ML20043F716

Evaluation of Seabrook Station Const Project.

ML20043F716
Person / Time
Site:	Seabrook
Issue date:	11/30/1983
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
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NUDOCS 9006180036
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November 1983 Construction Project Evaluation l RESTRICTED DISTRIBUTION x Seabrook Station ouo ic service g g g g&V s;D D. C . C .

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> 3 EVALUATION of SEABROOK STATION Construction Project o

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Public Service Company of New Hampshire L

fopyright 1984 by Institute of Nuclear Power Operations. All rights reserved. Not for sale. Reproduction of this report without the written consent of INPO is expressly prohl-bited. Unauthorized reproduction is a violation of appilcable law.

The wrsons and organizations that are furnished copies of this report should not deliver or - l truster this report to any third person, or make this report or its contents public, without the prior agreement of INPO and the member of INPO for whom the report was written.

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• INTRODUCTION 1

The Institute of Nuclear Power Operations (INPO) conducted an evaluation of :ne Pa :

Service Company of New Hampshire's (PSNH) Seabrook Station construction project anc t .e !

United Engineers and Constructors'(UEkC) design offices during the weeks of Octooer I and 24,1983 Be project is located in Seabrook, New Hampshire, approximately M miles >

nortn of Boston, Massachusetts. The project has two,1,198-Mwe Westingnouse pressurt:ea water reactors. Unit 1 is scheduled to load fuel in September 1984  !,

PURPOSE AND SCOPE INPO conducted an evaluation at the site and the principal design office of United Engineers and Constructors in Philadelphia, Pennsylvania to evaluate the control of design i and construction processes and to identify areas needing improvement. Information was '

assembled from discussions, interviews, observations, and reviews of documentation.

Re.INPO evaluation team examined organization and administration, design control, con ,

struction control, project support, training, quality, and test control. The team observec actual work performance and test performance. A portion of the evaluation focused on a i detailed vertical path examination of the control of design of two safety-related systems i comoined with a horizontal examination at several points.

INPO's goal is to assist member utilities in achieving the highest standards of excellence in I nuclear plant construction. The recommendations in each area are based on best practices, ,

rather than minimum acceptable standards or requirements. Accordingly, areas where improvements are recommended are not necessarily indicative of unsatisfactory perfor I mance. '

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RESTRICTED DISTRIBUTION Copyright 1984 by hstitute of Nuclear Power Operations. All rights reserved. Not for sale. Reproduction of this report without the written consent of INPO is expressly prohi )

bited. Unauthorized reproduction is a violation of applicable law.

The persons and organizations that are furnished copies of this report should not deliver or transfer this report to any third person, or make this report or its contents public, without the prior agreement of INPO and the member of If 4PO for whom the report was written.

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Tithin the scope of this evaluation, the team found, except as indicated by the finep, that the systems in place to control the design process and the quality of construction 2r3

being implemented effectively.

-The following beneficial practices and accomp!!shments were noted:

The Performance Enrichment Group provides a catalyst and a forum for exchange af ideas and improved communications concerning site performance problems.  ;

The site eye protection program is effective in reducing eye injuries.

The pipe storage laydown yard and off-site storage at Newington, New Hampshire are supervised and maintained in an effective manner.

The site receipt inspection program is comprehensive and thorough.

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The selective use of superplastizer in concrete mixes is effective in placing concrete in congested structures, l improvements were recommended in a number of areas. The fo!!owing are considered to be among the most important I

The control, issue, and installation of safety-related fasteners needs improvement to i ensure materlats are being used where required. <

The ASME code stamping program needs immediate management attention.

The system turnover process needs improvement to ensure systems are turned over on

schedule with a minimum of construction work remaining.

The QA surveillance program is basically sound, but the approach to corrective actions i needs to be expanded to analyze generic issues and solve root causes.

I More attention is needed in training supervisors and craf tsmen to ,ipgrade their use of l procedures. '

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Several identified problems in design control indicate a need for improved procedures, L training, and attention to detail.

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The control of drawings needs to be improved to ensure the project is being constructed as required.

E. Increased involvement of senior project management personnel is needed to ensure personnel are held accountable for producing quality workmanship and for meeting project objectives, i in each of the areas evaluated, INPO has established Performance objectives and supporting criteria. Findings and recommendations are listed under the Performance Objectives to which they pertain. Particularly noteworthy conditions that contribute to meeting Perfor-l.

' mance Objectives are identified as Good Practices. Other findings describe conditions that detract from meeting the Performance Objectives, it would 'not be productive to list as l-l, e t '

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Good Practices those things that are commonly done properly in the industry since v.s would be of no benellt to Public Service Company of New Hampshire or to INPC's othe-member. utilities, , As a result, most of the findings highlight conditions that 9eed .mproie- '

ment.

The recommendations following each finding _are intended to assist the utility in ongo#g a efforts 'to improve all aspects of its nuclear programs. In addressing these findings anc recommendations, the utility should,' in addition to correcting or improving specific condi.

t tions, pursue underlying causes and issues.- As part of each construction project evaluation. ,

the evaluation team follows up on responses to previous findings,in this case those from the self-initiated evaluation report. In areas where additional improvements were neeced a new finding that stands on its own merit has been written. Thus, this report stands alone, and-reference to the previous self-initiated evaluation report should not be necessary. For inis evaluation there are nine new findings relating to previous findings.

i The findings listed herein were presented to Public Service Company of New Hampshire management at an exit meeting on November 18, 1983. Findings, recommendations, and responses were reviewed with Public Service Company of New Hampshire management ,

on January 12,1984. Responses are considered satisfactory.  !

To follow the timely completion of the improvements included in the responses, INPO requests a written status by August 31,1984. Additionally, a final update will be requested six weeks prior to the next evaluation of Seabrook Station construction project.

The evaluation staff appreciates the cooperation received from all levels of Public Service Company of New Hampshire, Yankee Atomic Electric Company, and United Engineers and Constructors.

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Response Summary Public Service Company of New Hampshire, in cooperation with United Engineers k Constructors and Yankee Atomic Electric Company, has reviewed the findings and rec:m-mendations resulting from INPO's Construction Project Evaluation of the Seabrook 1 S ta tion. This evaluation identified a number of areas in design control and construction control where improvements-could be made.. i Each of the findings has been evaluated, and serious consideration has been given to *.he recommendations. Appropriate, positive actions have been .or are being taken in response to each of these findings.

Timetables for these actions have been identitled. The most signi!! cant of these actions are the following areast

a. Identification and timely resolution of project problems by management  ;

b. documented verification of systems for applicable transients

c. supervisory control of daily activities  ;

d. project emphasis on first-time quality

e. Increased training of personnel and relevant evaluations of program results

f. timely disposittoa of nonconforming materials l The management of the Seabrook Station project wishes to express their appreciation i to the evaluation team for their effort and dedication and to INPO for its assistance in.

striving for a high level of excellence in the construction of Seabrook Station.

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ORG ANIZATION AND ADMINISTRATION ORG ANIZATIONAl. STRUCTURE PERFORM ANCE OBJECTIVE: The owner's corporate organization and all other project organizations responsible for the design, engineering, planning, scheduling, licensing, con-struction, quality assurance, and testing of a nuclear plant should provide an organizational structure that ensures effective project management control.

i Finding (O A.1-1) Improvement is needed in'severai aspects of management direction'!

and control of the project. Meas for improvement include tne following:

a. ensuring the timely resolution of significant problems b, defining and promulgating senior- and middle-level project '

managers' responsibilities and project goals

c. holding individuals accountable for schedule adherence and for action items discussed in project meetings

d. *:asuring the timely update of project milestones  !

i Recommendation - Tne utility should develop an aggressive senior project management '

team. Management's interest, personal involvement, and forceful I direction should be more evident to all levels throughout the project ;

Major project programs and plans of action should be monitored and '

reviewed frequently to ensure their adequacy in areas such as the followings

a. timely problem identification  !

b. developing long-term problem resolutions

c. defining clearly individual responsibilities -i

d. assigning firm, realistic - commitments and completion dates i

e. holding personnel accountable {

Action plans should be in writing, should be reviewed, and the status i updated frequently at meetings involving the highest level of sitei management. The senior management team should include the site managers of the major subcontractors.

Response Senior PSNH management is presently conducting an assessment of every aspect of the Seabrook project. The assessment will include, but not be limited to budget; cost; personnel capabilities; organization structures; responsibility, authority, and accountability of personnel; and commitment monitoring. The results of the assessment will be directed toward providing a management concept that is capable of 1

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identifying and aggressively resolving project problems. It will clear;.

identify personnel responsibilities and authority, so that indi/tdu1;s !

can be assigned firm and realistic tasks and task completion ta:es. !

and can be held accountable for completing these assignments. ' De I assessment will be completed - and changes implemented by Wr:i 1984. .

i A Project Management Manual will be prepared and issued by '. tar: 5 i 1984. This manual will delineate the responsibilities, authority, and i reporting !!nes of senior- and middle-level PSNH, YAEC, and UERC personnel. All personnel covered by the manual will receive tra.ning _ '

i to ensure that they are cognizant of their duties and responsibilities by April 1984.

MANAGEMENT INVOLVEMENT AND COMMfTMENT TO QUALITY PERFORMANCE OBJECTIVE: Senior and middle managers in the owner's corporate office, designer's office, and at the construction site who are assigned functional responsibility for matters relating to the nuclear project should exhibit, through personal interest, awareness,~ ,

and knowledge, a direct involvement in controlling the quality of the project.

Finding (O A.2-1) Senior managers need to be more effective in resolving problems '

identified through the quality assurance (QA) program.on the pro-ject. Quality performance data is not being developed and analy:ed a '

to effectively address generic problems and root causes of degraded quality. The degree of project problems and needed corrective actions are not communicated accurately through existing reporting, systems. ,

Recommendation Summary and status of corrective action (SSCA) reports should:

include analyses that identify generic problems and root causes of-quality problems to higher - management levels. Senior . managers should take the lead in directing corrective action and follow up to ensure its adequacy on generic issues.

Response $1nce December 1983, the YAEC Construction _ Quality Assurance Manager has participated in the weekly Project Management meetings. This participation ensures that quality assurance project problems and the required corrective actions are accurately communi-cated to senior site managers. When escalated management actions are required, they are formalized through immediate Action Requests. A trending program, to identify recurring deficiencies, will be fully functional by February 1984. The trending results will be summarized and reported to management. A Management Action =

Report Program is also scheduled to be implemented in February 1984. This program will identify middle management accountability for resolving identified problems and provide for proper monitoring of corrective actions by senior site managers.

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= THE ROLE OF FIRST-LINE SUPERY1 SORS AND MIDDLE MANAGER l PERFORMANCE OBJECT!YE: The project first-ilne supervisors and middle managers -

should perform a significant role in ensuring the quality of the project.

l Finding ~(OA.3-1) Increased effort is needed to ensure supervisors in the areas of instrument and control (l&C) and measuring and test equipment l (M&TE) understand and assume their responsibilities. On several occasions, direction was given contrary to quality requirements. In other instances, corrective measures were not taken when known, deficient conditions existed in the work process.

Recommendation Ensure site !&C and M&TE supervisors are knowledgeable of and adhere to project quality goals and program requirements. Considera-tion should be given to the followings

a. establishing a " Supervisor Responsibility Development" program under the direction of the utility corporate

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b. requiring participation for a!! levels of supervision  !

c. establishing or designating a utility group to monitor e!!ectiveness through work activity surveillance with performance reports to utility senior site and corporate management Response To provide the necessary information, a program equivalent to the Supervisor Responsibi!!ty Development Program is currently in place. This program requires that, prior to commencing work, each ,

individual filling a supervisory position for major contractors be cognizant of the procedures for which he is responsible and receive training in his respective discip!!ne. A matrix or list has been  !

. estabilshed for each position giving the procedures, classes, and ,

reading required to be completed in order to meet the commitments '

of this program. These requirements clearly delineate the responsibil-ities of the respective positions and are comprehensive in scope.

A system for evaluating the effectiveness of all training is being '

developed and will be !mplemented. This system will identify deficiencies that exist in the area of supervisor's responsibilities. . An ~i evaluation of training. effectiveness will be included in monthly '

training reports submitted to senior project and site management. i All actions wi!! be implemented by February 1984.

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u Finding (C A.3-M The following Good Practice was noted: The establishment of the Performance Enrichment Group (PEG) is a fresh- approach towar:i .1 improving work site performance. Although the PEG has only :ea- .-

l existence since March 1933, the. following: positive indicators haie been noted:

a. improved communications through establishment of a nte newspaper

b. establishment of problem-solving meetings with PSNH. i UE&C, and all major site contractors (Their involvemea . -!

has already identified needs for training courses and t : -l necessity to perform work site surveys to determine causes for work delays.) j l

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Page ) l DESIGN CONTROL DESIGN INPUTS PERFORMANCE OBJECTIVE:' inputs to the design process should be defined and contro!!ed i to provide a consistent basis for making design decisions in order to achieve a complete, high quality design. ,

Finding (DC.I.1) A more effective system is needed to ensure all dynamic fluid tran-sients are considered and translated to- the final design documents.

Piping analysis work request (PAWR) packages were reviewed f ar some of the safety-related fluid systems. The documents reviewed did not show that fluid transients were considered in the pipe stress analysis. Also, the documents- did not reflect consideration. for building settlement loads and stress-range reduction factors. The i

effects of seismic acceleration on pipe supports have not been addressed and documented.

Recommendation Evaluate the controls that should have identified the need to consider dynamic fluid transient loads in the pipe stress analysis, and _imple-ment appropriate improvements. Also, evaluate the piping . design-specification for the need to specifically address the following:

a. dynamic fluid transients for 'each safety-related l'uid system

b. building settlement loads

c. stress range reduction factors

d. effects of seismic accelerations on pipe supports-Reconcile all discrepancies with the appropriate pipe stress analysis.

Response The following actions will be taken:

a. Those transients that 'are expected to happen with a reasonable frequency and have potential for significant ,

effects were considered and are scheduled to be evaluated.

To improve the program that ~ ensures dynamic. fluid '

transients are considered in - the final. piping- design,' a generic list of events for fluid transient considerations will be formalized. Program improvements will be incorpora't- 4 ed into Project Procedure A P-31, " Development of

..- Pressure / Temperature Data Sheets," by February 1984.

Further UE&C analysis will include documented verifica-tion for each system to establish which postulated transient is applicable, not applicable, or covered by a .

more severe bounding condition. Transients for which pipe stress analyses are not performed will be discussed to

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- define system features that preclude tne 3c:arrences, n; P,. associated piping analysis will be rechecked for t .e 2:;..- [

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cable transient effect to ensure that- the impact ;s .e ' -

the margin of design. These actions ~will be~ completec ::

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b. Procedure DEDP - 2607, " Computerized Piping Ana.ysis.

L will be revised to clarify the requirements for documen-ting the considerations for building settlements. The coce :

in effect (1971 Code, Winter Addenda of '72) does n:t '

contain . a specific requirement on building settiemen:

loads. . Building settlements are insignificant at Sesor:0<

because the plant foundations rest on bedrock. Therefore, no changes in the Seabrook piping specification to aadress this condition will be implemented.

c. Systems in PWRs generally.. experience less than 7.E cycles. Therefore, a stress-range reduction factor of 1.1 is used. UE&C will review the systems with a potential for a high number of equivaleet full-temperature cycles' over the expected years of service and verify the adequacy ;

of the assumption made for the' f value. In addition. -

AP-31," Development of. Pressure / Temperature Data j Sheets,? will be revised to emphasize this requirement. .

d. A sampling of 25 supports was chosen and analyzed, using !

criteria based on a worst-case selection of pipe size.,;

geometry, type, location, and support load condition.

1he results of the analyses indicate that the effect of f seismic accelerations on supports need not be considered.-

This is primarily due to the- stiffness and frequency '

-criteria, which provide sufficient design margin to alto v for the stresses produced by these effects. Therefore,1 UE&C does 'not plan any calculation retrofitting.

However, . the Pipe Support Design Guidelines will- be revised: by February 1980 to specifically address these effects in future designs.

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l v Finding (DC.1-2) The requirements for single-failure criterion need to be considered when establishing the bounding design conditions for the ASME Sec ,

tion m pipe stress analysis. Some minimum and maximum fluid tem l

perature excursions resulting from single component failures exceed.

the values utilized in the pipe stress analysis. I l

Recommendation Evaluate the need to expand the single. failure criterion definition and l the e,antrols that should ensure that the criterion is satisfied, and Lnplement appropriate improvements. Revise tne component cooling I

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water system pipe stress analysis to include consideration for ther~a. {

variations from control and alarm setpoints (minimum / maximum) 2 : 4 determine if similar considerations are required in other salen-related systems, l

Response

The maximum temperature condition is given more emphasis egart-ing single failure since this condition typically resu'lts in worst-case thermal stress condition. It appears that the identified inconsist-  ;

encies are confined to the identification of the minimum rather than the maximum temperature condition. J A comprehensive review of all the systems that have the potential t:

be exposed to temperatures lower than the normal piping ere=an temperature will be performed. As part of this review, UE&C .will i confirm that the' maximum fluid temperature (alarm setpoint) is mal; to or less than the maximum temperature utilized in the pipe stress analyses. The associated pipe stress analyses will then be reviewed to ensure their adequacy and revised for completeness.. The foregoing actions will be complete by July 1985.

l AP-31, " Development of Pressure / Temperature Data Sheets," will be -

revised by February 1984 to emphasize the single failure criterion requirement. ]

Finding (DC.1-3) Some additional thermal operating modes need to be considered in the '

ASME DI Pipe Stress Analysis. Use of fluid minimum temperatures in some operating modes is neither defined nor included as the bounding l condition for equipment nozzle thermal displacement. Cold water injection results in pipe contraction and affects the pipe stress analy-

' ses for several safety-related systems. i

. Recommendation Review and update calculations and pipe stress . analyses to ensure minimum fluid temperatures (less .than 70 degrees Fahrenheit -in winter) have been considered in those : piping systems that have.

potential . cold water injection sources during normal,' upset, test, '

emergency, and faulted operating conditions.-

Response As stated in the response to Finding DC.1-2, a comprehensive' review of all the systems that ha've the potential to be exposed to tempera-tures lower than the normal piping erection temperature 'will be }

performed. The associated pipe stress analyses will then be reviewed to ensure their adequacy and revised for completeness.- These actions will be completed by July 1985.

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Some design documents do not support required considerations for upstream of containment isolation remote-operated .\ r e v ,e s of several associated design documents' indicated that their poteb. I f ailure was not considered in the design process, as requirec.

Recommendation Review instruments and instrument lines that are part of t ,e on-tainment isolation boundary for conformance to failure effects analysis requirements.

Response

A complete re-review of the containment penetration arrange nents !

will be conducted to confirm that all instruments and instrument lines ,

that will be part of the containment boundary, under tne appropr:an plant condition, meet the appropriate containment isolation req ments of 10 CFR 50, Appendix A and Regulatory Guide 1.!!. Correc. '

tive actions will be implemented for discrepancies that are identified. This action will be complete by Maren 1984 Finding (DC.1-5) Industry design, construction, and operating experience information is !

not utilized fully. Relevant industry experience information is routed h for review, but records do not exist to show that SERs, SOERs,' anc other documents are evaluated fully for applicability, and corrective-actions are not tracked to completion. In addition, the NUCLEAR ;

NETWORK (formerly NOTEPAD) is not utillzed fully in the areas oiq construction and startup.

Recommendation Establish a comprehensive operating experience review program. The program should include a review, evaluation,'and documented dispost- {

tion of all SERs and SOERs to ensure that appropriate actions have j been taken. In addition, provide, relevant NUCLEAR NETWORK

• Information 'to c the Construction and Startup Test Department i managers for their review and use. Encourage NUCLEAR NETTORK' use te provide industry information exchange of generic interest.'

Response A program will be implemented to formally inform and educate supervisory personnel in Engineering, Construction, Startup, Q A, and' Production from Y AEC, PSNH, and UE&C on the purpose and use "of -

NUCLEAR NETWORK (formerly NOTEPAD) system reports, SERs anc SOERs. This program, including the requirements for evaluating and documenting actions taken on SER and SOERs, will be completed by March 1984 Each of the above organizations will conduct its own program.

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SOER ST ATUS i The status of Significant - Operating Experience Report (SOER) recommendations is as ]

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l Number of Recommendations Action Taken  ;

O Satisfactory 52 Not app!! cable 226 (32 red tab) Pending - awaiting decision 0 Pending - awaiting implementation 0 Need further review 0

Previously evaluated as satisfactory or not applicable .

The following recommendations are pending - awaiting decision:

SOER Number -

Recommendation Number 30-1 1, 2 80-2 1, 2 30-3 1, 2 i 30-4 1, 2, 3 30-5 4

1, 2 81-1 1, 2 31-2 1,2,3,4,5,6 31-3 1, 2, 3 31-4 1,2,2a,26,3,4 81-5 1, 2, 3, 4 81-6 1, la, 2 81-7 ,

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81-10 1 81-11 1  !

31-12 1,2,3,4a,4b 81-14 1, 2, 3, 4 31-15 la,Ib,Ic,2a,2b,2c,3 81-16 1, 2, 3 17 1, 2, 3 82-1 1,2a,2b,2c,2d,3,4 32 1 82-4 1,2,3,4,5,6 32-5 1,2,3,4,5,6 82-6 1,2a,2b,3,4,5 82 1, 2, 3, 4a, 46, 4c, 4d, he, 4f, 5 82-8 1, 2, 3, 4 82-9 1,2,.3,4,5,6,7,8,9 82-10 1,2,3,4,5,6,7 32-11 1,2,3,4,5 82-12 1,2,3,4,5

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Page . . l SOER Number Recommendatien Number 32-13 1, 2, 3, 4, 5, 6, 7, 3, 9, 10, i1, 12, 13 32-15 1,2,3,4,5,6 32-16 1, 2 33-1 S3-2 1,2,3,4,5,6,7,3,9,10,11,12,13,14 l, 2, 3, 4, 5, 6, 7, 3, 9,10, I t ,12,13,12,15, 16, 17, 18, 19, 20,.21, 22, 23, 24 33-3 1, 2, 3, 4, 5, 6, 7, 3, 9, 10, 11 33-5 1,2,3,4,5,6,7,8,9 33-6 1, 2, 3, 4 33-7 1,2,3,4,5,6,7,8,9 l

An update on the status of each recommendation listed in the "pending-awaiting decision" '

or "pending-awaiting implementation" categories shown above is requested in the six-month  ;

follow-on response to this report. In addition, the status of each red-tab SOER recommend- '

ation received subsequent to this evaluation should be included in the six-month follow-on response. A tabular summary, similar to that shown in this report, is requested.  ;

1 DESIGN INTERFACES '

PERFORMANCE OBJECTIVE: The design organization's external and internal interfaces.

should be identitled and coordinated to ensure completion of a design that satisfies all input requirements.

Finding (DC.2-1) Improvement is needed in the control of interfaces among the various design organizations. Design information originating in the Nuclear ~

Group is not always identified to or coordinated with the Control.

Group, the Fluid Analysis Group, the Mechanical Analysis Group, and with plant operations. The exchange of HVAC design information among the Mechanical Services Group and the Control Group, the Electrical Group, and the owner's design control group has _not always -

been complete. Electrical drawings and electrical design changes have not always received the proper interdiscipline review.

Recommendation Review the methods by which design information is transmitted among various design organizations,' and implement measures . to strengthen the control of these design interfaces. In those areas where design interface control weaknesses are identified, review the appropriate complete design work for adequacy of interface control.

Response UE&C will review the procedures governing discip!!ne interaction as well as the System Engineering Completion Program for potential changes aimed at implementing further improvements. Additional

. SEABRO M ". W Pag '3 training sessions for key engineering and design personnel vc :e N conducted by June 1934 to strengthen the existing discipline in:erac.

tion requirements.

.For areas where systematic / generic weaknesses are identified by the foregoing review, selected system's completed design work -will M examined to assess impact, and appropriate corrective action will te taken. -This examination will be completed by September 1934.

DESIGN PROCESS

- PERFORMANCE OBJECTIVE: The design process should be planned, scheduled, and con-trolled to ensure incorporation of design requirements.

Finding (DC.3-1)

More attention is needed in the preparation, verification, updating,

!- and timely issuance of some electrical design documents.. Some .

- calculations contain errors, inconsistencies, and missing. or out-of-date references. Some drawings contain errors and inconsistencies.

l Some calculations have not eeen issued although the equipment that is -

supported by these calculations has been installed. The delivered-configuration of some electrical and mechanical equipment is not reflected in the related specification.

Recommendation Upgrade the in-depth review of electrical calculations and drawings.

Evaluate the control and guidance governing these documents, and implement appropriate improvements. For the identified deficiencies, action taken should> include the followings

a. Prepare electrical calculations that support installed '

equipment. -

b; Confirm that the equipment and current designs affected u by these calculations are adequate to meet their intended L.

function.

c. Upgrade specifications to include the delivered condition f or all equipment. '

e p Response I UE&C has reviewed the program and guldance governing electrical' drawing and calculation preparation and has found them to be adequate. UE&C will re-emphasize the need for thoroughness in the implementation of these controls; specifically, for drawing and calculation preparation, and checking program through additional training of engineering and design personnel. This action will be completed by April 1984.

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l SE ASROCK ",33 3 i e -.,- Pap M UE&C has the following response to the specific recommended actw3- I pertaining to the identified deficienciest

a. Although certain electrical equipment, such as 430 V E.t substations, have been installed without hating issue:

formal loading calculations;. loading has been monitored a.!

along through load data maintained in our design fi!es.

Calculations are in the process of being issued.

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For the identified deficiencies in the 125 V de calculation.~

preliminary review indicates that- these deficiencies ui;i- "

not have an impact on the system design. These deficien.

cies will be corrected by April 198t4

c. Those specifications that do not rei!ect : latest delivered configuration of the equipment will be revised under the  :

System Engineering Completion Program to ensure that they reflect latest equipment data.-

DEstGN OUTPUT PERFORMANCE OBJECTIVE: Project design documents should specif rate, and clear requirements for a constructible, testable, operable,yand complete, accu-maintainable design.

' Finding (DC.5-1) Administrative control of the PSAR needs to be improved to ensure  ;

design basis criteria and licensing commitments are. satisfied. - Some exceptions have been taken to an FSAR section that established the -

design basis criteria and licensing commitments without documenting-the technical justification. Many minor discrepancies exist between text, tables, figures, and other design basis documents in this FSAR- -

section.

Recommendation Reconcile inconsistencies, and provide technical justifications where exceptions to FSAR containment isolation system commitments have . f been taken. Evaluate the control systems that should have prevented - I these discrepancies, and implement appropriate improvements. {

Evaluate other FSAR sections as required, and determire if other implementation deficiencies have occurred. I Response Review of the supporting details indicates a need to simplify the  !

presentation of information in the FSAR, for in some cases, excessive information lead to erroneous conclusions. Some of the minor discrepancies were already addressed in FSAR Amendments that are in the final stages of review. To address these inconsistencies and provide, where necessary, technical justification of exceptions taken, l

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' SEABROOK II H D Page U UE&C will review the applicable administrative procedures. UE&C.

will implement appropriate _ improvements. A thorough review wil! M .

performed of FSAR, Section- 6.2.4 and; several other sections' t:

determine if any other significant inconsistencies or discrepancies exist. This review will be completed by.May 1984 I

Finding (DC.5-2) More attention is needed in clearly indicating the safety classification l of equipment on design drawings. Classification marking of piping and ;

instrument diagrams (P&lDs) is ' not . consistent with some of the = - l app!! cable procedures. One electrical drawing did not indica te' .

" Nuclear Safety Related" as required. Some electrical drawings ;

incorrectly show annuciators as safety-related.

Recommendation Review procedural requirements for the. classification marking of ~ ?

drawings, and take action to eliminate any inconsistencies. Review P&lDs and electrical drawings to resolve incorrect marking. Consider extending this review to include other design groups.

Response UE&C will review the appilcable procedures for the classification marking of P&!D drawings to ensure consistency between procedures' .

and provide required clarification by Apri! 1984. The ASME B&PVC  !

Section Ill. boundaries are indicated, and the drawir.as se certified for '

Section III, NA2131 Code Class boundaries and as such do not require additional stamping. This is an accepted ud documented method-ology, ~ as indicated in Project Procedur2 Q A-3, .Section Ill.E.3.C.-

Inconsistencies on the electrical drawings have been corrected and other drawings checked. The drawings noted are considered isolated

, cases and as such do not have generic implications across disciplines.

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SEABROCK ;m P3ge .? l CONSTRUCTION CONTROL CONSTRUCTION ENGINEERING PERFORMANCE OBJECTIVE: Engineering and design performed on site under the autho-

. rity of the construction organization should be controlled as to consistency with the basic design criteria to ensure compliance with applicable codes, standards, and regulatory sm--

mitments.

Finding (CC.1-1)- The Engitteering Change Authorization (ECA) program needs improve- -!

ment. The existing program is cumbersome and does not always meet program objectives, resulting in errors or omissions not bein g -

detected. Also, contrary to project requirements, =some ECAs are being utilized to request information from the field.-

Recommendation Upgrade the ECA program. Include considaration of the following s steps in this effort:

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a. Institute. measures so that personnel and approval authority exist at the. site to make design changes and-engineering Improvements,

b. Evaluate the effectiveness of the existing design drawing and ECA review process relative to acceptance standards, and provide training as required to reduce the number of ECAs with minor errors and omissions.

c. Revise the ECA procedure to limit the time allowed for incorporation into the document of ECAs modified by the home office / site.

d. Revise the ECA procedure to require trending and analysis <

of the ECAs. The results should be made available to both l site and home offices for their use in reducing the ECAs by correcting the problems identified by trending.

e. Establish a policy with a!! contractors that w'ill allow on- i L -

the-spot ECAs to be acted upon immediately af ter appro-s vai by UE&C.

R L f. Eliminate any unnecessary steps in the problem-resolution t!

area.

g. Train the appropriate personnel in the revised program requirements, and ensure proper implementation.

. Response A comprehensive review of Administrative Procedure (AP-15),

defining the Engineering Change Authorization (ECA) Program, by i both UE&C and YAEC/PSNH was initiated in August 1983. In l November 1983, a revision to AP-15 was issued. The revision utilized l: i 1

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SEABROCK r;33r Page ;) - l the results of the internal reviews as a basis. The complexities of tw previous revision have been minimized while maintaining techn:ca.

and administrative controls.'

PSNH will continue to review the ECA Program in an effort to- l streamline and improve its operation. A review of this program is I included in the evaluation being performed by senior management, as described in response to Finding OA.1-1.

Specific responses to the INPO recommendation are as follows:

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a. Site engineering has had approval authority for design. l changes in specifically defined areas .(e.g., conduit  ;

supports, NNS-1 piping). The process of expanding this  !

authority to cover other areas will start in Februar_y 1934

b. The reviews identified above evaluated the' effectiveness of the design change program. Specific training 'was provided following the issuance of the revision of AP 15 in November.

c. Those ECAs modified / rejected by home office, where the contractor proceeds, are less than ' 5 percent Land are -

accepted as part of the risk to keep construction moving,

d. A trending program has been initiated for ECAs.

e. The p'roject will evaluate the ECA review cycle to attempt simplification by reducing the number of sign-offs.

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f. The latest revision to AP-15 removes unnecessary steps in' ,

, problem resolution.

g. As indicated above, training has been performed covering  ;

the latest revision of AP-15.

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MATERIAL CONTROL PERFORMANCE OBJECTIVE: Material and equipment should be inspected, controlled, and maintained to ensure the final as4u11t condition meets design and operational requirements.

Finding (CC.3-1) Some installed equipment is not being maintained in accordance with vendor recommendations and Project Preventive Maintenance programs. Construction personnel have not always followed require-ments to provide continuous protection of installed equipment and initiated maintenance requests for corrective action. Maintenance n

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and quality surveillance engineers have accepted some conditions est do not; satisfy the cleanliness, equipment protection, and inte a.

environmental controls specified by the vendors.

Recommendation Upgrade the protection of equipment from the construct t wir:n- 1 ment and the maintenance of internal environmental cor ~;.s. Ensure that maintenance, quality surveillance, and - construction actions demonstrate understanding of the preventive maintenance program requirements. Ensure that all deviations from preventive mainte-nance requirements are reported in writing to responsible manage-ment and corrective actions are implemented and verified.

Response

Procedural changes have been made to the environmental surveillance program to provide positive control of the construction environment, in addition, Preventive Maintenance personnel and Quality Assurance engineers have been instructed to report immediately in writing any deviations to maintenance requirements. All deviations to program-matic requirements will be documented properly.

The Preventive Maintenance Supervisor, who reported to the Chief Material Supervisor, now reports to the Medanicci Superintendent.

His responsibilities include electrical as well as mechanical. The '.

change will improve the construction PM Program control and provide better . program support with personnel resources and technica! l guidance.

The Startuo Test Department (STD) has implemented measures to '!

take -immediate responsibility for the preventive maintenance program for turned 'over equipment. STO will take sole responsibility for equipment cleanliness, including the areas surrounding the turned over equipment. The transition of these programs will be completed by March 1984.

,1 Finding (CC.3-2) The identification and installation control of safety-related structural botting materials need improvement. Incorrect nuts and washers are being used on high-strength bolts to assemble hanger components. .A unique system does not exist for identifying structural bolt materials installed in the plant. As a result, quality control (QC) inspectors cannot verify that the correct materials were purchased and installed.

Recommendation Upgrade the site process for identifying, installing, and verifying safety-related fasteners. Include the fo!!owing in - the upgrading. i efforts:

a. Establish methods to ensure that the installers receive the correct materials and know what materials are required to meet the design drawings.

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5. Provide a physical identification system to ensure tnt 2:

QC inspection time all safety-related f astners :an M identified. ' Identity. should show that they are :he correct structural materials and were purchased from a cernfie:-

vendor.

' Response Nuts and washers used .on high-strength bolts to assemble hanger components have been evaluated to be technics!!y acceptaole. The necessary documentation for the verification of quality requirements of subject fasteners in safety-related systems is under evaluation and will be available by March 1934.

By the end of February 1934, all personnel involved in the control.

installation, and_ inspection of NF bolting will be retrained in the requirements and method of control and identification of bolting  !

material.

The project will re-evaluate the systems of' controls to determine 'l their adequacy. If the evaluation determines an improved physical '

identification system is required to ensure safety-related fasteners can be identified, the system will be implemented by March 1984 CONTROL OF CONSTRUCTION PROCESSES PERFORMANCE' OBJECTIVE: The construction organization should monitor and control all construction processes to ensure that the project is completed to design requirements and that a high level of quality is achieved.

Finding (CC.4 1) Improvement is needed 'in providing. the craftsmen with complete, legible, and accurate installation documents. Additional information must be added to design drawings by Engineering Change Authoriza-tion (ECA) to complete construction activities. Deficiencies in docu-ments are resulting in a large amount of rework. Specific problems were found in the following areast

a. hanger installation

b. concrete drilling i c- alaetrical panel modifications

. Recommendation Identify responsible individuals _ at engineering, management, and supervision levels to review drawings to ensure that all construction  !

drawings are complete, legible, and accurate. At the first-line super-vision level, ensure that supervisors review and' provide additional specific guidance to the craf tsmen to reduce construction errors.

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SEABROCK '! ?s s .)

Page :: 'l Response - i The current program identifies engineering,- management, in: -l supervisory - personnel who are required to review . construc w -

drawings- to ensure their completeness.and accuracy. The progrim

' includes training of personnel preparing and checking documents, With l emphasis on high quality work standards to rninimize document revisions. Management emphasizes these quality requirements to-~ l supervisory personnel. Since the INPO evaluation, a Design Change -

Trending Program has been implemented to track the . reasons. for drawing changes and to determine their root causes. When causes are I identified, corrective action plans will be implemented, l A Drawing Enhancement Program was recently put in place to redraw aging drawings and to ensure good quality reproductions.-

To provide improvements in implementing the program, the following.

actions have been taken:

a. Supervisors and fleid engineers maintain a status schedu!e to ensure that design information is available prior to' commencing work. Field engineers are required to review

esign information, including drawings, to ensure that they are complete. Craftsmen are instructed to ask for

- guidance if the design information is inadequate or unclear, a

b. Inspectors are being rotated between in-process and final  !

inspections.  !

c. Personnel performing as-built verifications are now working directly with the QC final ~lnspectors. t Finding (CC.4-2) Improvement is needed in the control of some mechanical construc-I

' tion work to prevent errors. Examples include incorrect materials, improper welds,' arc strikes, improper dimensions, incorrect com ~

ponent location, and Improper work sequencing. ' Areas where -

weakness were noted included the followings j a. hanger erection i b. pipe erection -

c. availability of the required material Recommendation Upgrade the in-process controls of mechanical construction work to minimize errors during the construction process. The goal should be to achieve high acceptance during final inspections and walk-downs.

This effort should include the following:

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a. Increase the involvement of first-line supervision h i.: I daily activities of the craf tsmen. Develop methods w ,

evaluate the effectiveness- of first line superiision M ensuring that construction errors are reduced,

b. Integrate. the assignments of field: engineers and :he as - ,

built group to ensure construction is in accordance with  ;

design requirements.

Response

in order to upgrade the control of hanger installation, a tea m l approach to in-process inspection was implemented in Decembe- -

1983. For each pipe support crew foreman, one QC inspector and one j fleid engineer have been assigned. Application of additional nanpow . ' '

er resources was completed in January 1984, a in addition, inspectors are now rotating between in-process and final ,

inspections. Also, personnel performing as-built inspections are no'w working directl

. reports (NCRs)are y with the - QC final inspectors. Non-conformance being trended to further upgrade the installations d' prior to the as-built inspections.

Since the INPO evaluation, a Posted Areas 1.og showing the rejection -

rate of in-process inspections has been instituted. The log has increased the importance '.nd awareness of doing the work right the first time.

Finding (CC.4 3) The following Good Practice was noted:- A superplasticizer. is used in, concrete mixes to improve the placement of concrete -in congested '

structures. The possibility of voids is greatly reduced, and the cost benefit in labor and equipment savings is good.

Finding (CC.4-4) The organization and implementation of the ASME code stamping program need improvement. Responsibilities for the program are not defined clearly, and a schedule for stamping activities has not been s developed. As a result, documentation packages are very complex, have errors, and cause confusion for the craftsmen; mechanical inspections are performed months af ter construction is completed; and the as-built process yields rejectable items very late in the schedule.

Recommendation Evaluate and improve the methods and procedures for performing ASME code work. Reduce the complexity of the process control documents, and sequence the inspections'to be integrated with the construction work process in a timely manner. Assign responsibility

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to ensure the code stamping program is, coordinated, and deve'.o; a !

detailed integrated schedule that includes the designer, installe , d '

the ANI activities.

Response

Following the INPO evaluation, the ASME Code Stamping Pr: tram .

was changed to reflect UE&C/QA's responsibility for the leadersmp in  !

the Stamping Program. UE&C provides the vendor-supplied Document Index for the N-5 Data Reports. The NA certificate holders for pioing and !&C are responsible for developing the s_upplemer. ting N-5 Data =

Reports for their scope of work, including the supporting installation data. There will be one final N-5 Data Report for each class of each- . '

piping system.

The project is working to reduce the complexity of the process control documents and streamline the documentation process. Changes have been made to the UE&C as-built program, the UE&C Site QA~

Program, and the Piping Contractor's Nuclear QA Manual. There changes will also control as-built final inspection and the developret

of the N-5 Data Reports. Additional debugging and training of a people involved is required and will be accomplished by March 1984  !

A schedule has been developed for code stamping activities, is t ;

currently under review, and will be in effect by March 1984. , l QUALITY WORKMANSHIP '

. PERFORMANCE OBJECTIVE: The project should focus its efforts on achieving quality

, through the work force, with verification by the inspection force.

J Finding (CC.5-1)- Improvement is needed in the project's efforts to achieve a quality L

installation the first time. On several occasions, first-line supervisors-were directed to place emphasis on specific task completion without sufficient consideration of quality prerequisites.

Recommendation Implement a program with-all project contractors, for all levels of i supervision, that places increased emphasis on quality the first time.

implementation should concentrate on consideration of' quality; l prerequisites during task-planning activities. Senior management l

- should be involved in program development ' and should monitor l Fogram effectiveness through a planned surveillance feedback 'l program.

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Response PSNH will accept no compromise of quality in the construction of I l< Seabrook Station. <

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A pre-installation verification walkdown of pipe supports and baseplates-will be instituted as the best method of preventing not only errors, but also excessive rework. This program will be provided with the necessary manpower resources.

SEABROCK 3 33 r PMe 25  ;

y Major. contractors will institute a P)sted Areas Log, or equin;e-t.

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< m showing in-process rejection rates, in a effort to increase the awareness of the importance of achie<ing quality the first time. TNs-should make. first-line supervision c:gnizant of and accountaste f or -i work being performed by craf t personnel. Area superintencents should be able to focus their attentien in deciding whether personnei .;

retraining or replacement is necessary.

A trending program of NCRs and arca-log rejection information will

= also. be initiated. This trending report will be evaluated by senior "

construction management.

These actions were implemented in anuary 1984  !

.i TEST EQUIPMENT CONTitOL '

PERFORMANCE OBJECTIVE: Measuring and test equiwnent t should be controlled to sup-:

Port construction testing effectively. i Finding (CC.7 1) The implementation of the program for the control of on-site mea ~-

suring and test equipment does not meet some project requirements.

Weaknesses exist in the following areas:

c. staffing and training cf personnel in the UE&C gauge facility

b. the evaluation of off-site calibration services c.- the review of calibration intervals' following adverse . '

. calibration results f

Recommendation Implement a program to provide formal training in calibration -

procedures and equipment to gauge facility . technicians. Ensure-records of training include objective evidence in the L areas of l knowledge. skills, and experience to support the individual's grading.

Extend the scope of the program for qualifying off-site calibration i services to include adequate reviews of personnel, equipment, proce-_ 1 dures, and records that demonstrate compliance with the project QA q program. Review the calibration program intervals for each type of equi abi!!pment against thedeviations ties of equipment calibration histories to ensure that low prob-exist.

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Response Two technicians will be certified and added to the staff. The training j and certification program will be enhanced and will include formal documentation of training, including the results of general, specific, 1 and practical examinations. This will be implemented by March 1984 l

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. SE ABROOK ';)sr '

Page M UE&C Corporate . QA personnel will re-evalua te : the results M calibration f acility: surveys to ensure that essential attributes of t e vendor program . regarding M&T equipment were addressec adequately. The re-evaluation will be completed by March 1936 t A program for review of equipment calibration intervals for each t pe '

of equipment agalnst the calibration history to ensure that. lax !

probabilities of equipment deviations exist, is in effect, and is being implemented. UE&C will evaluate the effectiveness of all contractor i M&TE programs and wllt initiate corrective actions for any programs 1 found inadequate. This action will be completed by February 1934 -i s

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SE ABROOK 'iM M Page r PROJECT SUPPORT INDUSTRIAL. SAFETY t PERFORMANCE OBJECTIVE: The construction site industrial safety program should  ;

, achieve a high degree of personnel safety.

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F Finding (PS.1-1)

Added emphasis is needed by STD personnel'in following established i industrial safety practices during the conduct of testing activities.

Areas of concern include enclosed space entry and chemiest. '

handling. More attention is needed to control hazhrds created by construction activities, i

Recommendation implemen t measures, such as training and increased supervisory follow-up, to ensure that STD personnel follow safety rules during i testing activities. l

Response

Because of the increased exposure to activities that have a safety ~ !

concern and in light of the items noted, all certified test personnel :

were retralned by the site Safety Department in December 1983.  ;

In the future, safety retraining will be conducted as part of the test .

personnel recertification process. This training will be conducted by- i site-quall!!ed training instructors.  !

In order to improve STD's communication with the site safety groups,-. 1 a representative of the site Safety Group attends the STD's Plan-of- '

the-Day Meeting. At these meetings, Startup and Safety are able to =

communicate to each other their respective needs. This program has H been implemented.

f PROJECT PLANNING PERFORMANCE OBJECTIVE: Project plans should ensure completion of the project to the highest industry standards by identifying, interrelating, sequencing, and implementing the tasks of the project organizations.

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L Finding (PS.2-1) Iniprovement is needed in project planning and scheduling. The l existing master baseline schedule has not incorporated some impor-tant segments of work. Some activity durations are not realistic. l L. Recommendation Management should review the master baseline schedule to ensure l

that all activities have been incorporated and that existing activity.  ;

durations are -achievable. Rework (at the level the project is l experiencing) should be factored into schedule activities. Special l L

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' Pa.;e M attention should be given to scheduling major actitities such as t;e.

hanger, and N Stamp process.

Response

Management is currently reviewing project planning, scheduling, sn:

the mechanism for mear ring construction progress against see schedule. This reassessmer., will provide the inputs needed to produce a baseline schedule. The baseline schedule wi!! address concerns wen as rework, pipe and hanger installation, de,cument reviews necessary to support Startup activities, and the N. Stamp process. The baseli .e schedule will receive the highest level of management restew to ensure that all parameters have been considered and included. Mi performances by personnel and organizations will be evaluated against this baseline schedule. The baseline schedule will be available by March 1934.

Finding (P5.2 2) Significant improvement is needed in the planning of daily activities and developing weekly schedules. Insufficient planning exists in the fo!!owing areas: .

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a. timely availability of materials

b. timely availabl!!ty of design information

(: c. Identification of construction interferences before starting  !

a job

d. constructibt!!ty review prior to starting a job j Recommendation Develop detailed dally work plans prior to preparing the weekly or bi-weekly schedules. Provide the foreman with complete construction drawings and design information consistent with both daily and weekly schedules. Require increased Verdination among supervisors, field engineers, p'a.mers, and craf t Dromen to ensure that the scheduling process includes the fo!!owing elements:

a. foremen reviews of construction drawings and the required design information

b. availability of materials

c. veri!! cation of constructibility by foremen or the' appro-prlate levelin the construction organization

d. more timely ldentification and resolution of interferences Response Weekly schedules will be developad by each contractor's area supervisor (s), planners, and field engineers. These schedules will be broken down into daily work plans that will identify items needed to be worked to support long term (critical path) and short term (BlP e

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Turnover) priorities. Status of necessary support acti/ities v.5 as s engineering, materials, and contractor interfaces will be i:entified :- ,

these schedules. The support activities will be communicated to : e '

appropriate organizations to help them set priorities for the:r I activities, including the availability of materials in accordance utt5 '

the latest design information. The Construction \ tanager sna:1 l

coordinate these activities to ensure timely and orderly comp!etion of the work.

. The piping and hanger effort was in full operation in January 1934, with the other major discip!!nes to fo!!ow by Pebruary 1954.

A front-end Walkdown Program, to be closely monitored by the YAEC ,

Project Manager, was instituted and implemented in January 1934 This program will identify construction interference and determine j overall constructibility.

8 DOCUMENTATION MANAGEME!si +

PERFORMANCE OBJECTIVE: The management of project documentation should support the effective control and coordination of project activities and provide a strong foundation ,

for the documentation /information requirements of the plant's operational phase.

Finding (P5.6-1) The records management systems do not always identify the current status of project documents. Numerous instances were found where the Drawing Task System (DTS) did not reflect the actual status of-drawings in the Document Control Center. In many cases, the dis- ,

crepancies were long standing. Examples were found in the electrical area where the Project Change Notice System (PCN II) listed changes '

already incorporated into the applicable drawings.

Recommendation Re-indoctrinate engineerin;; and administrative personnel regarding  ;

their responsibilities for maintaining current and accurate DTS anci ,

PCN II docuinents. Determine if broadened audits should be perf orm.  !

ed in specific disciplines showing high error rates. Perform follow up reviews to ensure this area is receiving appropriate attention.

Response

The training program for design and administrative personnel h3ving  ;

responsibilities within the program has been expanded. Training wil! ,

Inc.ude the procedures for inputting current data and the require- I monts for maintaining an updated and accurase revision status of the l Records Management System. This trainin initiated in 1 December 1983 and will be an ongoing program.g wasIn addition, pro dures have been restructured to simpt.fy the inputting of data to the I Drawing Task System and to reduce the "tum-around" time.

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A high level of audit activity was undertaken curing the last tw :

quarters of 1933 to identify Records Management System det;;;e -

cies. Recent changes to AP-15 strengthen and emonasi:e t .e requirements for overall recores management (PCN-!!) acesraev.

Some deficiencies were found, and corrective actions have been 2-t will continue to be taken. Regularly scheduled audits of the system

' are undertaken on a continuing basis, the frequency of which ;s predicated upon audit findings. i Finding (P5.6-2)

Craftsmen and engineers working in the field are not always using the latest available revision of the applicable drawing or procedure.

There have been delays in the distribution of the construction docu-ments to some organizations and departments. The revision status of some construction documents cannot always be determined from the numbering or coding systems employed by the originating organiza--

tions.

Recommendation Improve controls over construction drawings and documents on site to -

ensure timely distrlbution of the latest applicable revisions to and the effective tracking and retrieval of superseded copies from all working levels.

Review document control programs to ensure they include all con-struction dxuments that impact on construction, installation, startup, and quality-related activities, and that their status is traceable using available document references.

Response The project will evaluate the controls for construction document I distribution and will initiate changes to improve distribution efficien-cy. This action will be completed by March 1984. The project will continue to monitor this area and take corrective action when required. The project will emphasize to all document control organizations the need for fast and effective distribution of approved construction documents, i

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TRAINING MANAGEMENT SUPPORT PERFORMANCE OBJECTIVE: Management should ensure that an effective program exists I for indoctrination, training, and qualification of personnel involved in the project. l Finding (TN.l.1) Management needs to provide increased support of training pro-  !

grams. Training of employees in spect!!c job procedures is limitec anc l

sometimes not performed. l.ess than 10 percent of the site super- ,

visors have received the supervisory development training off ered by l PSNH. ,

Recommendation Develop training to ensure that supervisors and craftsmen are  !

knowledgeable in the acceptance standards for the tasks they are I performin;g. Increase the emphasis in training supervisors in their responsibl.itles and developing thei" supervisory skills. Evaluate work -

presented for inspection, and li':,, rove training based upon the acceptability being achieved for this work.

l Response A committee composed of representatives from all contractor '

training departments has been formed. This committee meets weekly. Each contractor representative will identify areas requiring '

training by implementing a needs analysis based on job performance.

in addition, an ongoing subcommittee has been formed to develop a process for measuring and evaluating the effectiveness of site-wide training. This evaluation will be designed to measure and evaluate (1)

Instructor proficiency (2) training session content, and (3) relevance and impact on craft and supervision. Revisions to the training  ;

program will be implemented based upon the findings of the commit-tee. The overall program will be implemented by February 1984.

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To supplement supervisory. training, we are adding one instructor dedicated to the supervisory development training program. All site supervisors will be trained in the development and appilcation of  !

supervisory skills by the end of 1984.

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QUALITY PROGRAM IMPLEMENTATION . 1 PERFORMANCE OBJECTIVE: Quality assurance and quality control functions should be l performed in a manner to support and control the quality of the project activities. .

Finding (QP.2 1) The latest revisions of techrdcal documents are not always used as the basis for performing quality surveillances. Outdated checklists are 1 being used by Quality Assurance personnel from Yankee Atomic '

Electric Company. The check!!sts do not incorporate the require. ;

ments of revised specifications affecting electrical and instru.

mentation activities. j Recommendation Ensure that all quality surveillance checklists are compatible with the !

latest applicable revisions of the relevant construction documents. i Provide for early distribution to and review by QA of construction documents and revisions thereto that are subject to quality surveit-lance.

Response The need for assurance that master checklists are updated in a timely manner will be emphasized to surveillance discipline supervisors.

Individuals conducting surveillances will be directed through training and procedural changes to review their surveillance checklists prior to conducting the surveillance. Their reviews will ensure that surveil-lance check!!sts are written against the latest revision of the -

applicable document, and if they are not, describe the corrective action to be taken. The training was completed by December 1983.

The changes to procedures will be made in conjunction with an overall enhancement program to be completed in February 1984 The Surveillance Supervisor will perform a monthly review of tne

• surveillance checklists to verify they are up to date.

The above actions should ensure a timely update to the master check!!sts and that Quality Assurance personnel are performing surveillances to the latest revision of construction documents, l

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Finding (Q P.2-2) 1he implementation of the program for controlling non-conforming l equipment needs improvement. Interfaces between organizations identifying non-conformances and organizations that are delegated i responsibility for rework or repair are of ten ineffective. The following problem areas were noted:

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a. Many significant non-conformances identified on reces. z inspection are not being dispositioned and closed-out :!

the responsible organization, as required,

b. Equipment is being insta!!ed in a non-conforming c:nci-tion, and essential rework and repairs are being def erred.

Recommendation Review the interfaces amonk all on-site organizations to ensure c: ear definition and documentation of quality assurance and quality control responsibilities with particular ref erence to disposition, close-out, and documentation of r on-conformances.

Implement reviews of NCRs by responsible organizations to protnote timely disposition, close out, and verification of conformance to the  ;

satisfaction of the initiating organization. '

Response The following actions have been taken to improve the timeliness of disposition of NCRs:

a. The site NCR program has been revised extensively to ,

streamline document flow by eliminating unnecessary in. I line review and approval participants.

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b. The dispositioning and timely resolution of NCRs consist-ent with project schedule goals will be expedited. Project directives have been , issued to Engineering and Construc-tion organizations to disposition and correct non-conformances within specified time frames.

CORRECTWE ACTIONS PERFORMANCE OE3ECTfVE: Conditions re resolved in an effective and timely manner. quiring corrections or improvements sh Finding (QP.3-1) Measures to preclude damage to or potential misuse of materials stored in and around the site often are insufficient. Problems with the storage of ASME materials, reported in the self-initiated evaluation and in many subsequent quality surveillances, have not been corrected.,

Recommendation Determine that project QA programs adequately identify and define responsibilities for the control and storage of materlats within and around the site buildings. Re-emphasize to the responsible managers and supervisors the importance of maintaining the identity and in-tegrity of materials awaiting installation and the need to react qu,ckly and positively to audit or surveillance findings that reflect improper implementation of these responsibilities.

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• SEASR Nx ".3t3 Page ).

Response

in November 1933, management personnel of all project organ::st.: s were redirected relative to each organization's responsibiht.es n : e areas of housekeeping, material control, cnd storage. In addit:en to the controls applied by the contractor's QA/QC programs, start: g January 1984, each contractor assigned a management representati<e to continuously evaluate the effectiveness of the program and througt management actions ensure timely closeout of identified conditions.

The effectiveness of this program will be evaluated through YAE0 QC surveillance and audit program.

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P SEABROcx un), ,

Pye n TEST CONTROL TEST PROGRAM PERFORMANCE OtL1ECTIVE: The test program should include construction and pre-operational testing necessary to confirm the plant's design and capability to operate as intended. _

4 Finding iTC.I.1) The protection and maintenance of some equipment tumed over to the Startup Test Department (5TD) need more attention. Areas of con.

cern include electrical equipment cleanliness, area cleanliness, and '

identi!! cation of needed maintenance.

Recommendation Implement the STD Preventive Ma!ntenance Program on all equipment turned over. Upgrade area cleanliness in those areas occupied by equipment turned over. Take appropriate steps to ensure that the program to identify and perform maintenance is implemented fully.

Response Until recently, the protection and maintenance of equipment turned over to STD has been a shared responsibility between Construction and STD. STD has implemented measures to take immediate -

responsibl!!ty for the preventive maintenance program for turnover equipment and to take sole responsibility for cleanliness of equipment and the areas around the equipment. The transition of these programs will be completed by March 1984.

STD management has also committed to increasing their walkdowns and Inspections of equipment and areas under STD jurisdictional r control These programs have already been implemented.

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TEST PLANNING PERFORMANCE OBJECTIVE: Testing activities should be controlled effectively through the use of detalled plans and schedules.

Finding (TC.3-1) The planning and scheduling of day-to-day test activities needs improvement. Added emphasis is needed in the use of 'ommitment dates and priority assignments.

Recommendation Upgrade planning and scheduling to include appropriate commitment dates and priorities needed for day-to-day testing activities. When

,,cheduled activities do not occur, perform management follow-up to identify and correct the root causes of delays.

Response The use of commitment dates and priorities has been incorporated l Into the planning and scheduling of STD activities. This has been an i

._.,._-,....._,.,_,y, _y.,,.- , - - . _ _ . ,, , , - . , _ ,

1 EABROCKUnp Page 34 4 ongoing philosophy for the Plan-of the Day Meeting and has been re-emphasized in the implementation of this meeting. In addition.15e  ;

Project Completion System has Seen expanded to include post-  ;

turnover items needed to cupport ifD activities and prioritize these '

items to support the testing schedule. Delays noted in these meetings i are brought to management attention through distribution of meeting minutes and commitments. 1 l

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TESTING PERFORMANCE AND DOCUMENTATION l i

PERFORMANCE OBJECTIVE: Performance and documentation of the test program should ensure that test objectives are achieved and that test results are reviewed and documented properly.

Finding (TC.6-1) Closer attention to accuracy and completeness in making changes to some procedures and instructions is needed. Some fle' changes to procedures are not thoroughly incorporated, and some administrative - 1 Instructions are overlooked.

Recommendation Improve the review of test activity instructions and procedure changes. Stress accuracy, completeness, clarity, and adherence to administrative requirements.

Response The deficiencies in implementing the field change procedure have been reviewed with the test engineers involved. General training of all test engineers will be conducted to re-emphasize the requirements

• of this program. This training will be completed by March 1954 and will be ncluded in the recertification program. Current implementa-tion is reinforced through STD in-process reviews of test procedures and documentation. In addition, this area is subject to surveillance activities by Quality Assurance.

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Finding (TC.6-2) Significant improvement is needed in managing the systems tumover program. The following are examples of problems that have caused delays in system turnover i

, a. Some incomplete work items are not being identified, and ,

their significance is not always evaluated. '

b. System reviews are not conducted early enough to resolve problems prior to scheduled turnover dates.

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SEABROCK <1 psp '

Page r i c.- Assignments of accountability and fulfillment of commit-i i

ments are weak.

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d. Some materials and procedures are not availab!e to support turnover.

Recommendation Provide increased management attention to ensure improvements in the systems tumover program. Include the following elements in the  ;

program upgrades

a. System completion reviews should identify all incomplete items. Incomplete items should be evaluated f or impact on subsequent test activities.

b. Problems should be identified and resolved in a timely manner to support tumover dates,

c. System completion commitment dates that are not met should receive management review for root cause, impact, ,

and corrective action to prevent recurrence, l Response The Systems Tumover Program has received considerable manage.

ment attention and is one of the major areas that will be included in +

the overall project management assessment. The results of the assessment will be directed toward providing a better management grasp and resolytlon of the problems associated with the Systems  ;

Tumover Program.

Efforts are underway to improve the timeliness and accuracy of the open items that must be completed to achieve system turnover. The project has systems in effect to define action responsibility.

Management action is being taken to improve ,

scheduled system completion dates. This wl!! performance include in meeting clear definition of responsibility and management emphasis on accountabt!!ty. This will be accomplished by April 1934.

1 Finding (TC.4-3) Increased effort is needed to ensure a&erence to tagging programs on systems tumed over to STD. Items noted include a danger tag viola-tion, unauthorized construction, and use of uncontrolled information tags. +

l Recommendation Implement a program to erisure personnel in all organizations have a continuing understanding of STO tagging programs. Supervisory and management attention should be directed to ensuring programs are followed, institute a program to controlinformation tags and labels

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SEABROOK (1)S P t

Page 33 on turned over erluipment. Consider program improvements descr.tet in the following INPO Cood Practices:

a. OP-203, " Procedures for the Protection of Employees Torking On Electrical and Mechanical Components (Tag-outs),

b. OP-207," Control of Operator Aids"

c. OP-208," System and Component Labeling" l

Response

Project notices have been distributed by Construction Management Group to all contractors to re-emphasize the requirements of safety tagging. The visibility of the Safety and Jurisdictional Tagging programs has been increased through the use of site displays depicting the various tags and at craft "gangbox" training sessions. The use of i uncontrolled information tags and the proper use of safety tags on startup equipment will be controlled through increased walkdowns and 4 inspections by STD management. At the request of the Owner's Construction Management Group, STD and Construction Department managers are reviewing all safety tagging procedures used at Seabrook Station. This review was completed in January 1934 and

" changes implemented by February 1984. During the review, the - :

beneficial aspects of INPO Good Practices will be incorporated.

Finding (TC.4-4) Improvements are needed in the STD lif ted lead and jumper program.  !

Some procedural requirements are not fo!! owed, and periodic reviews are performed Infrequently.

Recommandation Provide periodic training and supervisory follow-up on adherence to l the STD lifted lean and umper program. Consider improving periodic  !

reviews, as sug  !

Bypass, Jumper,gested in INPO and Lifted Lead Control." Good

- Practice OP-202, " Temporary 3

Response A program to review the completeness of current inactive lif ted lead and jumper forms was implemented by the Technical Support Group in December 1983. The review of these forms will constitute an on--

going activity. General training of all test engineers will be conduct-ed to emphasize the requirements of the lif ted lead and jumper program by March 1984. STD will review the STD Lif ted Lead and Jumper Program in light of Good Practice OP-202, and beneficial aspects will be incorporated by March 1944.

Implementation of the lif ted lead and jumper program will be  !

monitored by supervisory personnel in the field during testing activities.

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