ML20009G439

Responds to NRC 810423 Ltr Re Violations Noted in IE Insp Rept 50-423/81-02.Corrective Actions:Audit Schedule Reassessed & Revised & Audits Performed

ML20009G439
Person / Time
Site:	Millstone
Issue date:	07/01/1981
From:	Counsil W, Werner R NORTHEAST NUCLEAR ENERGY CO.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20009G434	List: ML20009G439
References
A01685, A1685, AEC-MP3-241, NUDOCS 8108040260
Download: ML20009G439 (15)

Text

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f ; Ol' [,J (203) 666-6911 k L J s ' ' " l 's July 1, 1981 Docket No. 50-423 AEC-MP3-241 A01685 U. S. Nuclear Regulatory Commission Mr. T. T. Martin, Acting Director Division of Engineering and Technical Inspection Region I Office of Inspection and Enforcement 631 Park Avenue King of Prussia, PA 19406

References:

(1) T. T. Martin letter to W. G. Counsil, dated April 23, 1981.

(2) W. G. Counsil letter to T. T. Martin, dated May 12, 1981.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 3 I&E Inspection No. 50-423/81-02 On January 26, 1981 through February 6,1981 and February 18, 1981, the NRC Office of Inspection and Enforcement conducted an inspection of Millstone Nuclear Power Station, Unit No. 3. As a result of that in-spection, Reference (1) was transmitted to us for response. That trans-mittal contains three (3) parts: Appendix A, Notice of Violation; Appendix B, Significant Observations; and IE Inspection Report No.

50-423/81-02. Because of the extent of your transmittal an extension to the due date was requested and granted, Reference (2).

Our responses to Appendices A and B are formated by first identifying the Appendix and then restating the particular Appendix Item. This is then followed with a response. Unresolved items mentioned within the inspection report but not specifically mentioned within Appendices A or B have been reviewed, and assignments have been or will be made to ensure corrective action is taken.

8108040260 810720 PDR ADOCK 05000423 o PDR

r In regards to Appendix A, Northeast Nuclear Energy Company has satisfied the provisions of 10CFR2.201 through the submittal of the attached Appendix A responses.

We trust the attached responses satisfactorily respond to the violations and observations cited by your inspection team.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY N f, [

ms) /CF /L m ., , u M W. G. Cotnsil Senior Vice President f '/ p ')

A .x i . cc ,

~~Ey: R. P. We'rner Vice President Generation Engineering and Construction cc: Mr. R. T. Carlson, Chief Reactor Construction and Engineering Support Branch Region 1 Office of Inspection and Eaforcement U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. Boyce H. Grier, Director Region I Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 l Mr. Harold D. Thornburg, Director l Division of Reactor Construction Inspection Office of Inspection and Enforcement

! U. S. Nuclear Regulatory Commission Washington, D.C. 20555 l Mr. J. C. Mattia, Resident NRC Inspector l Office of Inspection and Enforcement

! U. S. Nuclear Regulatory Commission l

P. O. Box 128 l Waterford, CT 06385 i

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r STATE OF CONNECTICUT )

) ss. Berlin f / f[/

COUNTY OF HARTFORD ) #

Then personally appeared before me R. P. Werner, who being duly sworn, did state that he is Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.

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Appendix A A. On January 28, 1981, the inspector noted the following examples of the licensee's failure to audit applicable program elements:

No audits were performed during 1979 and 1980 of the con-tainment fabricator's welding process of the ASME piping erection; No audits were performed during 1979 of Stone and Webster field procurements; No audits were perf rmed during 1979 of the qualifications, training and certifico.lons of S&W Field QC personnel; and, The following audits have not been conducted per the procedural schedule requirements:

Audit Number NUSCO Scheduled Date A40545 6/30/80 (Not performed to-date)

A40552 8/31/80 (Not performed to-date)

A40528 3/31/80 (Performed on 8/14/80)

A40533 4/30/80 (Performed on 8/14/80)

A40511 10/31/80 (Performed on 5/15/80)

This is a Severity Level V Violation (Supplement II).

Response

The NUSCO Construction QA unit is performing the following:

l The present audit schedule will be reassessed and revised by June 30, 1981, to reflect the current work load for Millstone Unit No. 3.

Construction QA will schedule audits in the areas of work performance and in the areas listed in Appendix A and paragraph 2.a(1)(a) .

Status of specific audits:

a. Audit A40545 will be performed by August 1, 1981.

b. Audit A40552 was performed on April 13, 1981.

c. Audit A40571 (Criteria 1 & 2 - S&W Field QC Personnel) was performed on May 21, 1981.

d. Audit A40595 (changed from A40600) (S&W Field Procurement Activities) was performed on June 19, 1981, and future audits will continue on a regular basis.

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. l Construction QA will revies the audit schedules to assure audits are completed no later than 3 months beyond the schedule date or otherwise request rescheduling approval from the NUSCO Manager, Quality Assurance.

B. On February 5, 1981, the inspector noted that the heating, veat-ilation and air conditioning subcontractor was performing safety related work using its unapproved QA manual and procedures and no objective evidence of complying with applicable S&W procedures was available.

This is a Severity Level V Violation (Supplement II).

Response

Corrective Action The NEVC0 QA/QC program for site work had previously beca reviewed but evidence of the approval was not available. At the time of the inspection, NEVC0 was on S&W's list of approved suppliers. On February 5, 1981, a letter to Northeastern Ventilating Company from R. P. Bone, Lead Power Engineer, Stone and Webster, approving the (NEVCO) site QA/QC Program, was presented to Mr. Mattia, of the NRC.

S&W has also reviewed the status of all other subcontractors and has verified they are performing work to an S&W approved QA/QC Program.

NOTE: NEVCO's personnel numbered 12 manual and 2 nonmanual.

Stone & Webster Field Quality Control was performing continual daily surveillance of the NEVC0 operations.

Preventive Action S&W policy is that prior to subcontractors performing installation activities at the Millstone III site, formal approval of their QA Program is being required. As the situation with NEVC0 has been established to be an isolated case, no preventive action is deemed necessary.

C. On February 4, 1981, the inspector found that the licensee had not conducted annual management reviews in 1978 and 1979.

This is a Severity Level V Violation (Supplement II).

Response

It is recognized that the annual management assessment was not performed in 1978 and 1979. At that time a conscious but undocumented decision was made to forego the 1978 management review in recognition that, with the scheduled completion of the review of the Topical Report by the NRC (August 1978), the QA procedures would undergo drastic revision. The Topical Report was not approved by the NRC i until April, 1979, at which time the revision of procedures was initiated.

The 1979 assessment was postponed with the approval of Mr. W. G.

Counsil, in a memorandum dated January 12, 1979. This memo was presented to the NRC Inspectors at the time of the Inspection at Millstone Unit No. 3, to indicate recognition of the changes occurring in that time period. Recognizing the commitment a Management Review was performed in March,1980, and another completed the week of May 4-8, 1981. In both cases, the review was performed by a team of qualified auditors from other Utilities, acting as a Joint Utilities Audit Team.

In order to achieve the desired result of the Management Review, as described in the Topical Report and applicable Procedure NEO 1.06, the open items of both audits are being frilowed for implementation in a timely manner as well as the remaining items from the 1980 audit. Several of the open items have been closed since the Feb.

NRC inspection.

The observation that deficiencies identified in the 1977 audit were not being followed was true except for training, which was being followed in an informai manner. This has been corrected. The training deficiencies identifiec in the 1977 audit required extensive corporate commitment for resolution and, in fact, the whole purpose of the QA training audit conducted on Jan. 22, 1981, was directed at identifying the magnitude of the problem. As a direct result of the Jan. 22, 1981 audit an NEO Corporate Nuclear Policy statement was issued on March 23, 1981. The Training Program will be more clearly defined in implementing precedures relating to specific training.

NUSCO personnel performing functions and duties relating to Millstone Unit No. 3 will be trained within the procedures of the affected Departments. Retraining of personnel will be included as a part of the overall pregram- Additional related information is presented in response to item D4 of Appendix B (from 4(C)5 and 4(C)6.a).

D. As of January 28, 1981, the certifications of inspection personnel were issued prior to the actual evaluation and determination of the inspector's qualifications without sufficient supporting documentation by the inspector's supervisors. Adequate corrective action was taken during the inspection to correct this non-compliance and prevent recurrence.

Response

No response required.

E. As of January 30, 1981, Stone and Webster Specification 279 had eight E&DCRs issued against it. The sixth I&DCR was over two years old, the document had not been revised and/or reissued, and no objective evidence was available to show t;1at an extension had been granted.

This is a Severity Level V Violation (Supplement II).

Response

Corrective Action The outstanding E&DCRs against Specification 279 have been incor-porated by issue of Addendum 5 to this specification. This addendum was issued on June 18, 1981.

A comprehensive review of project specifications and drawings to identify any other document exceeding the stated time and number limit for E&DCR incorporation has been completed. All documents found to exceed the required incorporation limits as a' result of this review will be revised, or a specific extension will be authorized by the Project Engineer. These actions will be completed on or before December 31, 1981.

Preventive Action The Project has adopted a computerized system which identifies outstanding E&DCRs against each project specification and drawing.

This computer output is distributed monthly to Project Management and Lead Engineers. Furthermore, those specifications and drawings which accumulate six E&DCRs will be identified by the Planning Engineer and entered into the Project Network Schedule for revision within six months. If the E&DCRs are not incorporated in the six month period, the specification or drawings will be identified as having a revision behind schedule. Project action will be initiated to correct the delinquency.

F. The E&DCR #PS-2162, dated May 7, 1979, was not distributed and was not available to personnel who needed it for execution of work; consequently, Wall-G-7 in the ESF Building was not constructed according to design requirements specified in the E&DCR.

This is a Severity Level IV Violation (Supplement II).

Response

Corrective Action E&DCR PS-2162, which added structural steel embedment plates for platform framing, was not distributed to the construction forces because the documents it changed (Dwg. ES-31L & 31M) had not been issued. Since the drawings h.I not been issued, E&DCR PS-21o2 was maintained by Site Document Co crol to be issued with the drawing.

As a result, the C-7 wall was constructed to the existing dt-ign requirements as dctailed in the concrete drawings, which provided Richmond insert patterns in the wall for future attachments.

To accommodate structural steel platform connections to concrete, the design methods include embedding plates in concrete or attaching plates to the walls uFing Richmond inserts. The controlling method of design is determined by engineering based upon the construction and design schedules. The wall was constructed using Richmond

-5 inserts. The connection designs are now being finalized using I

Richmond inserts as the connecting mechanism. 'Serefore, the as-built condition of the G-7 wall, which includes the use of Richmond inserts, is an acceptable design alternative and is in accordanca with approved engineering requirements.

The Project has initiated a review to identify all E&DCRs which have been written against unissued S&W documents. This review has been

, completed. The information or design changes contained in the e E&DCRs will be written against issued documents or verified ir cases where vork has been completed. This review will be completed by August 1, 1981.

Preventive Action To preclude recurrence, instructions have been reemphasized concerning procedurai requirements to make changes only against issuee documents t al to estrblish a jobsite policy of not accepting or processing docurant ( banges on unissued documents.

i G. As of February 4, 1981:

a. There was no object.ve evidence to show that the requirements of standard ACI-318-71 were objectively used as design inputs in the analysis of the effect of rebar substitut4~ in E&DCR PS-2337.

b. There were no engineering calculations to confirm the adequacy of the design change nor was there auf objective evidence of an independent design verification.

This is a Severity Level IV Violation (Supplement II).

Response

The licensee acknowledges that objective evidence of the acceptability of the change from Grade 40 to Grade 60 rebar was not available at the time of the inspection. Subsequently, this evidence was transmittea to the NRC on February 26, 1981, by licensee letter AEC-MP3-231.

The !icensee was advised on March 4, 1981, in a conference call with Messrs. Ebnetter and (haudhary of the NRC that the evidence resolved their concerns and that concrete placements might be resumed.

To preclude sutb occurrences in the future, Stone & Webster has reinf';rced its Structural Technical Review Program. This corporate program will be under the direction of an Assistant Chief Structural Engineer and will require a review and approval of all design criteria and analytical methods to be used in the design of structures.

The program will also inclide the scheduling of a series of reviews during the design phase to assure proper application of the structural desi;n t criteria and analytical methods and the acceptability of the final design. The program is staffed with senior engineers and consultants with xtensive experience in the areas of dynamic analysis, design, and engineering of structures. In addition to the

scheduled involvement of these individuals, they are available to the project groups for consultation whenever required. The imple-mentation of this program will ensure consistent and proper designs for all structures.

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Appendix B A. Construction Quality Assurance Staff The NUSCO construction quality assurance organization assigned to MS-3 construction site apparently is not adequately staffed in 3 number and by qualification to fully implement the commitments made

in the QA Topical Report.

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Response

Prior to the February, 1981, inspection at Millstone Unit 3 the need for additional QA personnel to cover the anticipated increase of activities at Unit 3 in 1981 was recognized. An evaluation to determine the number and type of personnel increases required and the needed date of employment was being developed by the Director of Nuclear Engineering and Operations Services. The need for additional l personnel was recognized by the Director and upper management, however, these people were not interviewed in the course of the audit. Subsequent to the NRC inspection, approval was received from Management Resources to hire three additional QA personnel. Two of the personnel have been added in June, 1981, and the third has accepted an offer and is expected on site prior to August 1, 1981.

The current CQA Unit includes five (5) personnel under the Construction QA Supervisor, performing QA functions for the Millstone Unit No. 3 Proj ect.

With respect to the observation of an " excessive turnover rate of 20%..." we would point out that none of the Construction OA personnel who left in this period resigned from the company. The four people all transferred to other sections of either construction or operations.

Corrective actions are being taken to ensure commitments made in the

. GA Topical Report are implemented.

l B. Organization The NUSCO organizatior. structures and functions related to MS-3 construction, project management, and quality assurance require clarificatina and additional definition. This observation is based on the following:

1. The implemented jurisdiction (position) descriptions i'or project management have not been formally approved by manage-ment.

Response

Position (jurisdiction) statements are being revised to more accurately reflect the dr. ties of Generation Construction Department personnel. Tae updated position statements will be issued after management approval.

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2. ~he implemented jurisdiction descriptions for Quality Assurance have not been formally approved.

! Response:

NQA Procedure NQA1.01 shall be revised to include specific references to functions and duties of the Construction QA Unit and personnel pertaining to Millstone Unit No. 3 and the operating plants. Wherever NQA1.01 refers to other procedures relating to CQA duties, these procedures will also be revised to be more definitive of CQA duties. The above shall be completed by October 1, 1981. In regards to the provision for an Acting QA Supervisor, NQA procedures shall be revised to include the requirement for an assignment of a qualified person to perform the duties of the QA Supervisor in his absence. The above shall be completed by October 1, 1981.

3. Functional organization descr4 .ons do not reflect the actual functioning of organizations.

Response

The NUSCO Generation Construction Organization Chart has been revised to indicate that the Construction Quality Control Unit has no responsibilities for work on Millstone Unit No. 3.

4. The responsibility for stop work authorization is not clearly defined.

Response

Revision 1 to Generation Construction Department Procedure i GCD 4.08, issued April 21, 1981, delegates authority to issue and release Stop Work Orders to the System Superintendent -

Generation Construction or his designee. The procedure, in both cases, requires the concurrence of the NUSCO Supervisor -

Quality Assurance, and further provides for resolution between the Director - Generation Construction and Manager - Quality Assurance if concurrence is not obt ned.

l l C. Design Controls The control of design, including design verification, updating of design documentation, and control of field design is considered to j be a major weakness in the program. This is based on the three l

noncompliances identified in Appendix A, Items E, F and G related to l design documents and the lack of adequate procedural controls for field design of conduit supports.

Response

As stated in the individual responses, items E and F are the result of noncompliance to S&W program requirements for control of design.

The preventive action proposed is considered to be adequate to

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prevent recurrence of these noncompliance Item G, as stated in a the response, is an item that has been previously resolved.

1 The S&W Project procedure (FCP-297) for control of the field design work noted in tt above observatians had been prepared, but was i

still in the apyroval cycle at the time of the inspection. This procedure will be issued on or before June 15, 1981. A review of

! field design activities will be completed by S&W on or before Jane 15, 1981, to ensure that all such activities are supported by approved procedures.

Procedures will be developed and formally approved prior to coamence-ment of any new field design activities.

Conclusion It is recognized that the referenced Appendix A items and the observations addressed above require appropriate action as detailed by each corresponding response. We do not, however, concur that the nature of these items / observations and the specific circumstances related thereto, constitute a valid basis for a conclusion that control of design is a major program weakness.

We recognize the items as implementation noncompliances. They will be corrected and fully prevented using our existing design control program.

D. Training l

The training of personnel at the MS-3 site was identified as a I weakness based on deficiencies found in quality assurance and construction training programs. The need for improvement in training is an immediate concern due to the projected increase in work activities and manpower s*-ffing levels in the very near future.

l The following items const..mte the basis for a weakness in training.

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i Interviews with S&W craft personnel indicated that all persons assigned to MS-3 had not received orientation training as required by project procedure.

2. Interviews with S&W construction management in relatior to construction training and corrective action tasea in response to S&W Audit 23 indicated additional emphasis is required on construction training.

Response

Corrective Action i

j Additional personnel have been added to the training staff: one clerk / typist and one training specialist. Stone & Webster is confident that the training staff is sufficient but will continue to monitor the work load and add additional training personnel as required.

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_10 Stone & Webster has identified all personnel working on site who have not received indoctrination training. The personnel have been scheduled for indoctrination training. This effort should be completed by July 2, 1981.

Preventive Action Newly hired personnel are usually given thei indoctrination training on the morning they report for work. An Indoctrination Training Exception Report is generated weekly and reviewed for scheduling of make up classes the following week.

Effective June 1, 1981, a policy will be instituted requiring newly hired personnel to attend the Indoctrination Training Course within one week of the date of hire. To work on the site more than days after hire without indoctrination, specific written authorization must be obtained from the Senior Site Representative.

S&W recognizes that these observations have identified weaknesses in the training program. We are confident that the action taken to date and the preventive action proposed will ensure that personnel are properly trained. This program will be responsive to changes in Construction personnel levels and technical activities.

3. Inadequate S&5.4 training documentation to support qualifications of S&W inspection personnel.

Restonse:

No response required.

4. Failure of NUSCO management to take effective corrective action in response to findings in the 197'/ management review of the QA program.

Response

Also see response to Appendix A, Item C. To supplement the above response, the Generation Construction Department and the Construction QA Unit personnel will be trained for tue quality related activities I which they perform. The training will be performed within the requirements of the applicable procedures.

5. Inadequate training of a NUSCO QA auditor in relation to assigned inspection functions.

Response

No response required.

_11 E. Regulatory Reporting Regulatory reporting of potential construction deficiencies in accordance with 10 CFR 50.55 (e) is considered a program weakness.

This is based on:

1. The apparently excessive time for the licensee an! his contractor to evaluate po: ential 50.55(e) conditions.

2. The inability of NUSCO to identify potential 50.55(e) conditions in a timely manner due to an inadequate program for review of S&W nonconformance reports.

3. Inadequate attention by NUSCO to previously identified NRC concerns documented in IE Inspection Reports 80-07 and 80-04.

Response

The licensee acknowledges that in the case of the Reactor Plant Component Cooling Heat Exchanger Supports, an inordinately long period was requi>ed to determine the significance of the manufacturing deficiencies and to report them. Subsequent to the identification of this problem, S&W has implemented Quality Standard 16.2, Rev. A (10/31/79) to provide additional guidance in handling of potentially reportable items of significant deficiency under 50.55(e). Training on this procedure, and its associated Engineering Assurance Procedure (EAP 1.62), was presented to the MP3 Project in March of 1980.

Furthermore, the project has issued a procedure to establish internal tracking of potential 10 CFR 50.55(e) reports during S&W review.

Generation Construction Department Procedure GCD 4.09A, Rev. 1, dated January 30, 1981, provides guidance for prompt reporting of significant and potentially significant deficiencies.

The licensee would point out that 10 CFR 50.55 (e) does not address the reporting of potential deficiencies. This interpretation was presented during the exit interview for Inspection 50-423/80-04.

The licensee would also note that the concern documented in Inspection Report 80-07 was only a statement that further documentation relative l to the reported significant deficiencies in the design of the Service and Auxiliary Buildings would be requested, particularly in l the area of corrective action. This request was formalized on 1 Janua ry 29, 1981, and responded to on April 21, 1981.

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