSON-NMP2/ICR - 0002.0.0 05/19/87
O 6
-e Initial Acceptance Rate, Volumetric Examination 83%
Initial Acceptance Rate, Surface Examination -
97.5%
ITT has generated the following inspection reports:
YEAR LIQUID PENETRANT / MAG. PARTICLE RADIOGRAPHY 1982 1729(1) 774 1983 2867 633 1984 7590 1163 1985 11819 1832 TOTAL 24005 4402 Initial Acceptance Rate, Volumetric Examination 72%
Initial Acceptance Rate, Surface Examination 95%
i NOTE 1: LP/MT exam totals for 1962 for first nine months only.
NOTE 2: SWEC QA/NDT, Boston conducted a complete review of 4,189 ITT Grinnell radiograph packages prior to 11/25/84. A total of 775 weld radiograph packages required some form of corrective action, which has been accomplished.
i O
. - -. _ _ _ - - - - - - - - - - - _ _ - - - - - - - - - - - - - - - - -. - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
n.
@ ' ty') ;
paar J V i.v.
c
/
'o UNITE 3 5TATES g
NUCLEAR REGULATORY COMMISSION g
1.
y REGION I 8,,
c
$31 PARK AVENUE
/
KINO OF PRutstA, PENNSYLVANIA 19406 b
Docket No. 50-410 MEMORANDUM FOR:
Harold R. Denton, Director, Office of Nuclear Reactor Regulation
'i FROM:
Thomas E. Murley, Regional Administrator
SUBJECT:
NINE MILE POINT UNIT 2, LOW POWER LICENSE RECOMMENDATION This memorandum provides the Region I assessment and recommendation for issuance of a Low Power Operating License for NMP-2.
This plant had a history of problems during construction.
Because of m e concerns we had in 1983, I asked the Director, IE, to schedule a Construction Assessment Team (CAT) inspection in November 1983. The team found a number of deficiencies in the plant-and in the QA programs. The deficiencies led to-an enforcement action comprised of a 5100,000 civil penalty and an order requiring an independent audit of both Unit 1 operations and Unit 2 construction, a quality improvement program, and an independent review of the licensee's corrective action program including the adequacy of its implementation.
Niagara Mohawk Power Corporation (NMPC) senior management responded promptly and positively.
In early 1984 they brought in an independent organization to assess their operations. This assessment led to significant organizational changes to strengthen NMPC management of construction and the addition of experienced cons-truction management people from outside the company. As a result, they slowly but steadily corrected their construction man:,gement and QA problems.
In addition, during this period the President of NMPC has given close personal attention to the progress of these improvemi9 ::.stvities.
In July 1986, as a result of resident inspector activities observing electrical connector replacements on Unit 1, we received some allegations that raised ques-tions concerning the quality of operations at Unit 1, and by extension, poten-tially at Unit 2.
We sent a team to the site to conduct a diagnostic inspection
- of the issues es well as the overall operation of Ur,it 1.
We requested that the licensee conduct their own investigation of the specific issues identified in the allegations and of any broader issues they might indicate.
The diagnostic team inspection concluded that there were no immediate technical safety issues resulting from the allegations, however, the team did conclude that there were programmatic wgaknesses in the hMPC management system, in that:
1.
Methods within the organization to identify shortcomings and potential problems have not been effectively implemented. As a result, problems are frequently not brought to the attention of management for resolution.
h
(p,
1 4o gy Harold R. Denton, Director 2
N bb I
{
1 2.
Once identified, problems are not always dealt with in sufficient I
depth to find root causes; 3.
The NMPC Operational QA program is not as effective as it should be I
in helping the line organization to find and correct problems.
In the course of the diagnostic inspection, we found additional material that raised questions about the effectiveness of their' overall QA program at Unit 2.
l In order to resolve these issues we sent a QA audit team to conduct an onsite
-follow-up inspection. The team determined that there were no safety issues and no unresolved hardware issues. However, similar to the above diagnostic inspec-tion,- the QA audit team concluded that some programmatic issues existed, pri-I marily due to organizational' problems, and these issues need to, be corrected.
As a result of our followup to these issues Region I believes that the senior management of NMPC recognizes these weaknesses and has committed to take the necessary actions to correct them, although it will take some time to fully implement all of the corrective actions. Therefore, we will monitor their progress carefully until we ara satisfied that the weaknesses are corrected.
To put this in perspective, however, we believe that the overall management of Unit 1 is effective and that the weaknesses discussed above do not represent a fundamental problem that would seriously question the ability of NMPC to operate Unit 2 safely.
Accordingly, I and the Region I stiff recommend the issuance of a Low Power Operating License for Nine Mile Poir.t, Unit 2.
This recommendation is based upon the Region I evaluation documented in the attached Initial Operating License Review Report and upon the following specifics:
1.
We have concluded that Niagara Mowhawk Power Corporation is essentially ready to load fuel at Nine Mile Point Unit 2 and is capable of operating the plant safely at low power.
2.
The construction and preoperational testing inspection programs have shown that the Nine Mile Point Unit 2 plant has been constructed substantially in conformance with the construction permit and the application, as amended, the provisions of the Act, and the rules and regulations of the Commission, as required by 10 CFR 50.57(a)(1) and(2).
3.
Each Region I professional staff member was requested by memoranda dated December 8,1985 and September 9,1986 to identify any unad-dressed safety concerns which he or she might have concerning Nine Mile Point linit 2.
One concern was raised that action to resolve problems with the design and operability of the Main Steam Isolation Valves (MSIVs) be completed prior to issuance of the license. These issues were already under regional and NRR licensing staff review.
All regional personnel are now satisfied with the program described in the following paragraph to resolve the MSIV issues.
L w
29 AUS be Harold R. Denton, Director 3
A remaining issue concerns the closure time and leakage requiremer.ts of the MSIVs. As the valves are a unique ball valve design, we are particularly concerned about the resolution of these problems and will continue to follow them closely including offsite prototype valve testing. However, we believe it is acceptable to issue the low power license at this point and to require i
that the MSIV requirements be individually assessed as to their impact on l
initial criticality and power operation requirements. This issue has been carefully reviewed by the NRR and regional staffs, and we are in agreement with the NRR licensing approach.
The following actions are planned by Region I to evaluate the licensee's performance during initial operations:
1.
Three resident inspectors are assigned to the Nine Mile Point site.
The initial operations of Unit 2 will be assigned priority sc-h that coverage will be provided by the resident inspectors to ensure confor-mance with the Technical Specifications.
2.
Region-based startup testing s)ecialists will be assigned such that onsite coverage of fuel loadint and startup testing will be provided.
3.
A special team inspection will review the licensee's operations in an in-depth, diagnostic manner during the power ascension program.
The team will review the effectiveness of their management controls in addition to the safety of their daily operations. The inspectors will utilize the inspection t chniques developed during similar team inspec-tions at TMI,_ Pilgrim and Peach Bottom. This effort is expected to involve in excess of 500 inspection hours.
In conclusion, I find that Nine Mile Point Unit 2 has been constructed substan-tially in accordance with Construction Permit CPPR-112, the FSAR, and NRC requirements, and that the licensee is capable of operating the plant safely at low power subject to the conditions of the license.
=^@
Thomas E. Murley Regional Administrator
Attachment:
Initial Operating License Review Report w/ enclosures cc: w/ attachment V. Stello, EDO J. Sniezek, DEDROGR J. Taylor, IE J. Davis, NMSS R. Bernero, NRR Adensam, NRR
. Haughey, NRR
. in M
7;.
.. ~ ~=
. -, :- c
- - = - - - - - ~ -
4 ke;J.&'
c
+
Wr
. U:-T-e - y e.
, - p :
,- pq g i
i t
h,-'
,.5<
f.
e a
p:
l:.
r
- 9. ~;
n l!'
p e
~ INITIAL OPERATING LICENSE -
REVIEW REPORT FOR-
.1 NINE MILE POINT--UNIT 2 DOCKET NUMBER 50-410 PREPARED.BY
^ UNITED STATES NUCLEAR REGULATORY COMMISSION
.. g g)
REGION I k-I4
[' i.
m_
m
,w.... _,_._.- -,
c.
L a ?.1 spb pg TABLE OF CONTENTS PAGE 1.0--INTRODUCTION
'I
_2.0 FACILITY CONSTRUCTION....................;..
2
^
2.1 ~0verview and Status.............'......
2.2 Irsoection ProgramL.
.2
'2 2.3 Tt
- Party Audits'and Evaluations............
10 2.4 Q s / ty. Assurance 'for Construction........
12 2.5' Construction Summary and Conclusions...........
13 3.0 PREOPERATIONAL TESTING 15-3.1 Overview and Status 15 3.2 Inspection Program...............
15 h
3.3 Quality Assurance for Testing.
16 3.4 Testing Summary and Conclusions.
17-14.0 PREPARATIONS.FOR OPERATIONS..................
18 I
4.1 Overview and Status 18 4.2 Operations Staffing and Procedures............
18 4.3 ~ Quality Assurance for Operations.............
20 4.4 Emergency. Preparedness Program and Facilities........................
21 4.5 Radiological Controls Program and Facilities:
21
- 4.6 Security Program and Facilities...........,.
21 4.7 Fire Protection Program and Facilities'........................
22 4.8 Technical Speci fications.................
22
'4.9 Startup Test Program..............
22 4.10 Operations Summary and Conclusions............
23 5.0 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 24 5.1 Overview.....................
24 5.2 First SALP.........................
25 5.3 Second SALP 25 5.4 Third SALP................,.......
5.5 Fourth SALP 12 5 26
- 5. 6 Fi f th SALP........................
27 6.0 ALLEGATIONS AND INVESTIGATIONS 28 6.1 Overview.....................
28 6.2 Unit-2~A11egations'....................
28 6.3 Unit 1 Allegations....................
29 6.4 Quality First Program 30 6.5 Allegation'and Investigation Summary and Conclusions 31 7.0 REGION ' 1 FUTURE ACTIONS....................
32 8.0
SUMMARY
AND CONCLUSION 33
.l c
K' j
f LIST OF ENCLOSURES Enciosure.
1 inspection Summary for Nine Mile Point 2 2
NMPC Quality Assurance / Quality Control Sumary-e f
1 i
l:
,.o
{
r
'f L.
1.0 INTRODUCTION
i The Nine Mile Point Nuclear Station, Unit 2 (NMP-2).is located on a 900 acre site owned by the Niagara Mohawk Power Corporation (NMPC) on Lake Ontario in Scriba, New York.
It is situated between two operating. nuclear plants, Nine Mile Point Nuclear Station, Unit 1 (NMP-1) and the James A.
FitzPatrick Nuclear Power Plant (FitzPatrick), owned by the New York Power Authority (NYPA).
NMP-2-is a General Electric boiling water reactor (BWR-5) with a Mark II containment. The designed net electrical output is 1080 MWe. Stone and Webster Engineering Corporation (SWEC) has served as the Architect Engineer and Construction Manager.
NMPC currently operates NMP-1, a BWR-2 licensed in 1969, and previously constructed and operated FitzPatrick, a BWR-4 licensed in 1974, prior to its transfer to the NYPA.
Th'is report describes the process used by NMPC to monitor and control quality of construction and preoperational testing, discusses the results of independent evaluations of NMPC's performance, and addresses both the inspection program and the Systematic Assessment of Licensee Performance (SALP) program conducted by NRC Region I.
The report also discusses fa-cility preparations for operation. The Region I staff has gained suffi-
.cient information to assess the performance of NMPC and its major contractors and subcontractors.
This report presents the basis for the Region I conclusion that (1) Nine Mile Point Unit 2.has been constructed substantially in accordance with Construction Permit CPPR-112, the Final Safety Analysis Report (FSAR), and NRC regulations, and (2) the Niagara Mohawk Power Corporation is ready to safely operate the facility, i
I
s s
2 2.0 FACILITY CONSTRUCTION 4
2.1 Overview and Status Construction of Nine Mile Point, Unit 2 is essentially complete.
While early construction work proceeded uneventfully, major quality assurance (QA) problems were found beginning in 1981. NMPC took proper corrective action in response to two civil penalties and completed con-struction in an acceptable manner.
2.2 Inspection Program Region I inspections of construction activities at Nine Mile Point 2 have been conducted in accordance with the program established by the Office of Inspection and Enforcement (I&E). The objective of these safety inspec-tions has been to obtain suf ficient information through direct observation in the field, personnel interviews, and review of procedures and records to determine whether construction and installation of safety-related com-ponents, structures, and systems met applicable requirements. A cortion of the inspection effort has been directed toward inspection of NMPC's Quality Assurance Program and its implementation, as described in the Pre-liminary and Final Safety Analysis Reports.
The Nine Mile Point 2 site was staffed with a construction resident in-spector from October 1981 to May 1983 and from July 1983 to July 1986. A second construction resident was assigned in October 1984 through June 1985.
In November 1984, an additional Senior Resident Inspector was dedi-cated on a part-time basis to follow the preoperational testing program.
Presently a site senior operations resident and two unit resident inspec-tors are assigned. The direct observation, independent verification, and daily presence of resident inspectors at the facility have provided a means to detect quality problems, to track their resolution, and to monitor NMPC's compliance with the site QA programs.
2.2.1 Inspection History Inspection of NMPC began in 1972 and has continued in conjunction with the completion of construction activities. Region I inspections monitored soils and foundations, concrete work, safety-related structures, piping, welding, electrical activities, safety-related mechanical components, in-strumentation, and related areas. Enclosure 1 identifies the inspections performed, the areas inspected, and significant inspection findings. At present, about 150 inspection reports have been issued for the Nine Mile Point 2 facility.
L
m.-
.x
-- -?
3 A comparison of inspection hours' expended at' other BWR facilities at a-similar stage of construction (up to ACRS hearings) is shown below:
NMP2 Hope Creek Shoreham Susquehanna 1 Limerick 8250 hrs.
7600 hrs.
6S00 hrs.
7100 hrs.
7800 hrs.
A total of approximately 12,000 inspection hours have been expended to date at Nine Mile Point 2.
The early inspections conducted at Nine Mile Point 2 through late 1981 did not identify substantive deficiencies. The work activities at that time involved site preparation, concrete place-ment, reactor pressure vessal p'lacement, and QA program reviews. While several violations and infractions were issued, no programmatic problems were apparent.
A Regional Construction Team Inspection conducted in November,1981, in conjunction with the assignment of a site resident inspector, served to identify program deficiencies that were not previously apparent. The con-centrated team inspection approach found several problems with the misap-plication of site QA programs and found an inadequate NMPC program for monitoring their contractors. The Region I staff also identified defi-ciencies with the piping contractor's welding activities. These findings resulted in two enforcement conferences between Region I and NMPC in which Region I informed NMPC that greater management a*.tention and surveillance were needed to ensure control of the piping contractor.
Further Region I scrutiny of the site QA programs resulted in the identi-fication of. Stone and Webster's use of trainees to perform inspections and the associated falsification of inspection' records.
This violation re-suited in a $100,000 Civil Penalty. Also, NMPC's steps to improve the performance of the piping contractor had been ineffective. Between Octo-ber 1982 and August 1983, three management meetings were held with NMPC, during which Region I emphasized that the licensee needed to improve con-tractor oversight so that the subcontractors adequately performed their work.
The I&E CAT inspection in late 1983 provided further evidence that the site QA programs were deficient. The identified QA problems resulted in an enforcement action comprised of a Severity Level II Violation, a
$100,000 Civil Penalty, and an order requiring a management audit, a qual-ity trending program, and an independent review of site corrective action programs.
In response NMPC instituted a major management reorganization to bring experienced personnel on site to guide the remainder of construction ac-tivity and to review past practices. Site software and snspection proce-l' dures were enhanced to closely identify inspection criteria. Numerous reinspection of plant hardware have been performed to assure its adequacy l
relative to the design criteria. Results of nondestructive examination i
activity have been reviewed to assure pressure boundary integrity. The new project management instituted changes in both construction and QA activity to enhance the quality and oversight of site construction.
1----------
^
s 4
4 In response to the weaknesse Jentified in the site quality assurance and project management programs, an Augmented Inspection Program was initiated by Region I in June 1984, which supplemented the routine construction in-spection p' gram.(MC 2512) by the following:
Frequent meetings between NMPC and NRC management to assess the pro-gress of licensee corrective actions.
Additional team and individual inspections t9 assess the effective-ness of site quality programs.
Assignment of additional site inspectors (a second resident and de-talled senior resident inspectors).
Monitoring of NMPC performance indicators.
The Augmented Inspection Program actions have been completed, and this was documented !n a Region I memorandum on August 6, 1986.
Verification of NMPC corrective actions was accomplished by closeout of NRC open items.
2.2.2 Special Team Inspections For a more in-depth assessment of construction quality, several special team inspections were condveted along with the normally prescribed inspec-tion program. These inspections are discussed below:
1981 Regional Construction Team Inspection The first inspection was conducted from November 30 to December 18, 1981 by three region-based inspectors, the resident inspector and a section chief and involved 394 onsite inspection hours. The inspec-tion covered site quality assurance activities; design controls; pro-ject management practices; procurement control; and construction controls in the electrical, mechanical and nondestructive examination areas. The primary inspection function was to assess NMPC management control of the Nine Mile Point 2 construction activities. Several problems were identified as noted below:
Structural steel items improperly released from storage.
Inadequate training of contractor personnel.
Excessive dependence on contractor construction personnel to monitor quality-related activities.
Nonconformances not evaluated to determine root cause.
Untimely corrective action for QA identified deficiencies.
Project Manual without defined position descriptions, leading to confusion on roles and responsibilities.
i ~
- g ~.
.l
[
j M.
Inequitable pay and benefits for QA personnel and ineffective management control over SWEC and subcontractor QA.
Inadequate design control measures.
Cable-tray procurement documents not conforming to The _ National Electric Manufacturers Association (NEMA) standard.
The Notice of Violation issued with Inspection Report 81-13 indicated that the observed deficiencies, when viewed in total, were indicative of an ineffective Quality Assurance program at Nine Mile Point 2.
1983 I&E Construction Appraisal Team (CAT) Inspection In November and December 1983 the Office of Inspection and Enforce-ment (I&E) conducted a Construction Appraisal Team (CAT) inspection to evaluate the management of construction activities and the quality of construction at Nine Mile Point Unit 2.
The inspection team was comprised.of eleven inspectors, including five consultants, and a -
team leader. The. inspection consisted of detailed examinations of installed hardware after NMPC's quality control inspections, examina-tion of procedures and records, observation of in process work, and interviews of -site personnel.
The inspection detected a broad range of prehlems. in construction and inspection programs.
The major findings are identified below:
Electrical cable and raceway installations, particularly in the control room complex, exhibited separation problems that had either not been identified by QC, or NMPC had not determined how these deficiencies would be corrected.
Indeterminate bolting material was utilized on the. station battery racks and at ship-ping splits for switchgear and motor control center enclosures.
Inspection records did not reflett' the design documents to which the inspection had been performed. The inspection procedures were found to be deficient with respect to attributes on raceway marking, acceptance criteria for separation, bolting material identification, and protrusions into cable trays.
The inspection found that HVAC and piping runs were generally erected in accordance with the applicable requirements. Several pipe supports were found to contain deficiencies not previously identified by contractor quality control (QC) personnel. The concrete expansion anchor installation program acceptability was questioned as the pre qualification tests had been performed in a concrete mix of lower compressive strength than normally used for seismic Category I structures. A significant loss of pre-lead was observed when the installed expansion anchors were totgua tested.
.m_____
+
x 6
The insoection identified major deficiencies in the ITT Grinnell program for ASME code radiographs, involving weld quality, film quality, and inadequate documentation. The associated Stone &
Webster Engineering Corporation and NMPC program for review and acceptance of these radiographs was found to be deficiert.
It was noted that some similar problems were also identified by site quality assurance / quality control programs, but timely cor-rective actions were not taken.
Inadequate liquid penetrant surface examination of ASME pressure boundary welds was identi-fied. The site structural welding to the AWS Code was found to be generally satisfactory.
The concrete and structural steel installations met regulatory and specification requirements. Minor problems were identified with concrete placement activities and records.
l The project storage and maintenance programs were examined and found acceptable.
Inadequate control of unused weld filler na-terial was identified, and some pipe support members lacked the requisite inaterial traceability.
In the aggregate, the inspection findings indicated that NMPC had an ineffective audit program. Nonconforming items were dispositioned on documents other than formal QA documents such that the trend programs were bypassed.
Inadequate documer.t con-trol measures were observec, in that out of date drawings were utilized in the field, and inspection records did not reflect the actual design documents used during the inspection. QC in-spections were untimely as evidenced by the wide disparity be-tween the number of items completed by construction in relationship to those inspected by QC-1 On March 20, 1984, an Enforcement Action (EA) was issued for the CAT identified problems at Nine Mile Point 2.
The Enforcement Action was composed of a Severity Level II Ilotice of Violation, an Order, and a Civil Penalty of $100,000. The order called for a management audit, the development of a site quality performance trend program, and
{
an independent review of site corrective action programs.
i NMPC responded to the Enforcement Action with steps to address the specific deficiencies and an overall corrective action program. A q
consultant, Management Analysis Company (MAC), was retained by NMPC to perform the review of the corrective acticn program.
NMPC committed to develop a site quality trend program that would serve to I
monitor the quality levels of various installation activities.
1 l
i j
~.
{
1.
j C
.g i
h 7
f NMPC instituted a complete management reorganization at both the corporate offices and the site. NMPC retained MC to provide key managers with nuclear experience to fill both project and quality assurance positions.
Project management was relocated onsite, and j
the line organization was reorganized such that the Stone and Webster project director reported directly to the NMPC project director.
-Quality Assurance management was strengthened to enhance QA effec-1 t1veness. This significantly improved their control of site acti-
.vities.
In order to provide for trecking and disposition of the inspection
)
findings Region I reviewed the CAT report and classifiec; items as violations or followup items. The Augmented Inspection Program was to utilized to closely monitored NMFC corrective actions via inspection report documentation.
1984 Regional Construction Team Inspection Tre second inspection of this type was conducted by Region I from j
December 3 to December 14, 1984 by six region-based inspectors, the j
senior resident inspector, and a section chief, and invcived 687 in-l spection hours.
The inspection focused on the hardware associated i
with the High Pressure Core Spray system. The inspection noted an
{
improvement in site quality activities following the I&E CAT incpec-l tion and found that the installed hardware met regulatory criteria j
with two minor exceptions. This inspection was used as a partial i
measure of the status and effectiveness of NMPC corrective actions.
1984 Nondestructive Examination Inspection I
An independent nondestructive examination (NDE) inspection was con-
)
ducted by Region I during the Spring of 1984 using the Region I mo-bile NDE laboratory and involved 662 inspection hours.
l l
The purpose of the inspection was to verify the adequacy of NMPC's NDE program through independent testing. This was acconclished by performing the same tests that NMPC had perforsred, and then comparing i
Region I results to those of NMPC. The progrr.. also performed inde-
' pendent pipe wall thickness measurements and radiographic film comparison.
A random selection of welds was used to provide a representative sample of piping systems, components, and structural welds represen-ting various pipe sizes, and shop and field welds fabricated to AWS and ASME Class 1, 2, and 3 standards. The items selected were previously accepted by Nd?C based on vendor, shop, and onsite QA/QC records.
l 1
l i
l
o-8 i
The examinati'ons were performed using detailed procedures specifi-cally written for compliance with NMPC's PSAR commitments to the ASME Section III Boiler and Pressure Vessel Code. The intent was to duplicate, to the extent practicable, the technique; and methods of the original examinations. The independent examinations included:
radiographic testing (RT), liquid penetrant testing (PT), magnetic particle testing (MT), thickness measurement, anchor bolt length ultras:nic examination, hardness measurements, and radiographic film review.
The independent NDE verification showed generally good agreement with NMPC's determinations.
Further NMPC review of radiographic film was accomplished to provide additional assurance of the technical adequacy of the film interpretations.
1985 Nondestructive Examination Inspection A second NDE inspecticn was conducted by Region I f rom December 9 to December 19, 1985. The scope o' the inspection and types of welds
{.'
examined were similar to the er* lier NDE inspection.
No unsatisfac-tory findings were identified.
The inspection covered the following areas:
radiography (RI), liauid penetrant (PT), magnetic particle examination (MT), thickness measurement, hardness measurement, visual examinations, and ferrite testing.
All items examined were found acceptable. The inspection results confirmed that suf ficient corrective actions had been instituted to address previously identified deficiencies in the NDE aret.
1986 As-Built Team Inspection The As-Buf1t Team inspection was conducted from April 14 to April 25, 1986. The inspection was performed by Region I staff including a section chief and six region-basec inspectors. The inspection fo-t
.cused on hardware associated with the service water, residual beat l
removal, onsite electrical power, and control rod drive systems. The inspection examined mechanical, electrical, instrumentation cnd weld-ing areas to assure the as-built conottions reflected the FSAR and design document description. Four sinct violations were identified.
The overell conclusion was that the irstalled hardware was in accor-dance with licensing and design documents, l
2.2.3 Enforcement History The inspection program utllized by the NRC provides for enforcement mez-y sures to promote adherence to regulatory requirements, redace repeated nonconformances, and encourage self-identification and correction of non-conformances. Notices of Violations wera issued when applicable, and NMPC was required to respond with proposed carrective actions.
NRC inspectors i'
m L i 1.-
- t 9
.]
l
'and management reviewed and evaluated these responses for acceptability.
p The-inspection staff subsequently confirmed that NMPC properly completed the' corrective actions.
The following table gives a comparison of the Nine Mile Point 2' enforce-i ment statistics with those of four other BWR plants. Early. en forcement actions were classified as violations, infractions, and deficiencies (in descending order of severity), while the more recent findings contain violations categorized into severity levels ranging from I to V (again, in E
descending order) in addition to deviations from commitments.
Issue of Facility CPPR VIOL INF DEF I II III IV V DEV TOTAL Limerick 1 6/19/74 0
45 20 0 0
- 0. 11 19 5 100 Shoreham 4/14/73 0
38 6
0 0 0 17 13 1 75 4
Susquehanna 1 11/2/73 0
47 15 0 0 0 18 19 3 102 Hope Creek 11/2/74 0
19 5
0 0 0 19 13 2 58 NMP-2 6/24/74 0
12 1
0 1* 1 29 23 1 68
- numerous issues in 9 areas (see page 5).
The.early enforcement history did not indicate any significant programmatic weaknesses at Nine Mile Point 2.
However, a greater number of violations with higher severity levels were assessed later in the project.
The level.
III violation was issued in 1982 for using trainees to conduct inspection efforts and the identification of falsified inspection records.
A $100,000 Civil Peralty was issued for the violation. The. level II violation was issued in 1984 for a multitude of QA problems identified during the I&E CAT inspection, including significant deficiencies in QC inspection pro-grams' and the adequacy of nondestructive examination tests. A $100,000 Civil Penalty and Order were issued to NMPC.
j NMPC instituted numerous corrective actions including program revisions I
and hardware reinspection, as discussed above in the I&E CAT Inspection l
section (page 5). As a result of the post-I&E CAT Inscection Order, a-third party evaluated the adequacy of the corrective actions, and NMPC addressed the recommendations of that third party audit.
NMPC developed a performance indicator management tracking program to assess the overall quality of the plant construction. Based upon NMPC s response to the third party findings and implementation of the Quality Performance Manage-ment Program, the conditions of the Order were terminated on March 13, 1986.
Overall, the number of violations at Nine Mile Point Unit 2 is below aver-age. relative to other recently licensed BWRs in Region I, but the large number of issues associated with the CAT inspection severity level II vio-lation and the fact that it is the only construction facility in Region I to receive two civil penalties, give it the poorest overall enforcement performance in Region I for a construction facility.
Close NRC scrutiny
- s f
4
-._xa--
_ _ ~ _.. - - -. = --
10 and strong enforcement action have been necessary to assure competent con-struction management and an acceptable construction quality at Nine Mile Point Unit 2.
2.2.4 Review of Construction Deficiencies Significant deficiencies in design and construction, as defined in 10 CFR 50.55(e), are required to be reported to the NRC. The responsiveness of NMPC to this requirement and NMPC management's attention to this reporting activity are a measure of the licensee's commitment to quality and ability to identify abnormal conditions.
Continuing review by Region I indicates that NMPC's program of significant deficiency reporting has been effective. To date, NMPC ha~s evaluated 265 potentially reportable construction deficiencies and has reported 164 de-ficiencies under 10 CFR 50.55(e). Of these, 76 were subsequently with-drawn after further evaluation.
The reported deficiencies covered a wide range of topics.
The most sig-nificant deficiencies involved the main steam isolation valves (MSIVs), a unique ball valve dign manufactured by Crosby.
The MSIVs were unable to meet the FSAR and Te.nnical Specification closure time criteria of 3 to 5 seconds, because the taechanical latching rnechahism did not release quickly enough.
In addition, during extensive testing the roller bearings associ-ated with the latch mechanism cracked. The third significant MSIV defi-ciency involved the failure to meet the FSAR and Technical Specification leakage requirements following stroke testing due to flaking of the tung-sten carbide coating from the ball and the apparently associhted scratch-i ing of the seating surface. All of these deficiencies were reported in l
August and September 1986 and have received extensive review by NTC Region I and NRR.
2.3 Third Party Audits and Evaluations Aside from their own quality assurance and quality control (QA/QC) over-sight programs and pro.1ect management evaluations of construction, NMPC participated in additional evaluation programs sponsored by independent organizations. These included the Institute of Nuclear Power Operations (INPO) and the Joint Utility Assessment Team (JUAT). Also, an independent team of SWEC engineers performed a Design Verification Program audit.
Region I has remained cognizant of the findings generated during the inde-pendent evaluations and concluded that no additional action by tre NRC was required.
2.3.1 INPO Evaluations a
In September 1982 NMPC conducted an INPO self-evaluation which involved approximately 2600 man-hours.
Problems were icentified with QA/QC staff-ing levels, design control, and segregation of nonconforming material. No L
substantial hardware coficiencies were identified.
j i
l l!
i J
[
11 Following the I&E CAT Inspection and the resulting enforcement action, an INPO construction audit was conducted from September 24 to October 5 and October 15 to October 19, 1984.
The audit addressed organizational struc-f ture, desigr. control, material storage, residual heat removal system de-sign verification, QA program implementation, equipment qualification, hardware installation inspections, plant safety, and test activities.
Three Construction Deficiency Reports were prepared as a result of INP0 concerns regarding control of equipment spare parts, diesel generator voltage profile study for 600 V Class IE starting loads, and the auxiliary system voltage profile without the 208/120 VAC systems.
The audit identified licensee strong points regarding NMPC assessment of contractor performance and the scope of Stone and Webster Engineering Cor-poration (SWEC) Engineering Assurance Audits.
2.3.2 Joint Utility Assessments The Joint Utility Assessment Team (JUAT) program provides independent au-dits by utility senior management of a licensee's QA activities.
There have been four JUAT audits of NMpC corporate and site QA efforts. The most recent assessment covered the period of March 5 - 9, 1984.
The scope of the audit included QA coverage of startup and test activities, effec-tiveness of nonconformance trending programs, and timeliness of corrective actions resulting from the I&E CAT inspection.
Several enhancements were recommended for improving the trending efforts and resultant application of corrective actions. The audit identified examples of inadequate followup to QA nonconformances in that root causes were not identified and corrective actions to preclude recurrence were not specified in the non-conformance report dispositions.
2.3.3 Design Verification Program The SWEC Engineering Assurance (EA) technical audit program was imple-mented in lieu of either an Independent Design Inspection or an Indepena dent Design Verification Program. The final EA technical audit was performed from April 29, 1985 to July 11, 1985. The audit team was com-prised of 20 team members that had no direct design responsibility for Nine Mile Point. The purpose of the audit was to assess the entire design process with respect to FSAR commitments and regulatory requirements. The commitment implementation was verified in design criteria, diagrams, spec-ifications, vendor documents, design changes, and as-built verification programs.
The audit scope included the following areas:
Reactor core isolation cooling system Electrical AC and DC power distribution Control building structure Main steam tunnel structure Structural load tracking
f.{'
((- [
.[
12-
'As-built stress reconciliation' Environmental qualification Raceway supports-Electrical separation High energy line breaks Seismic interaction
' Design documents were reviewed to ensure-that the design met. base require-ments and commitments and was based on complete, accurate calculations and documents. Additionally, plant walkdowns were performed to supplement the document review phase to verify proper implementation of the design requirements.
The NRC Office of Inspection and Enforcement monitored the' audit planning
' stage, audit conduct, and resolution of the audit action items.
The SWEC audit concluded that the design process was adequate, in '.that none of the
. identified deficiencies were caused by a programmatic design weakness.
2.4 Quality Assurance for Construction NMPC's construction quality assurance program was described in the PSAR-and was implemented through the Stone & Webster Quality Assurance Manual.
A summary of the activities of the quality assurance program is presented in Enclosure 2.
This summary was based on data presented by NMPC.
As discussed in Section 2.2.2, the CAT ~ Inspection concluded in early 1984
.that the quality assurance activities at NMP-2 were poorly controlled and implemented and.were generally ineffective. The resulting enforcement action required NMPC to undergo an' independent management audit, which precipitated a major reorganization of construction and quality assurance management. Under the new management, site activities were reoriented toward assuring that proper quality was an integral part of construction and that quality assurance personnel independently confirmed the quality.
In. addition to the management reorganization, NMPC.took the following cor-rective actions concerning reinspection and review of the quality of.com-pleted work:
Reinspected mechanical equipment bolting and structural steel on a sampling basis to verify acceptability.
Inspected Power Generation Control Complex (PGCC) to identify elec-trical separation violations.
Reinspected previously accepted hardware installations to establish the quality level.
Repeated liquid penetrant tests on ASME pressure boundary welds.
_; 4 '
i 13 Reinterpreted ASME pipe weld radiographs to ensure that all reject-able indications'had been resolved.
Tested concrete' expansion anchor bolts to demonstrate load carrying capacity.
As part of assuring proper quality in the remaining construction work, NMPC took the following corrective actions:
Increased NMPC surveillance and audits of contractor performance, particularly hardware related activities.
Reviewed inspection procedures and attributes to ensure adequate ac-ceptance criteria definition.
Assessed in-depth the adequacy of contractor QA organizations.
i Also, NMPC developed a Quality Performance Management Program (QPMP) which monitored the quality status of the site. Key parameters such as quantity installed, quantity inspected, and QC acceptance rates were trended for construction hardware commodities.
The program monitored outstanding de-sign changes and open QA deficiency documents. Trending was performed on some of the documented nonconforming conditions.
Region I monitored the utilization of QPMP by NMPC through management meetings, review of QPMP data, and attendance at the QPMP review meetings at the site.
- Region I developed an acceptable degree of confidence in the NMP-2 nonde-
'?
structive examination (NDE) program as a result of the independent verifi-cation of NMPC's examinations, usitg the NRC Region I NDE Van, as discussed in Section 2.2.2.
2.5 Construction Summary and Conclusions The quality of design and construction at Nine Mile Point 2 has been the subject of extensive NRC inspection efforts. Significant weaknesses were identified in the application of the Quality Assurance Program as evi-denced by both hardware and management deficiencies. The contractor Qual-
)
ity Assurance and Quality Control (QA/QC) functions were ineffectively j
implemented, aad the NMPC OA overview failed to detect the problems. The root causes of the problems included a lack of NMPC management involvement at the project, excessive reliance by NMPC on the contractor quality and engineering organizations, and a weak NMPC QA program.
NMPC instituted a major management reorganization in early 1984 to bring experienced personnel onsite in both the quality and project management organizations. Project management created a goal of all personnel per-forming their job correctly the first time. Training and welder qualifi-cation testing was enhanced to improve the quality of pipe welding.
Site inspection procedures were enhanced to clearly identify inspection at-tributes. A management trending program was developed which tracked pa-rameters such as QC acceptance rates, amount of work remaining, open QA
)
4 i
j
C
~
14.
p findings, gnd incomplete engineering design changes. Extensive hardware reverification were performed by NMPC to assess the quality of-the L
in-situ hardware. The site radiography program was extensively audited to verify-assurance of pressure boundary weld integrity.
Routine' NRC inspections have continued to identify specific instances of
. hardware or management deficiencies.
Some of the concerns relate to improper translation of licensing commitments into the site design process.
SWEC engineering has contributed to several concerns through the incomplete assessment of design basis events on plant systems.
Recent inspections have verified that the NMPC corrective actions have effec-tively resolved previously identified concerns. The plant systems have been generally installed in accordance with the FSAR and design documents.
System functional capability has been ' demonstrated in the associated preoperational tests Mil results review inspections, NMPC's efforts to reinspect and review earlier construction activities and their improved commitment to quality assurance following the 1984 Enforce-ment Action have resulted in a quality project. Overall, Region I finds the construction program quality at NMP-2 to be acceptable.
G
j
' b..
15 3.0 PREOPERATIONAL TESTING 3.1 Overview and Status _
The preoperational test program was composed of two phases,' including the-preliminary component testing and the preoperational and acceptance test-
.ing.
To date, 124 of 140 integrated' system reoperation and acceptance tests'have been completed including results approval.
The remainder of the preoperational.and acceptance tests are in progress, in the results review phase, or will be deferred until after license issuance. All pre-operational tests required' for fuel load have been completed and reviewed.
NMPC has requested deferral of preoperational testing and post-test review.
of the following systems until after fuel load.
Hydrogen recombiner system.
Offgas system Containment atmosphere monitoring system Electro-hydraulic control system Completion of the deferred testing is keyed to post-fuel load milestones.
Detailed, technical descriptions of the requested deferrals have been 'sub-mitted to both NRR and Region I for review.
3.2 Inspection Program The preoperational test inspection program began in January 1985 and was conducted t:y both resident a'd :.gion-based specialist inspectors. In-spections of. management' controls and procedures, including the quality assurance program, initially indicated inadequate test procedure review in-that some design criteria' would not have been confirmed by testing. In addition, NMPC initially took credit for preliminary tests to satisfy-preoperational test acceptance criteria without prior notification-to the
'NRC.
After considerable interaction with Region I, NMPC corrected these deficiencies.
Inspection of test procedures,-test performance, and test results has progressed consistent with NMPC's activities.
NRC preoperational test procedure review, test observation, and review of NMPC's test results, including resolution of test deficiencies and retest-ing are complete.
During the course of Region I inspection activity, the following areas l
have been inspected:
29 preoperational tests reviewed 15 preoperational tests witnessed 26 preoperational test results reviewed I.
1&.
.;=
y E
j l
.j-16.
i l
Inspection reviews concluded _that the preoperational tests satisfa'ctorily tested system function and logic, and the performance of preoperational tests has been generally acceptable. The few examples found in which the preoperational acceotance criteria were inconsistent with licensing com-
]
mitments were corrected.
The test engineers were found knowledgeable of their systems. and the administrative test controls. - Adequate test witness coverage by quality assurance personnel was noted.
The' Containment Integrated Leak Rate Test was successfully performed in, April 1986. The Loss of Power Test was successfully performed in May I
1986.
3.3 Quality Assurance for Testing Startup Quality Assurance and Quality Control performed both monitoring.
and auditing functions during preoperational testing.
The presence of startup QA/QC throughout the preoperational test procedure review, test' performance, and test results review processes has been evident.
Late in the preoperational testing phase (July 1986) contractor QC person-nel assigned to the NMPC QA department raised concerns about their support from management in assuring the quality of work' done during the testing phase and about programmatic issues not being properly resolved. These concerns were raised to NMPC's internal allegation clearinghouse system known as the Qcality first Program, discussed further in section 6.0.
After becoming aware of these concerns in August 1986, management meetings between Region I and NMPC were held on August 29 and September 4.
NMPC concluded that while the concerned inspectors had raised some valid pro-grammatic concerns, which were being addressed, these concerns had not resulted in any unsatisfactory hardware conditions.
These conclusions were based on interviews with all QC inspectors, both NMPC personnel and contractors, who could not describe any unresolved hardware' issues.
In addition, NMPC stated that the QC function was overchecked by QA audits, QA surveillance, and QA engineering.
An NRC Region I team inspection was conducted from September 8 to'12,1986, to independently assess these conclusions. After reviewing NMPC's inves-tigation, interviewing a sizeable sample of NMPC's QA department staff including supervision and management, and following up on lingering con-cerns identified by these interviews, Region I agreed with NMPC's conclu-sion that hardware had not been adversely affected and that programmatic concerns needed to be addressed. These programmatic concerns apparently stemmed from the following factors.
A poor transition from a rigidly defined Stone and Webster construc-tion QA program to a more flexible NMPC operational QA program with little implementing policy guidance from management.
An aggressive and sometimes overzealous Startup and Test
/
Organization.
Lw
WTO
. {: *
~
L I7 -'
Little feedback from supervision on the resolution of interdepartmen-tal conflicts.-
Poor communications between the QC inspectors and their management concerning a QA. department. reorganization.
The inspectors also concluded that there was a lack' of clearly defined '
111mits and 1.ns'pection. criteria' for troubleshooting activities during main-'
tenance of equipment.
The Region I team: inspection also established that-LQA. surveillance and engineering activities were identifying hardware is-sues not identified by QC.and therefore, providing an effective overcheck of QC activities..
NMPC's initial corrective actions.to these concerns included Vice Presi-dent - QA meetings'with all levels in the QA department to explain depart-mental policy and direct field involvement of QA engineers in defining inspection criteria for. troubleshooting-activities. NMPC identified addi-tional corrective actions to Aegion I in a' letter dated September 9,1986.
These corrective actions will be tracked by Region I.
2.4 Testing Summary and Conclusions Re'gion I inspections of.the Nine Mile Point Unit'2 preoperational test program included' programmatic. reviews, test procedure reviews, test' wit-nessing and test results evaluation. The technical adequacy of test pro-cedures has been acceptable, and the personnel performing tests have been well qualified..NRC review has determined that the test results review and approval process and NMPC's resolution of test exceptions and defi-ciencies have been well documented and supported. :The issues raised by.
the QC personnel did not cause any adverse effects on the installed equip-ment;or its testing, and resolution of the programmatic concerns will be tracked'and reviewed by Region I.
l l
L i-
)
u 2
gm_
yv n
y 18 4.0 PREPARATIONS FOR OPERATIONS 4.1. Overview and Status NMPC's activities in preparation for initial fuel load were closel, moni-tored by Region I.
Facility staffing, personnel qualifications, training, procedure development, and implementation and establishment of operational organization interfaces have been reviewed. The first new fuel shipment was received onsite on December 5, 1985.
Fuel handling and receipt in-spection were performed in a well controlled manner with one minor incident.
The Nine Mile Point site organization, similar to the multiunit site or-ganization used when NMPC operated both Nine Mile Point Unit I and Fitz-Patrick, has been in place and functioning since before the preoperational test program began in April 1985.
Except for the independent operations departments reporting to the Unit I and 2 Station Superintendents, all other departments will be site departments reporting to the General Super-intendent of the Nine Miie Point site. However, each department will have dedicated unit supervisors and assistants but will draw from common man-power resources.
NMPC's efforts to prepare for the licensing and subsequent operation of Nine Mile Point Unit 2 have been guided by and focused through the Pre-paredness for Operations Plan, which ider.tified all procedures, personnel qualifications, and training required prior to fuel load, assigned respon-sibility for completion to the appropriate department or individual, and established a schedule for completion. This readiness overview has been conducted by the NMPC Quality Assurance Department.
4.2 Operations Staffing and Procedures The Nine Mile Point Unit 2 Station Superintendent and Operation Superin-tendent are responsible for the safe operation of the plant. The Opera-tion Superintendent ensures that plant operation complies with the facility operating license, technical specifications, and all NRC and com-pany regulations. He ensures that a properly trained, licensed and non-licensed staff is available to support safe unit operation.
All licensed operators at Nine Mlle Point Unit 2 were previously licensed on either Nine Mile Point Unit 1 or FitzPatrick. Therefore, NMPC does not plan to use shift advisors during plant startup, power ascension, or routine operations.
The shift staffing levels of licensed and nonlicensed operators will be i
adequate to support startup and low power operations.
Each startup shift j
is composed of at least 2 SR0s, 3 R0s, and 2 A0s.
The first set of reactor operator (RO) and senior reactor operator (SRO) i license examinations were conducted on June 11, 1985 with the following results:
l I
Fs n
a
);
/*/
+
L1 P
5 19
-12'SRO candidates - 10 passed 12 RO candidates - 3 passed The second set of RO and ERO license examinations was conducted on December 9, 1985 with the following results:
12 SRO candidates - 8 passed 20 R0 candidates - 18 passed The third set of RO and SRO license examinations was conducted on July 22, 1986 with the following results:
9 SRO candidates - 5 passed 5 RO candidates - 5 passed Based upon the relatively poor results from the first examination, a spe-l cial inspection of the NMPC training programs was performed during the week of October 28, 1985. The programs inspected were licensed operator
{
training and technical, training for technicians. Several factors were identified as having contributed to the high failure rate of initial li-cense candidates,. including an incomplete plant simulator, the lack of some operating procedures, the use of nonstandardized text books, and an insufficient number of written exams given during the training program.
NMpC has addressed these problems. No concerns were identified with the nonlicensed personnel training program. Excellent physical facilities were available for training.
Instructors were knowledgeable, and students had a positive attitude toward training.
The second set of licensing examinations was administered in December 1985.
The results demonstrated a significant improvement over the first license examination results.
Ninety percent of the R0s and 66% of the SR0s passed the examination. The 34% failure rate of SR0s is somewhat higher than normal. However, a distinct separation between passing and failing exam scores was observed, indicating that the cause for the failures was indi-vidual candidate deficiencies and poor screening of candidates and not programmatic deficiencies. Marked improvement in the simulator perfor-mance was noted during the second examination. A program for improving
.the simulator fidelity was determined to be warranted.
The third set of licensing exams was administered in July 1986. The re-sults of the SRO exams (5 passes and 4 failures) again indicated individu-al weaknesses and poor screening of candidates versus training program problems. The 5 successful candidates all received high grades in each written section, whereas, 3 of the failures did poorly in all written sec-tions. The fourth failure was due to poor performance on the simulator portion of the exam.
The Region I review of NMPC's preparations for operations included inspec-tions of procedure preparation, review, and approval as well as implemen-tation where possible. Management control of the process and safety committee actions were also evaluated.
___=_
mp
. ;w v
j.
l *,~
20 Specific'. inspections between _ April and July 1986 reviewed plant adminis-trative, operating, maintenance, and emergency procedures. NMPC has pri-oritized the preparation process and'has written those procedures needed for modes 4 and 5 first. Most procedures had been prepared, reviewed, and approved as interim operating procedures. NMPC's program has been to field test the procedures and after additional review and proof testing, convert them to plant operating procedures.
Inspection results indicate two additional areas where NMPC is continuing to finalize their program: 1) preventive maintenance scheduling for elec-trical instrumentation, and 2) completing the motor surveillance schedul-ing program.
NMPC's' actions to date and plans fcr completion appear ade'quate for ini-tial station operations.
4.3 Quality Assurance For Operations The NMPC Quality Assurance (QA) organization for plant operation has been defined. The QA organi,zation will report to a Vice President - QA. The four QA managers reporting to him will have the following responsibilities:
Nuclear OA Operations: surveillance, QC inspection, trending, personnel training and certification.
Corporate OA: audits, procedures, Quality First Program, trending, personnel certification.
Quality & Reliability Engineering: Vendor surveys, procurement docu-ment reviews, inspection planning, Nonconformance Report (NCR) dispo-sition, and trending.
Non-Nuclear QA Operations: surveillance, inspection, trending, per-sonnel training and certification.
A QA topical report, which endorses NOA-1 and ANS 3.2, has been submitted and approved.
During April 1986 a Region I mini-team inspection, consisting of 3 inspectors, was performed which reviewed nonlicensed personnel training, control of measuring & test equipment, QA staffing, QA training, QA audits, and QA implementing procedures. The operational QA program was determined to be satisfactory.
)
The implementing QA procedures were developed from existing Unit 1 proce-dures, which complied with ANSI N45.2 and its daughter standards. These implementation procedures referenced ANSI N45.2 and its daughter standards and generally exceeded the requirement of the NMPC QA topical report.
]
NMPC, upon issuance of the QA topical report, initiated a consistency re-view of implementing procedures against the QA topical report.
Several inconsistencies in references were identified by both NMPC and the NRC and l
l
____._._______________________.________________________________________._____________________________________.________._________a
p 1
c.
h
- .?
21 are being corrected. NMPC's current schedule is to complete this effort prior to commercial operation.
As noted in Section 3.3, the transition from a construction QA environment to an operational QA environment was not smooth, particularly in the QC inspection group.' It was complicated by more than one departmental: reor-ganization, by policy guidance which was not well defined or communicated, and by less structured controls over troubleshooting activities than in the construction program.
In spite of these weaknesses, a generally well qualified and experienced staff of NMPC and contractor auditors,'inspec-tors, and. engineers has identified and corrected hardware deficiencies during the testing ' program.
In addition, a strong surveillance program has been helpful in identifying hardware problems and trends which were H
missed by the inspection staff.
I 4.4 Emergency Preparedness procram and Facilities A full participation Emergency Plan exercise was conducted on November 13, 1985 for the Nine Mile Point site Unit I with joint NRC/ FEMA observation.
The newly constructed Technical Support Center and Emergency Operations Facility' functioned acceptably during the exercise. The joint Operational Support Center was also found satisfactory.
The Nine Mile Point state and local plans and preparedness for radiologi-cal emergencies have been evaluated by FEMA and found adequate in accor-dance with 44 CFR 350. The adequacy of the public alerting and notification system was determined to be acceptable. An Emergency Pre-paredness Appraisal for Unit 2 was conducted on May 19-22, 1986, and the results were generally good. The.open items from the appraisal were closed out in an followup.aspection conducted on August 4-6, 1986.
4.5 Radiological Controls Program and Facilities Region-based inspections have been conducted to assess the Radiological Controls Program.
The inspections have evaluated the environmental moni-toring, health physics, radioactive waste management, and radiological controls programs. As these programs at Unit 2 represent extensions of the existing programs at Unit 1, the main emphasis was on the installation and testing of the new equipment and the training of the new personnel.
In general, the programs were found to be acceptable. The specific elements associated with fuel receipt were inspected and found to be acceptable.
4.6 Security Program and Facilities Preoperational inspections were conducted in this area beginning in June 1984. The inspections covered the review of the Physical Security Plan and implementing procedures; security organization; security audit pro-gram; security records; security system testing and maintenance; control of locks, keys, and combinations; physical barriers for vital and protect-ed areas; security system power supply; lighting; assessment aids; access l
22 control for personnel, packages and vehicles; detection aids; alarm sta-tions; communications; personnel training and qualifications; and contin-gency plans.
The NMPC plans for Nine Mile Point 2 Physical Security, Safeguards Contin-gency and Security Training / Qualification have been approved.
4.7 Fire Protection procram and Facilities i
Region-based inspections have assessed NMPC's operational readiness with respect to fire protection features.
The inspection scope included the i
capability to safely shut down the plant in the event of a design basis fire and the emergency lighting system components. Sevesa-1 unresolved concerns were identified which involved minor hardware problems. Other concerns were identified due to many incomplete construction items (light-ing, fire detectors, and fire seals). The Fire Protection Program organ-ization, administrative controls, equipment maintenance, inspection and test program, fire brigade training, and QA audits were reviewed and de-termined to be acceptable.
4.8 Technical Specifications The proof and review Technical Specifications (TS) were issued by NRR on November 22, 1985.
NMPC and the staff provided comments back to NRR in January 1986.
A comparison inspection of the proof and review TS, FSAR, and as-built plant was performed from January 6,1986 to January 17, 1986 by a Region 1 consultant team. The inspection verified through walkdown inspections that select *C installed hardware was compatible with the TS.
Preopera-tional and surveillance test procedures were examined to assure that their performance would fulfill the TS requirements. Both the program and pro-cedures were adequate.
In addition, the resident inspectors and region-based staff revi'wed the final draft Technical Specifications and found them to be acceptable.
4.9 Startup Test Program NMPC has prepared drafts of all startup tests and has approved 111 of the 121 total. NMPC recognized that some inconsistencies could exist between the startup procedures and approved operating procedures, and therefore, a second review of the startup test procedures for consistency and workabil-ity will occur prior to use. NRC inspection findings also supported the need for a second review.
NMPC has proposed some reductions of their test program based on their review of the Pope Creek program, but the magnitude of the reduction pro-posals are far less than approved for Hope Creek.
23 The administrative controls for the implementation of the startup test program have been revised based on inspection findings and represent-l adequate controls to implement the program.
1 The staffing levels of the startup program are adequate to implement the program. Training of personnel including operators and test personnel will be performed prior to beginning the program.
4.10 Operations Summary and Conclusions Region I has performed readiness for operations inspections in accordance with the I&E inspection program and generally found NMPC's programs to be well organized and consistent with regulatory requirements, Areas in-spected included operational staffing, training, procedures, quality as-surance, fire protection, emergency preparedness, water chemistry control, radiological controls, security and technical specifications. Because of previous licensed operator experience at Nine Mile Point Unit I and Fitz-Patrick the use of shif t advisors in the control room will not be required during the power ascension program. Based on programmatic reviews and observations of activities, Region I feels that the Nine Mile Point Ur.it 2 facility and staff will be ready to conduct low power operations upon com-pletion of the preoperational test program and applicable surveillance testing.
i 24 5.0 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 5.1 Overview NMPC's performance has been assessed five times under the SALP program. A tab-ulation of.the results of these five SALP Reports is presented below in Table 1:
TABLE 1 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
SUMMARY
SALP No.
FUNCTIONAL AREA SF CONT PIP COMP SYS ELEC INST ENG.
0A LIC 1
2 2
2 2
2 2
2 2
2 1
1 2
2 2
2 N
3 2
3 1
2 3
2 2
2 3
2 4
2 2
1 1
3 2
3 2
2 OP RAD SUR POT FP SEC CONST QA LIC 5
2 2
3 2
1 1
2 2
2 SF = Soils and foundations CONT = Containment and other safety related structure PIP = Piping and supports COMP = Safety related components SYS'= Support systems ELEC = Electrical power systems INST = Instrumentation and control 1
ENG = Engineering QA = Quality Assurance LIC = Licensing OP = Readiness for Operations RAD = Radiological controls SUR = Surveillance i
POT = Preoperational testing FP = Fire protection SEC = Security CONST = Construction N = No basis for rating i
- = Not assessed l
3 25 5.2 First SALP (February 1, '1980 to January 31, 1981)
Inspection activity had covered the containment structure, reactor pres-sure vessel installation, reactor pressure vessel internals, biological shield wall, and quality assurance. Only one notice of violation had been issued during the period for inadequate incorporation of design changes into the associated engineering drawings. NMPC had reported four 10 CFR 50.55(e) reports.
5.3 Second SALP (October 1, 1981 to September 30, 1982)
Two enforcement conferences (50-410/82-06 and 82-08) had been held to dis-cuss a violation involving ASME Class I weld procedures that had not been properly qualified for impact testing. The following root causes were identified: inexperience of the piping contractor (ITT) personnel, inef-fective Stone and Webster control of the piping contractor, and inadequate NMPC attention to subcontractor activities.
NMPC committed to strengthen.
ITT engineering and QA staffs, to increase SWEC audits of ITT programs, and to reorganize the NMPC corporate offices to create two new positions of Vice President-QA and Senior Vice President Nuclear to serve as respon-sible NMPC management for all project matters.
There were several concerns in the Electrical Power Supply area in;luding failure to specify design separation criteria in the installation 2pecifi-cation, cable trays did not conform to procurement specifications, incor-rect design of cable tray weldments, and inadequate weld deposit on cable tray cross brates.
There were significant weaknesses within NMPC and contractor QA programs including: inexperienced personnel on the QA staffs, failure of QA to identify programmatic weaknesses, NMPC overdependence upon SWEC QA to as-sure plant quality, inability of NMPC to resolve audit findings, lack of licensee control of SWEC activities, and inadequate NMPC management in-volvement in the project.
NMPC corrective actions to the QA shortcomings included: increased the site QA staff, created position of Vice President-QA, increased NMPC QA surveillance, increased SWEC surveillance of contractor activities, and increased overall NMPC management control of SWEC activities.
5.4 Third SALP (October 1, 1982 to September 30, 1983)
Region I identified two violations regarding the QC acceptance of noncon-forming concrete expansion anchor bolts and the inadequate QC inspection of structural steel bolted connections. The NMpC performed extensive re-inspections to assure the adequacy of other hardware.
During the period, major deficiencies were identified by NMPC in the ITT radiography program.
Several instances of film enhancement were discov-ered by NMPC. The questionable welds were radiographer again and found acceptable.
NMPC project management and oversight of ITT were weak as indicated by inadequate QA review of weld planner packages, inadequate
y.
,, y 26
~
control of the NDE process, and ITT QA management's prohibition of person-nel expressing quality concerns to'the NRC.
An Enforcement Conference (82-13) was held on October 20, 1982 to discuss the improper use of QC trainees and the falsification of QC inspection records. Region I stated that greater NMPC overview was required of pro-ject QA activities.
' On May 23, 1983, a Management Meeting (83-09) was held to discuss the ne-cessity for increased NMPC control over ITT' Another Enforcement Confer-ence (83-14) was convened on August 30, 1983 to discuss the prohibition of personnel from bringing safety concerns-to the NRC. - Steps were instituted to increase.the ITT OA staffing and to increase the level of NMPC surveil-lance of ITT activities.
5.5 Fourth SALP (October 1,1983 to January 31,1985)
There were further problems with the application of the AISC acceptance criteria for high strength bolting. NMPC reinspected and reworked the associated structural steel connections.
Vendor Procurement Quality Assurance (PQA) activities had not been effec-tively implemented. Nonconforming hardware had not been detected by PQA as evidenced by: undersized shop welds, inadequate mechanical component bolt thread engagement, and electrical equipment vendor wiring deficiencies.
The NMPC Quality Performance Management Program identified improved QC acceptance rates for piping and pipe support installations. The SWEC small bore piping hardware was of high quality.
The control of-Preventive Maintenance (PM) activities required greater levels of management attention to assure that plant equipment was properly maintained during the construction phase.
Electrical wiring deficiencies were identified throughout the PGCC panels.
The entire PGCC was reinspected by GE and SWEC personnel to identify all locations of electrical separation problems. Additional concerns regard-ing the PGCC wiring terminations, harness supports, and as-built verifica-tion were identified.
Extensive project management and quality assurance personnel changes re-sulted in improved NMPC control of site activities. The Quality Perfor-mance Management Program served as a maragement trending tool to identify those areas on which to focus management attention. Numerous program enhancements were instituted to upgrade site nondestructive examination efforts.
The rate of design change remained high. Examples were detected in which the design change documents were inaccurate and not completely reviewed.
Several components were identified which engineering had not designed to l
L
E3 O
~ ~ ~
'i
~~n.'
/nl *.T t
appropriate seismic standards. Some instances were found where the design drawings had erroneously identified components as nonsafety-related.
An. enforcement conference and several management meetings were~ held to-
~
discuss the CAT inspection findings and the implemented site corrective actions.
5.6 Fifth SAlp (February 1,1985 to January 31, 1986)
This~ assessment concentrated mainly on readiness for operations-and con-struction transition.
It found NMPC's performance satisfactory.
Improved craft attitudes regarding the necessity to build quality. into the plant were apparent, while management maintained oversight'of construction quality through a site trending effort that tracked key parameters.
In addition, the acceptability of previously installed components was assured.
through reinspection efforts. Notwithstanding, poor housekeeping condi-tions, the occasional lapses in the implementation of complete corrective actions, and control of Final Safety Analysis Report commitments were areas where improvement was noted as being needed.
The preoperational test activities have been executed by generally knowl-edgeable personnel, and the field testing was well controlled. Close mon-a itoring of preoperational test activities was maintained by-Quality Assurance personnel. Also, permanent plant staff were actively involved in the system turnover and preoperational testing process to gain system familiarization and to exercise plant operating procedures.
Increased management attention was warranted. in performing more timely reviews of preoperational test results to' assure that satisfactory test completien was achieved.
For the transition from the construction phase, NMPC conducted a self evaluation to assure that all necessary preparations were performed to support plant operations. The permanent plant staff positions were filled with technically competent personnel. Due to a high Reactor Operator failure rate on the initial licensed operator examinations, increased man-agement attention was given to the operator training program to ensure that a. sufficient number of licensed operators were available to support fuel load. As a result, significant improvement in candidate performance was noted on the second set of examinations.
Some recurring program and individual shortcomings were noted on the thrid set of examinations for senior operators.
l
W j
J n
^!
r.
'l 28
]
t 6.0' ALLEGATIONS AND INVESTIGATIONS 6.1 Overview
' Allegations received by NRC Region I addressed both safety-related and nonsafety-related areas.
Each allegation was reviewed by a board that included regional management, and appropriate followup was determined based on'the potential safety significance of the allegation. Several of.
these allegations were investigated by members of the NRC Office of l
!?
Investigations.
6.2 Unit 2 Allegations Region I records indicate that 37 Nine Mile Point Unit 2 allegations have been received to date.
Of those allegations which were substantiated, 5 resulted in enforcement action as discussed below:
An allegation was received in September 1982 that uncertified quality control personnel.were performing inspections. Subsequtnt Region I investigation verified that inspections of safety-related electrical equipment had been performed solely by uncertified trainees. The associated inspection records were falsified, as qualified Level II inspectors had signed the documents, which signified the in',pections were performed by certified personnel. The deficient inspections and the falsified inspection records demonstrated the need for tJMPC to increase its management involvement with contractor activities to assure proper. implementation of site QA/QC programs. A "evel III violation and civil penalty were assessed. NMPC reinspected the work performed by the trainees and did not identify any substantive deficiencies.
An allegation was received in February 1983 that ITT welders were not provided weld procedures for ASME piping installation. The concern was substantiated through interviews with craft supervision and weld rod room attendants, and a Level IV violation was issued. NMPC con-ducted extensive training programs to ensure that craft personnel were aware that weld procedures are maintained for reference at all ITT weld rod issue stations. NMPC verified that the weld procedures were indexed at the field stations.
An allegation was received in April 1983 that inconsistent diesel generator loading sequences were assumed by General Electric aad Stone and Webster Engineering Corporation. The FSAR load sequencing was found to be inaccurate, and a Level V violation was issued for inadequate design review. NMPC amended the FSAR to portray the cor-rect load sequencing and instituted measures to enhance the review of FSAR submittals.
An allegation was received in April 1984 that Quality Assurance Audi-tors involved in Audit 84-4 were harassed and intimidated. An 01
.E 29 investigation completed in April 1986 substantiated that there was evidence to support four instances of harassment and intimidation including stripping two lead auditors of their lead auditor status, denial of a promotion to a lead auditor, a reduction in points on a performance evaluation of a lead auditor and adverse comments on a performance evaluation of a QC inspector. ELD felt that only the first issue was enforceable and then only based on a preponderance of the evidence. Based on further information submitted by f:r.PC at an enforcement conference, the NMPC organizational changes since the incident, and other programmatic improvements resulting from the 1984 CAT order, Region I recommended against escalated enforcement action.
An allegation was received in May 1985 that neutron monitoring system cable had been damaged during pulling. Region I asked NMPC to review this issue through their Quality First Program (Q1P). NMPC's response indicated that the cable had been installed using a push (as opposed to pull) method.
Subsequent Region I review found that there had been no procedure for the push method. The push niethod also required cable pull.ing, however this was not monitored by QC. A demonstration of a worst case installation configuration showed that the installed cable was acceptable, but a violation was issued for failure to im-plement procedures.
The adequacy of the QIP investigation of this matter is still under 01 review.
Currently open allegations and actions to complete them are listed below.
Harassment of QA auditors involved in Audit 84-4; Enforcement letter in preparation.
Adequacy of Q1P review cf neutron monitoring system cable pulling i
concerns; OI report being reviewed in OI headquarters.
The following late allegations were received in October 1986 and are under j
regional review.
f Ability of control room ventilation system to maintain suitable environment for personnel and equipment; awaiting licensee response to Concerns.
Two main steam isolation valves failed local leak rate tests and records were altered to show the valves passed.
6.3 Unit 1 Allegations i
In July 1986 several allegations were received by both NRC and NMPC from I
an instrumentation and control (I&C) technician at Unit I which poten-tially implicated Unit 2 because of the common I&C management. The allegations involved installation of Local Power Range Monitor (LPRM) con-nectors of an unapproved design, replacement of LPRM connectors without
l^ a f
~
30 documentation or QC inspection, replacement of Intermediate Range Monitor (IRM) connectors without documentation or surveillance testing, improper local leak rate testing of a containment isolation /feedwater check valve, an inadequate leak test of the stack gas sampling. system, improper vibration testing on a control rod drive pump and harassment by his peers and super-vision for bringing issues to QA and the NRC.
Subsequently, the issues were presented to NMPC, an NMPC investigation was performed, management meetings between NMPC and Region I were held, l
and a special Region I diagnostic team inspection was conducted.
Based on these actions and subsequent interaction with NMPC, Region I concluded the following:
l Most of the allegations are factually correct.
The safety aspects of the allegations wsre minor and have been re-solved by either prior NMPC action or subsequent-evaluation.
There are no direct implications of Unit 2 hardware, prograns, or personnel.
Programmatic weaknesses exist in the NMPC management system in that
.some problems are not brought to the proper level of management for resolution, root causes of problems are not routinely icentified, and the QA organization is not effectively used to find problems.
The harassment allegation was addressed by the licensee and remains under regional and OI review.
Notices of. violations are being issued to NMpC for those parts of the al-legations where regulations were violated.
Further, Region I plans to closely monitor the ongoing NMPC corrective actions concerning the indi-cated programmatic weaknesses.
6.4 Quality First prooram In 1983 NMPC established an allegation clearinghouse program identified as the Quality First Program (01P). The 01P program includes exit inter-views, a toll-free telephone line to receive concerns, and feedback to the concerned employee after the investigation is completed.
The adequacy of Q1P has been closely reviewed by Region I due to allega-tions that concerns were not properly handled when reported to the Q1P office. A Region I team inspection of the Q1P was performed on January 27, 1986. The inspection scope included a review of identified concerns, interviews of Q1P personnel, review of concern resolutions, examination of related site procedures and hardware, and interviews of site personnel not affiliated with the Quality First Program. The resolution of safety re-lated concerns was found satisfactory. Some program weaknesses were iden-tified in the area of handling of wrongdoing issues and the level of the
. ~..
- l 31 l
L
~ Quality First' documentation to substantiate concern closure. A subsequent i
followup inspection. conducted in June 1986 indicated improvements in these weak areas.
6.5' Allegation and Investigation Summary'and Conclusions The most.significant allegations at Nine Mile Point Unit 2 have' involved L
quality concerns and harassment of those raising such concerns.
In an i
attempt to identify and deal with these issues NMPC developed their Q1P program in late 1983. While this program appears to be working adequately l
based in Region I reviews, its integrity has been questioned several times by allegers.' However, most of these concerns seem to be more ir.dicative of poor employee relations and communications rather than poor quality hardware.
~
e
7' t
32 7.0 FUTURE REGION I ACTIONS Three resident inspectors are currently assigned to.-the Nine Mile Point site.. Region I resident ~and specialist inspections will continue through-out the startup test program. Results evaluation will be closely monitored.
A Readiness Assessment Team inspection is currently planned during the low power portion of the power ascension test program.
A team inspection of the Post Accident Sampling System and related TMI Task Action Plan post-accident monitoring issues is' planned during low power testing.
A plan'is being developed to closely monitor the progress of the NMPC cor-rective action program resulting from recent reviews of the Unit 1 I&C technician's allegations and the QA program concerns brought to Q1P.
p.
f.--;.y
, -[
_y.
- o. --
33
~8.0'
SUMMARY
AND CONCLUSIONS-Region I has expended over 12,000-inspection hours at the' Nine Mile Point Unit 2. facility and has determined that the project has been adequately managed while under close NRC scrutiny. Early in the project few problems were identified.' Beginning in 1981 and continuing through the CAT inspec-tion in late -1983, significant weaknesses were' identified in control over contractors and quality assurance, which resulted in both hardware and management deficiencies.
As a result, two civil penalties and an order were. issued. Consequently, experienced project construction and quality assurance management were brought in to correct deficiencies' and complete construction. Under continued close Region I scrutiny in the form of an Augmented Inspection Program, which continued to identify and ensure cor-rection'of deficiencies, the new management organization was verified as able to complete the construction of the facility with acceptable' quality.
Although it developed and progressed very slowly, and early procedure re-views sometimes indicated'an' inadequate incorporation of licensing crite-ria, the preoperational, test program was ultimately well executed and results indicated few test exceptions..In addition, surveillance test procedures have been completed after system turnover and prior.to declar-ing_ systems operational in most cases.
At this time the remaining open issue that would prevent reactor opera-tion at Nine Mile Point-Unit 2 is the resolution of problems with the Main Steam Isolation Valves. Prior to initial criticality the deficien-cies associated with the MSIVs must be resolved, and the valves must be satisfactorily. tested. On the basis that the license meets such a condi-tion, we believe it is acceptable to issue the low power operating license at this time.
We therefore conclude that Nine Mile Point Unit 2 has been constructed substantially in accordance with Construction Permit CPPR-112, the FSAR, and NRC requirements. We further conclude that NMPC has taken all neces-sary actions to permit initial license issuance subject to conditions of the license.
l l
3
r-
-a c
- a 4 -._
r*;
7 p'-
1.
l ENCLOSURE 1 NINE MILE POINT UNIT 2 INSPECTION
SUMMARY
INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE No. OF INSPECTdRS 72-01 Initial management meeting None None 4/10/72 2
-None 7/28-8/24/72 1.
.6/14/73 2
73-02 QA Program None None 7/19-10/9/73 1- 01 QA Program 6 UNR None 9/26-9/27/74 1
75-01 QA Program None None 4/16-4/17/75 2
75-02 Excavation progress, engi-2 UNR None 7/9-7/10/75 neering review / approval 1
program, review of construc-tion procedures 75-03 Environmental protection None None 7/29-8/1/75 program
,1
g' >-: 1*
,I...-
l o
2
- INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE NO. OF INSPECTORS 175 Site preparation activities 2 UNR None 10/21-10/22/75' and' procedure review 2
76-01 Specification. review, review 2 UNR Infraction:
2/24-2/26/75 of audits,. material storage,
' Requisite QA 2
corrective action controls, requirements review of project manual not in speci-fication.
- Infraction:
Specification review not.
performed'in accordance with proce--
dures.
Deficiency:
Audit findings not properly documented.
76-02 Blasting records, OA proce-4 UNR.
None 4/12-4/14/76 dures for concrete and foun-2 dations, site preparation, groundwater control 76-03 Site preparation excavation 3 UNR None 5/25-5/27/76 mapping, design review 2
meetings, porous concrete foundation drainage system, batch plant qualification, concrete mixes 76-04 Concrete activities, batch None Infraction:
1 7/19-7/21/76 plant operation Inadequate
'l cadweld in-spections 76-05 Environmental protection i UNR None 8/16-8/20/76 activities 1
L - - _ -
1
~ ::..
1 e'I L
1 3
-Enclosure l' i
INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE NO. OF INSPECTORS 76-06 Foundation backfill opera-3 UNR Infraction:
-?
9/28-9/30/76:
tions, site preparation Concrete curing 1
inspections.
not performed:
76-07 Site preparation and founda-1 UNR Infraction:
- 11/16-11/18/76 tion records, QC personnel 1
q' qualification, batch plant operation 77-01 Containment base mat concrete, None None 3/22-3/24/77 geologic investigation on 1
rock stress 77-02 Containment reinforcing' steel 2 UNR None 4/5-4/7/77 cadwelding, QA Manual review 2
for containment liner contractor 77-03 Containment steel liner in-None None
. 4/14/77 sta11ation, geologic investi-1 gation review l
Containment structural steel, 2 UNR None l
77-04 5/2-5/5/77 containment concrete proce-2 dures, containment base mat concrete activities, noncon-formance program review l
77-05 Containment base mat concrete, 1 IFI None 5/17-5/19/77 containment _ liner welding 77-06 Containment base mat concrete, 3 UNR None 6/8-6/10/77 containment structural steel I
welding, component storage, reinforcing steel erection 07 Containment base mat concrete None None 6/15/77.
2 77-08 Primary containment steel None None 7/18-7/20/77 liner welding, control of weld I
material, weld inspection f
a
4 INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE NO. OF INSPECTORS 77-09 Environmental protection None Infraction:
8/3-8/5/77' program Settling pond 1
operation procedures not followed.
77-10 Component storage and main-1 UNR Deficiency:
8/23-8/25/77 tenance, containment basemat Failure to-2 concrete records perform proper
- preventive maintenance on recirculation pump motors.
77-11 QA record review for concrete 1 IFI Infraction:
10/11-10/13/77 basemat concrete Failure to 3
follow procedures for l
batch plan uniformity tests.
Infraction:
Failure to document and report corrective actions to management relative to I&E Bulletins &
Circulars.
77-12 Installation and welding of 1 UNR None 11/15-11/17/77 containment liner 2
78-01 Measuring and test equip-None None 1/31-2/2/78 ment nondestructive weld 1
examination 78-02 Reinforcing bar installa-None None 3/28-3/31/78 tion, I&E Bulletins and 1
Circulars L
____.___._m_
M-u ~:
- 5
~
INSPECTION NUMBER.
~ AREAS INSPECTED
- FINDINGS VIOLATIONS.
INSPECTION DATE NO. OF INSPECTORS-
- 78 Piping and. supports.in-None None 4/24-4/26/78 sta11ation, penetrations, 13 geotechnical. review 78-04 Equipment storage, sur.
None None 5/15-5/18/78.
'veillances, concrete activities
- 2 78-05 Cable tray support' records None None 6/14/78 1-78-06' Mechanical equipment in.
1 UNR None 7/25-7/27/78 sta11ation, equipment main-
'l
-tenance, I&E Bulletins and Circulars78-071 Risk release program equip-1 UNR None 9/26-9/28/78 ment installation documentation
- 1 78-08 Management controls 2 UNR None y
9/25-9/29/78 1
78-09 Concrete activities, equip-1 UNR None 10/30-11/2/78 ment installation 1
79-01 Structural steel erection, 2 UNR None 1/8-1/11/79 cadweld operations.
1 79-02 Containment liner welding, None Infraction:
3/20-3/23/79 structural steel erection, Required 2
stud welding, equipment storage radio-graphy exami-nation not performed.
79-03 Reinforcing bar, concrete 1 UNR None 4/24-4/26/79 activities, backfill operation 1
- w e
i 6-INSPECTION' NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE 4
.NO. OF INSPECTORS l
79-04 Containment liner installation, None None
.7/10-7/12/79-piping, structural steel erection 1
79-05 Structural ~ steel erection, None Infraction: No 5/14-5/17/79 containment liner installa-procedure for 1
tion ultrasonic examination.
79-06 Concrete activities, rein-1 UNR None 8/27-8/31/79 forcing bar storage, elec-1 IFI 1-trical installation 79-07.
Suppression pool downcomers, 4 UNR None 10/9-10/12/79 electrical activities 1 IFI 2
79-08 Reactor pressure vessel None None 11/6-11/8/79 transport / rigging / lifting 1
79-09 Containment liner welding, 1 UNR None-11/28-11/30/79 equipment rigging, valve
.2 installation 80-01 Equipment maintenance and 1 UNR Infraction:
1/9-11/11/80 storage Invalid 1
preventive maintenance records.
80-02' Reactor pressure vessel None None 3/19-3/21/80 storage, biological shield
& 4/10-4/11/80 wall installation 3
80-03 Plant tours None None 4/24/80 2
80-04 Repair of biological shield 2 UNR None 5/12-5/15/80 wall welds 2
i 5
l
t v'l 4 _
7 INSPECTION NUMBER AREAS INSPECTED FINDINGS -
VIOLATIONS E
- INSPECTION DATE NO. OF INSPECTORS 80-05 Containment reinforcing bar.
2 UNR' None 6/17-6/19/80
-cadweld operations 1
80-06 Reactor pressure vessel None None
- 7/14-7/18/80 storage and placement 1
80-07 QA procedure review, review 1 UNR None 7/15-7/18/80 of engineering design changes, 2
nonconformance report disposition, trend analysis, audit program 80-08 _
Reactor pressure vessel placement None None 8/4-8/8/80 2
80-09 QC record review, reactor 1 UNR None 9/9-9/11/80 pressure vessel storage, 1
.CR0 hydraulic control unit storage 80-10 QA program review None None
- 9/23-9/26/80 1
80-11 Concrete record documenta-None Infraction:
10/21-10/23/80 tion review Inadequate-
& 11/4-11/6/80 document I
control of engineering changes.
81-01 Concrete placement, rein-1 UNR None-1/20-1/23/81 forcing bar cadwelds, engi-1 neering change document review
~ 81-02 Environmental protection None None 2/18-2/25/81 program 1
81-03 Plant tour, cadweld None None 4/21-4/23/81 operations 1
l L
, r-4
?;
,o f,
8 1
' INSPECTION NUMBER AREAS' INSPECTED-FINDINGS VIOLATIONS INSPECTION DATE
' NO. OF INSPECTORS
' 81-04'.
SALP management meeting None None 4/22/81 2
81-05 Primary containment liner, 3 UNR None
.6/23-6/25/81 equipment storage, house-I keeping 81-06 I&E Bulletin and Circular None~
None 7/14-7/16/81 review 1
81-07 Electrical procedure review, 1 UNR
-Violation:
7/27-7/31/81 installed raceway, geologic Pump motor 2
fault study review, primary electrical containment concrete test data not submitted to engineer-ing.
81-08 QA program personnel None None 8/4-8/6/81 certifications, licensee I
audits 82-09 Primary containment record 1 UNR None 8/18-8/21/81 review, biological shield 3
wall welding, weld filler metal control, pipe welding 81-10 Plant tour, concrete aggre-1 UNR None 9/1-9/V81 gates, corrective action 2
programs 81-11 Plant tour, review of QA None None 9/29-9/30/81 organization 3
81-12 Containment penetrations, 1 UNR Violation:
10/13-11/13/81 piping and structural steel 1 IFI Incorrect 1
erection date sheet.
Violation:
Inadequate corrective
- actions, i
1
4
]
9 INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE NO. OF INSPECT 0ks 81-13 Region I CAT inspection, 1 UNP Violation:
11/30-12/18/81 welding, nondestructive Ineffective QA 5
examination, electrical, program.
structural, procurement Violation:
Lack of design control.
Violation:
Inadequate equipment
' qualifica-tion.
81-14 Structural steel erection, 1 UNR Violation:
12/21/81-1/15/82 piping activities, welder 1 IFI failure to qualification implement checklists.
82-01 Pipe whip restraints, 3 UNR Violation:
1/18-2/26/82 structural steel, welder Inadequate QC 1
qualification, nondestruc-personnel tive examination, piping, training.
procurement Violation:
Failure to follow instruc-tions.
82-02 Pipe supports, RPV nozzle 3 UNR Violation:
3/1-3/26/82 modifications, structural failure to 1
steel, receipt inspection, record data nondestructive examinations, properly.
piping 82-03 Structural steel, cadwelding, 4 UNR Violation:
3/29-4/30/82 expansion anchors, piping, 4 IFI Failure to 1
equipment, design control correctly translate design informa-tion.
Violation:
Failure to impose QA requirement on purchase orders.
I
'lp;, -
p 72 [
10' -
INSPECTION NUMBER-AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE WO. OF INSFECTORS 82-04' Electrical components 3 UNR None 5/11-5/13/82 1
82-05 F1 ping, HVAC installation, 1 IFI-None 5/10-6/3/82 structural steel 1
82+06 Enforcement conference on None None 6/1/82-ITT Class I weld procedure
~
4.
82-07 Piping, rigging, mechanical 1 UNR Violation:
6/21-7/23/82 equipment storage, structural 4 IFI Inadequate I
steel control of rigging operations.
Violation:
Failure to identify a nonconforming condition 82-08 Meeting on ITT welding None Violation:
7/16/82.
procedures Failure to
.5
. control weld-ing processes.
82-09 Management controls 1 UNR None 7/13-7/16/82 &
7/20/82 2
82-10 Concrete testing, concrete 2 UNR Violation:
7/26-8/27/82 expansion anchors, piping, Underlength I
reactor head cavity, pit, welds on review of engineering design cable tray changes braces.
Violation:
Aggregate material not properly tested.
~.1 11 Enclosure l'
'3.
INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS ~
INSPECTION DATE NO. OF INSPECTORS 82-10(Cont).
Violation:
Inadeqate inspection of concrete expansion anchors.
82-11 Mechanical equipment erection, 4 UNR Violation:
~8/30-9/30/82 piping diesel generator build-2 IFI
~
work per-2 ing, weld rod control, welder formed with.
qualification, pipe supports, out' planner raceway package.
Violation:
Weld filler material not properly stored.
82-12 Small bore piping, instrumen-2 UNR Violation:
10/12-11/12/82.
tation, structural steel, re-2 IFI ASME piping I
circulation pipe welds, non-planner conformance reports package not properly reviewed.
82-13 Enforcement conference re-None None 10/20/82 garding use of trainees to I
conduct inspection 82-14 High strength bc1 ting, elec-1 UNR Violation:
31/15-12/22/82 trical support welds, struc-2 IFI high 1
tural steel welding qualifi-strength cations, measuring and test boits not equipment inspected per AISC.
Violation:
Weld material requisition improperly filled out.
Violation:
Improper concrete anchor bolt l
installa-tions.
L N
y
- f 12 INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE NO. OF INSPECTORS 82-15 Bic1hield wall fill material None Ncne 12/13-12/17/82 placement, reactor building I
concrete activities 82-26 E:quipment storage, raceway 2 UNR None 12/14-12/16/82 installation I
83-01 Instrumentation, pipe whip 4 UNR Violation:
1/3-2/4/83 restraints, engineering 7 IFI procedures 2
change documents, pipe not available supports, piping, cables to welders.
83-02 Safety related equipment, 3 UNR Violation:
2/7-3/11/83 concrete installation, cables, 2 IFI Planner 1
structural welding, piping package adhered to for pipe installation activities.
83-03 Electrical equipment storage 5 UNR None 3/1-3/3/83 raceway installation 1
83-04 Piping, licensee surveillance 2 UNR None 3/14-4/15/83 and audits, instrumentation 1 IFI 1
supports, structural steel, HWAC duct 83-05 Recirculation pipirg, con-1 UNR Violation:
4/25-5/27/85 tainment liner, procurement, 4 IFI Inadequate 2
corrective action, instru-trend mentation supports, piping
- analysis, and pipe supports Violation:
Underlength fillet welds.
83-06 QA record review, design veri-2 UNR Violation:
5/16-6/1/83 fication procedures, as-Inconsistent l
1 built plant verification FSAR diesel generator load sequen-
- cing, j
l
~
if 13
' INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE NO. OF INSPECTORS.
83-07 Pipe supports, piping, struc-3 UNR None 6/13-6/17/83 &
tural steel, weld filler.
3 IFI 7/13-8/5/83 material control, cable and I
equipment installation-83-08 Switchgear installation and 3 UNR Violation:
6/7-6/9/83 instrumentation Deficient I
vendor wiring on electrical
~
equipment.
83-09 Management meeting regarding -None None 5/23/83 licensee overview of contrac-1 ter performance 83-10 Corrective action programs, 2 UNR None 7/25-7/29/83 piping and plant housekeeping i IFI 2
83-11 Cables, raceway, motor. con-1 UNR None 8/2-8/4/83 trol centers, electrical QA 1 IFI 1
records 83-12 Preventive maintenance, pipe 5 UNR Violation:
8/8-9/21/83 supports, cables, concrete 5 IFI Installed 2
placement, recirculation cable not piping nozzle modification properly inspected.
Deviation:
Inspection holdpoints not specified in QC inspec-tion plans.
83-13 Environmental protection None None 9/14/83 program 2
83-14 Enforcement conference on None None 8/30/83 licensee overview and I
investigations of the piping contractor
r-L f;
14 l
INSPECTION-NUMBER AREAS INSPECTED FINDINGS VIOLATIONS E
INSPECTION DATE NO. OF INSPECTORS 83-15 Electric'al cables, motor 1 UNR None 10/18-10/20/83 control centers and QA 1
records 83-16 Equipment turnover,' piping, 6 UNR Violation:
10/1-12/2/83/84 pipe supports, reactor build-2 IFI Nonconforming 2
ing enclosure, CRD piping, welds accepted fire protection, instruments-by quality tion QA program control.
83-17 RPV storage, hydraulic con-4 UNR None 12/5/83-1/20/84 trol unit installation, 5 IFI 2
piping, pipe supports, j
welder qualification, HVAC systems 83-18 I&E CAT Inspection 91 IFI Violation:
11/7-11/19/83
. Inadequate
& 11/28-12/9/83 review of 7
design change documents, inadequate review of radiography film, defic-ient' inspection procedures, nonconforming pipe supports, electrical separation violations, inadequate inspection documentation, inadequate weld filler metal control, Deficient NDE weld surface exams, non-conforming conditions not identified on NCRs.
j l
)
l lt:
s.
H 15 INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE g
-NO. OF INSPECT 3RS 84-01 Pipe. supports, diesel gen-4 UNR Violation:
1/23-3/2/84 erator cranes, reactor 1 IFI Nonconforming 2
vessel internals, QA program pipe supports.
Violation:
Failure.
to follow procedure for handling of-significant.
. deficiency.
84-02 Cables, switchgear and QA 5 UNR Violation:
2/7-2/9/84 records Wrong,non-I conformance-form in use.
.84-03 Management meeting on None None 2/22/84-licensee corrective actions 1
for CAT-findings i
84 Concrete anchor bolts and None None 3/12-3/16/84 and structural steel l'
welding 84-05 Electrical terminations, 3 UNR Violation:
3/5-4/7/84 piping, pipe supports, OA 1 IFI Inadequate I
surveillance, contractor design control audits, design control for Seismic II/I items.
84-06 Structural steel, weld 2 UNR V1olation:
4/9-5/11/84 material control, pipe 2 IFI Weld filler 2
supports, housekeeping, not control-post inspection rework led.
control Violation; Rework to structural beams not controlled.
Violation:
Inadequate inspection of bolting and pipe supports.
l
l:
p
. =~
) l,?
16 -
INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE NO. OF INSPECTORS
.. 06(Cont.)
Violation:
l-m Lack of inspection
. status for structural steel.
Violation:
Inadequate plant house-keeping.
84-07 Large and Small bore pipe None-None 5/14-5/18/84 supports 1
84-08 NDE van inspection of ASME 3 UNR Violation:
L 4/30-5/25/83
'and structural weldments by film indica-3 independent exam.ination tion evaluated /
' documented.-
Violation:
Inadequate review of RT film.
Violation:
Minimum wall violation.
84-09 Corrective action programs, I UNR Violation:
5/14-6/15/84 electrical penetrations, pipe 4 IFI trends not 2
whip restraints, component detected by supports analysis.
Violation:
Penetration NDE not per-o formed.
84-10 Pre-operational security 25 IFI None 5/21-5/24/84 inspection 2
b
~
r s
17 INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE NO. OF INSPECTORS 84-11 Document control, contain-S UN.T Violation:
6/18-7/27/74 ment supports, design change 2 IFI Hold points 3
control, plant stack, battery violated installation, equipment pre-during pipe ventive maintenance whip restraint installation.
Violation:
Inadequate review of design change documents.
84-12 Cancelled 84-13 Design change control, re-4 UNR Violation:
7/30-9/6/84 vetment ditch, pre-op per-Inadequate 1
sonnel qualifications, hydro-thread tests, preventive maintenance, engagement standy liquid control system, of strainer weld filler metal control top bolts.
Violation:
Field issued weld filler metal not controlled.
84-14 Welde qualifications, weld-4 UNR None 8/20-8/24/84 ing, welding records 1
84-15 Electrical cable separation, 6 UNR None 9/10-11/2/84 containment penetrations, 3 IFI 3
diesel generator modifica-tions 84-16 Radiological control None None 10/29-11/2/84 staffing 1
84-17 Safety related equipment in-1 UNR None 10/29-11/2/84 stallation, inspection of 1
equipment, preventive maintenance J
7 c.
.18 INSPECTION NUMBER-AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE l.
NO. OF INSPECTORS 84-18 Region I CTI, QA, project.
2 UNR Violation:
l 12/3-12/14/84 management, mechanical, elec-5 IFI Failure to 9
trical, instrumentation, execute design control & welding adequate PM program.
Violation:
Undersized weldments on instrument
- support stand.
84-19 MSIV cladding,' instrument 2 IFI Violation:
11/5-12/21/84 tubing, small bore supports, to perform 2
concrete expansion anchors adequate'QC inspections on supports.
Violation:
Lack of effective corrective action implementa-tion.
84-20 Management meeting to None None 11/14/84 discuss CAT corrective actions 84-21 Concrete expansion anchors, 3 UNR Violation:
12/24/84-1/1/85 design control, HVAC supports 3 IFI Inadequate PSI, QA corrective action HVAC support systems inspection.
Violation:
Failure to translate FSAR QA commitments to site design docu-ments.
-m
+
9 '
l
- 19.
N
. INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS L
' INSPECTION DATE NO. OF INSPECTORS 1
85-01 Preoperational test program None None 1/15-1/18/85 and procedure review 2-l 85-02 Review of Johnson Controls None None 1/28-2/1/85 and Reactor Controls welder 1
qualification and welding operations.
85-03 Instrumentation, electrical, 2 UNR
- Violation:
2/11-2/15/85 HVAC, and preventive main-Inadequate 3
tenance HVAC baseplate installation.
Violation:
Inadequate i
PM for inplant elec-trical items.
85-04 FSAR verification, electrical None None 2/4-3/18/85 equipment wiring, ACRS 2
hearing participation 85-05 Management meeting to None None 2/6/85 discuss CAT enforcement corrective actions.
85-06 QA/QC for system turnover 4 UNR None 3/4-3/8/85 control, pipe supports, CRD 3
piping 85-07 Cancelled 85-08 Electrical equipment install-None None 3/18-3/22/85 ation, electrical QC records, 3
instrumentation components 85-09 Management meeting to discuss None None 2/27 & 3/16/85 conduct of Engineering Assur-ance audit and as-built veri-fication of RCIC system
ll 1:.~
(
20 INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE ND. OF INSPECTORS 85-10 Reactor coolant system hydro 2 UNR Violation:
l 3/19-4/26/85 test, spent fuel racks, r.itro-Improper 5
gen inerting system,'allega-concrete tions, QPMP expansion bolt instal-lation.
85-11 Reactor coolant system hydro 1 UNR None 1
4/2-4/4/85 &
test l-4/9-4/12/85 L
2 85-12 Cable pull tension calcula-None None 5/6-5/10/85 tions and open items 1
85-13 EA audit. QPMP, diesel ex-4 UNR None 4/29-6/7/85 haust system, CRD bydrotest, 2 IFI 3
instrument tubing and supports, MSIV testing, pipe supports, allegations, SU-QA records, battery preoperational test procedure, CRD installation 85-14 Review of EA audit plan numerous None 4/22-4/23/85 comments 7
85-15 Operator licensing exams None-None 6/11-6/19/85 2
85-16 Preservice inspection None None 5/28-5/31/85 activities 1
85-17 Open Items review None None 6/10-6/14/85 1
85-18 Review of EA program plan 28 None 5/21-5/24/85 implementation items 6
85-19 RPV internals, flood control 2 UNR None 6/10-7/19/85 berm, QA activities, 3 IFI 2
QPMP, preliminary testing i
l
P h
21
'I INSPECTION NUMBER AREAS INSPECTED ~
FINDINGS VIOLATI'ONS INSPECTION DATE-NO. OF INSPECTORS 85-20 Preoperational radiological 1 UNR None 6/24-6/28/85 controls, preop testing rad-8 IFI 3
waste systems, HVAC material control q
l 85-21 Management meeting to discuss None None 6/17/85 licensee reinspection of 3
1arge bore pipe supports l
85-22 Cancelled 85-23 Preservice inspection program 1 IFI None i
7/16-7/19/85 and examination data
]
~85-24 HVAC duct supports and open None None j
7/22-7/26/85 item review i
1 j
85-25 Piping and supports, hydro-2 UNR None 7/22-8/30/85 static testing, diesel gen-2 IFI 2
erator testing, RPV internals QPMP 85-26 Management meeting to discuss None None 7/23/85 licensee hardware verifica-tion, FSAR verification, and electrical separation 85-27 QPMP, local leak rate testing 1 UNR None 9/9-10/18/85 ing, pipe welds, HPCS walk-down, 2 IFI 5
PM program, preoperational procedures, QA Audits.
85-28 Review of EA audit results 23 OI's None 8/12-8/16/85 and corrective actions 85-29 ASME C1.1 weld impact test 1 UNR None 9/30-10/4/85 data, bioshield wall weld-1 ments, pre-and postweld heat treatment, welder quali-fication, QC records
]
- 22.
INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS
-!NSPECTION DATE NO. OF INSPECTORS 85-30 Preoperational test program 1 UNR None 9/9-9/13/85 implementation, QA/QC inter-1 face with test program 85-31 Review of licensee large 1 UNR None 10/7-10/11/85 bore pipe support verification, 2
as-built pipe stress reconciliation program 85-32 Rad Controls program, fuel 9 IFI None 10/14-10/18/85 receipt planning, preopera-1 tional testing of radwaste systems, HVAC, shield survey program 85-33 Review of REV hydrotest None None 10/21-10/25/85 results and open item review I
85-34 Fire protection review, safe 7 UNR None 10/21-10/25/85 shutdown capability, emergency 3
lighting system 85-35 Electrical equipment install-None None 10/28-11/1/85 ation 1
85-36 Allegation, QPMP, preopera-None Violation:
10/21-11/26/85 tional testing, preliminary Undersized 3
testing, electrical equipment, bolting walkdown hardware in preoperational j
preparedness, RCIC mote shutdown l
panel 1
85-37 Training program review for 1 IFI None
-10/28-11/1/85 licensed operators and tech-5 nical training for mechanics, electricians, and I&C technicians.
_m.________._____
c
~
23 I
INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE NO. OF INSPECTORS 85-38.
Security plan implementation None None 10/28-11/1/85 for fuel receipt, preopera-1 tional security program 85-39 Cancelled 85-40 Nuclear material control None None 11/25-11/27/85 and accounting, shipping I
receiving, materials control system 85-42 Neutron monitoring system 1 UNR Violation:
11/12-11/15/85 installation Coaxial cable 1
installed w/o procedure.
Violation:
Minimum cable bend radius violated.
85-43 NDE van inspection of ASME None None 12/9-12/19/85 piping weldments 3
85-44 Allegation followup, fuel 1 IFI None 12/2/85-1/10/86 receipt, preoperational 4
testing, information notices.
85-45 Fire protection program I UNR None 12/9-12/10/85 for fuel receipt 1
85-46 Preservice inspection 1 UNR None 12/9-12/12/85 activities 1
85-47 Radiological controls 3 IFI None 12/16-12/20/85 program, fuel receipt, pre-1 operational testing 86-01 IEB's, allegations, refuel-2 UNR Violation:
1/13-2/21/86 ing floor contamination, pre-Inadequate 5
operational testing, pre-preopera-operational service inspection tional test CRD removal rework control.
procedure acceptance criteria.
7p.li s -
E4 -
N
]
24 INSPECTION NUMBER AREAS INSPECTED' FINDINGS VI0l.ATIONS INSPECTION DATE NO. 0F INSPECTORS.
86-02' Tech Spec review 4 IFI None 1/6-1/17/86 3L
- 86-03 Preop test' procedures &'
'1 UNR ~
None 1/21-1/24/86 test conduct 1
86-04 Implementation of Q1P None None 1/27-1/31/86 5
86-05 Preep test, interim surveillance None None 3/3-3/7/86-preliminary test procedure review 1:
86 Management meeting:
None None 1/22/86 Construct 1on completion, preoperational test status and operational readiness.
86-07' Inspection of Engineering None None.
1/3 and 1/7/86
' Assurance audit'results'and corrective actions 86-08 Instrumentation components 1 UNR Violation:
3/3-3/7/86 and cables Unaccept-able Cable separation.
Violation:
Use of uncontrolled drawing.
Violation:
Damage to instrument tubing.
Violation:
EQ cable l
connector integrity lacking.
e 25
)
INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE-NO. OF INSPECTORS 86-09 Structural integrity test, 45 IFI Violation:
2/22-4/18/86 raceway installation, pre-1 UNR Improper q
4 operational test procedure, design 1
preoperational test witness control for and TMI action plan items.
class IE cable routing.
86-11 Readiness implementation of 2 UNR None 3/31-4/4/86 operational QA program, 3
Audits. QA/QC surveillance, M&TE, nonlicensed training, safety review committee.
86-12 Radiological controls, 1 IFI None 3/24-3/28/86 training, exposure control, 2
ALARA, control of contaminated material.
86-14
- Preoperational test program None None 3/31-4/4/86 procedure review and test I
witnessing.
86-15 Preoperational testing, None None 4/7-4/11 and operational readiness, 4/21-4/25/86 administrative procedures, 3
operations procedures, design changes, and modifications.
85-16 Integrated Leak Rate Test 1 UNR None 4/7-4/15/86 (ILRT) and Structural 1
Integrity Test (SIT).
86-17 Radiochemistry, liquid and 3 IFI None 4/28-5/1/86 gaseous radwaste, effluent j
2 radiation monitors, procedures, training and qualification.
86-18 TMI action plan items, 4 IFI None 4/19-5/31/86 generic letters, preopera-8 tional test procedures, pre-operational test witness, and preoperational test results.
p
/y 26 INSPECTION NUMBER AREAS INSPECTED FINDINGS: VIOLATIONS
[
INSPECTION DATE NO. OF INSPECTORS 86-19 Radiological controls inspec-None None 5/19-23/86-tion covering the Preop Test 2
program and. licensee action on previous findings.
86-20 Preoperational test proce-1 UNR None 5/5-5/9/86 dures, test witnessing, test 2
results review, power ascension test program and QA/
QC interfaces.
86-21 Fire protection / prevention None None 5/12-5/15/86 program readiness, admini-2 strative controls, training, QA audits.
86-22 Procurement, receipt, storage 1 UNR None 4/30-5/9/86
& handling document, records 2
management programs, and licensee actions on previous inspection findings.
86-23 Emergency preparedness 13 IFI None 5/19-22/86 implementation appraisal, 5
including organization, admini-stration procedures, training, facilities, and equipment.
86-24.
Status of security program None None 5/12-16/86 testing and maintenance, 2
physical barriers, security system power supply, lighting, licensee action on NRC in circulars, bulletins and inspection follow-ups.
86-26 TMI action plan items, main-None None 5/20-23/86 tenance organization, main-2 tenance staffing, proper QA/
QC interfaces, and emergency operating procedures.
86-27 Preoperational test program, 1 UNR None 5/19-5/23/86 test witnessing, test I
results evaluation.
l I
l
s
]
27 INSPECTION NUMBER AREAS INSPECTED FINDINGS VIOLATIONS INSPECTION DATE NO. OF INSPECTORS 86 Inspection of licensee None Hone 5/27-6/13/86 action or construction 2
deficiencies, IE Bulletins and Outstanding Items 86,-29 TMI action plan items, IE 5 IFI None 6/1-7/6/86 Bulletins & Circulars, NRR 5
open items, QIP follow-up, preop test procedure review, test witnessing, and test result review.
86-30 Preop testing None None 6/2-6/6/86 1
86-31 Preop test program, prelim.
None None 6/16-6/27/86 test witnessing,-test review, l
2 QA/QC interface with preop test program.
86 Preservice inspection None None 6/23-25/86 program, review of 1
installation procedure, and QC inspection of bolted piping joints 86-33 Preop testing None None 6/30-7/11/86 2
86-34 Cperator licensing None None 7/21-9/21/86 4
86-35 Radiochemistry, liquid 1 IFI None 7/7-11/85 radwaste, and gaseous radwa ste 86-36 Operational readiness of 1 UNR None 7/7-11/86 of instrumentation and I
control maintenance program 86-37 Previous findings, instru-None None 7/14-8/15/86 mentation, electrical, 4
equipment qualification i
--m--~
y:;.._ _
1 e.;
.: 6
- 14-28 j.
INSPECTION NUMBER AREAS INSPECTED-FINDINGS-VIOLATIONS L
INSPECTION DATE l
NO. 0F INSPECTORS 86 Preop testing results &
2 IFI None 7/14-24/86
'startup program l
2 86-39 Resident Ins'pector None None 7/7-8/31/86 5
86-40' Physical security &
None None 7/28-8/2/86 safeguards 1
86-41 Startup program; surveillance None None 7/29-8/1/86 testing, ILRT
'2 86-42 Resident Inspector None None 9/1-9/30/86 5
86-43 IE Bulletins & previous None None 7/28-8/1/86-findings' 1
86-44 EP appraisal followup-None-None 8/4-6/86 3
86-45 Environmental monitoring None None 7/21-25/86 program 2
1 86-47 Tech. Spec. surveillance 8/4-8/8/86 program 1
1 j
i l
je d
ENCLOSURE 2 QUALITY ASSURANCE / QUALITY CONTROL
SUMMARY
A.
Much of the information presented within this enclosure was compiled by the applicant's Quality Assurance (QA) organization.
The data were extracted from NMPC QA report " Quality of Construction Report" dated March 10, 1986.
The information has not been verified for accuracy by Region I.
B.
A multi-tier quality program has been implemented during the construction phase at Nine Mile Unit 2.
First line Quality Control (QC) inspection responsibilities have been performed by. Stone and Webster Engineering Corporation (SWEC), ITT-Grinnell Inc.-(ITT), Johnson Controls Inc. (JCI) ar.d Reactor Controls, Inc. (RCI).
Each of those contractors also had an affiliated QA organization that performed audit, surveillance, and other QA functions.
SWEC site QA has performed surveillance of the sub-contractor efforts. SWEC QA audits have been performed by the Boston QA Auditing.
Department. The applicant has maintained a site QA organization that has performed both surveillance and audits of all contractors.
NMPC Audits and Surveillance NMPC has conducted over 180 audits and 8,800 surveillance of SWEC, GE, and the other site sub-contractors. A summary of the NMPC audits and surveillance is shown in the following tabulation:
AUDITS TOTAL YEAR OFF-SITE ON-SITE SURVEILLANCE FINDINGS 1972 1
0 0
20 1973 4
0 0
39 1974 10 0
0 20 1975 10 1
74 25 1976 6
3 302 58 1977 9
4 800 73 1978 7
4 673 65 1979 5
2 569 34 1980 9
5 359 40 1981 7
4 742 30 1982 7
9 822 54 1983 10 4
1959 94 1984 7
9 1570 263 1985 9
37 981 124 Total s 101 82 8851 939 As a result of the findings identified during the conduct of audits and surveillance, NMPC QA has exercised the authority to issue Stop Work Orders on nine occasions to cease werk activities to prevent degradation of the conduct of safety-related activities.
1 i
l _,4
. )
2 SWEC Audits SWEC has conducted audits of component suppliers, engineering activities, QA programs, construction activities and subcontractor activities.
SWEC Quality Assurance Aude.ing Division (QAAD) has performed' site, subcontractor, ASME and supplemental audits as summarized by the following:
No. of Audits
' Total Year Program Site Contractor ASME Supplement Findings 1975 1
1 53 1976 1
4-112 1977 1
4 3
112 1978 1
4 2
1 111 1979 1
4 4
1 120 1980 1
4 3
49 1981 1
4 2
66 1982 1
4 9
112 1993 1
4 10 4
77 1984 1
4 11 6
94 1985 1
4 9
4 77 Totals 11 41 53 6
10 983 Ten Stop Work Orders have been issued as a result of the deficiencies identified b'.
the QAAD audits.
SWEC Procurement Quality Assurance Division (PQAD) has performed supplier audits as summarized below:
SUPPLIER TOTAL YEAR AUDITS FINDINGS 1974 1
3 1975 0
0 1976 3
19 1977 12 106 1978 48 289 1979 40 241 1980 28 195 1981 31 229 1982 66 392 1983 44 280 1984 36 190 1985 28 101 Total 337 2045
- e I'
i'
]
3
. Enclosure 2
'SWEC Engineering Assurance (EA) has performed audits and surveillance to ensure that the' design control process has been adequately implemented. :The' EA activities are summarized below:
NUMBER NUMBER YEAR-0F AUDITS OF SURVEILLANCE 1972:
3 1973-10 1974-8 1975 8
1976 8-1977 8
1978 10
,1979' 10 1980 3
1981-1 2
1982 8
1 1983
-8 11 1984 7
19 1985 6
8 Total 98 41 ITT Audits ITT was the major piping subcontractor responsible for fabrication and installation of large bore and small bore piping and supports.
ITT performed audits of site and vendor activities as summarized:
SITE VENDOR AUDIT YEAR AUDITS AUDITS FINDINGS 1977 1
0 1978 1
2
'1979-4 18 1980 2
0 1981 2
1 1982 4
2 11 1983 4
2 13 1984 4
2 29 1985 4
4 8
Total 26 10 82
s...
,. N
'l 4.
ITT issued eight Stop Work-Orders as a result of deficiencies identified regarding the piping activities..
JCI Audits JCI was the' subcontractor responsible for the installation of instrument tubing, supports.and instruments. JCI performed the following audits:
-SITE CORP.
AUDIT YEAR-AUDITS AUDITS FINDINGS 1983 1
2 36 il 1984 l'
6
.46 1985 1
3 14' TOTAL 3
11 96 JCI issued six Stop Work Orders to halt specific activities until necessary corrective actions were implemented.
RCI Audits RCI was the. subcontractor responsible fer the design and installation of the CRD system and installation of reactor internals and recirculating water system piping. RCI performed the following audits:
SITE ENGR.
AUDIT YEAR AUDITS AUDITS FINDINGS i
1981 0
1 2.
1982 2
I 12 1983 3
1 3
1984 4
1 9
1985 2
1 6
TOTAL 11 5
32 Seven Stop Work Orders have been issued by RCI.
QC Inspections QC inspections have been performed by SWEC, ITT, JCI and RCI. The inspections were performed to inspection plans or checklists to verify conformance of hardware or acceptability of software. The SWEC inspections are summarized below:
., a L Re 7.' '
p 4 5
g RACEWAY ASME PROCUREMENT
. YEAR STRUCT REC ELEC MECH PGCC HANGERS S/8 INSTR QA 1975 321' 0
0 0
1976 3391 912 87 120 151 1977' 2937 2739 860 862 754 1978 5728 2535 985 1191 1379 1979 8213 2770 1840 1618 1589 1980-2500 1052.
194 786 965 1981 6188 1864 2324 903 1102 1982 11041 2801 5984 1471 1691 1983 10581 4067 3883 2602 2635 7584 180 2000 1984 5694 4462 7123 4495 3792 9904 3038 1906 1985-3293 4017 14577 3636 4180 8760 5097 315 1005
~
TOTAL 59887 27219 37857 17684 10607 26248 8315 315 12542 Total Procurement QA Inspection Reports thru 1985 = 12,542 Total Field QC Inspection Reports thru 1985
= 188,167 The subcontractor QC. organizations have generated the following Inspection Reports (irs) through 1985:
ITT - 74,106 irs JCI - 17,938 irs RCI 2,985 irs NONDESTRUCTIVE EXAMINATIONS (NDE)
Nondestructive examinations have been performed to verify through surface and volumetric examination that components and welds are in compliance with design requirements. SWEC has generated the following NOE reports:
RADIO-ULTRA-MAG LIQUID BUBBLE WELDER YEAR GRAPHY SONIC PARTICLE PENETRANT TEST QUALS.
1976 9
1977 72 1978 19 1979 197 127 191 1980 7
1981 x
161 72 1982 2925 317 52 231 1983 15 39 1137 860 22 734 1984 44 1161 3698 126 1529 1985 132 72 1372 4876 196 524 TOTAL 344 289 6756 9823 396 3309
- 6301 inches x 1676 inches
_ _ _ _ - - _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ - _ _ - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ -