ML20085L360
| ML20085L360 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 09/30/1983 |
| From: | TORREY PINES TECHNOLOGY |
| To: | |
| Shared Package | |
| ML20085L363 | List: |
| References | |
| GA-C17258, GA-C17258-V01, GA-C17258-V1, NUDOCS 8310240178 | |
| Download: ML20085L360 (25) | |
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1 GA-C17258 l INDEPENDENT CONSTRUCTION REVIEW OF
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MARBLE HILL NUCLEAR GENERATING STATION l UNITS 1 AND 2 l
l VOLUME 1 EXECUTIVE
SUMMARY
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Prepared for l
i Public Service Indiana l
l GA PROJECT 2485 SEPTEMBER 1983 C OLOGY A Dvson o' G A Technologies Inc. -
"BA!!8aK"o888826 A PDR
GA-C17258 INDEPENDENT CONSTRUCTION REVIEW 0F MARBLE HILL NUCLEAR GENERATING STATION UNITS 1 AND 2 VOLUME 1 EXECUTIVE
SUMMARY
Prepared for Public Service Indiana SEPTEMBER 1983 J bY TECHNOLOGY A o.wison of GA Technologies Inc.
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FOREWORD This final report is presented in three volumes:
Volume 1. Executive Summary Volume 2. Program Results Volume 3. Potential Finding Reports Volume 1, Executive Summary, is a complete overview of the program, the work performed, and the major conclusions drawn.
Volume 2, Program Results, provides a thorough discussion of the entire program. It describes the program organization, the actual work performed, the questions raised during the review, the resolution of these questions, the final conclusions associated with each part of the program, and the overall program conclusions.
Volume 3, Potential Finding Reports, is a compilation of all of the Potential Finding Reports initiated during the review, the Corrective Action Plans for the Findings, and a review of those Corrective Action Plans. Volume 3 does not include progr.sm discussions, a description of the work, or any conclusions.
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- 1. INTRODUCTION Torrey Pines Technology (TPT), a Division of GA Technologies Inc.
(GA), was engaged by Public Service Indiana (PSI) to conduct an independent review of the construction of Marble Hill Nuclear Generating Station Units 1 and 2, including the quality assurance organization and PSI management policies toward quality assurance. This is a final report for this pro-gram, which began in June 1983. At the time of this review, Unit I was approximately 50% complete and Unit 2 approximately 25% complete.
[ The program was structured to evaluate the following:
e Adequacy of the QA organization and whether the attitude of PSI management toward QA would promote a quality attitude among those performing and checking the construction so that the high stan-dards expected of the nuclear industry would be maintained.
e Control of required design changes by PSI upon receipt from the architect-engineer through construction of hardware.
e Conformance of construction of the Marble Hill Nuclear Generating Station to engineering documents.
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The Marble Hill Nuclear Generating Station is located on the Indiana shore of the Ohio River, approximately 30 miles northeast of Louisville, Kentucky. It is a two-unit plant with Westinghouse 3425-MW(t) reactors and Westinghouse turbine generators with a net output of 1132 MW(e) each. The
) project is a replicate of Commonwealth Edison's Byron and Braidwood Sta-J tions. Sargent & Lundy Engineers is the architect-engineer. PSI is the constructor.
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The program reviewed the activities of PSI, Sargent & Lundy Engineers, Westinghouse Electric Corporation, Newberg Marble Hill (Gust K. Newberg Construction Company and Gust K. Newberg, Incorporated, Joint Venture), and Cherne Contracting Corporation. More than 2,100 documents were reviewed or used in the review, and more than 13,000 checks were performed on the implementation of procedures and the verification of hardware. Over a four-month period, approximately 200 manweeks of effort were applied to this program.
This report consists of three volumes: Volume 1, Executive Summary; Volume 2, Program Results; and Volume 3, Potential Finding Reports.
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- 2. DESCRIPTION The program consisted of five review tasks, a sixth task dealing with L
the procer, sing of Potential Finding Reports, and a final task covering program planning, management, and report preparation.
Task A addressed the PSI QA organization and PSI management policies toward QA. It covered the organizational level and status of the QA Department, the authority and responsibility of key QA personnel, access by QA to upper management, QA involvement in project activities, and the involvement of PSI management in QA activities.
f Task B addressed the control system used by PSI management for (1)
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changes to approved design documents, (2) design changes initiated by Sargent & Lundy Engineers, and (3) design changes initiated in the field.
The adequacy of the control system and the effectiveness of its implementation were evaluated.
Task C was designed to verify that hardware of safety-related systems
( and structures was constructed to the engineering requirements depicted by the engineering drawings and specifications. Selected mechanical systems, piping, pipe supports, associated equipment, selected civil structures, reinforced concrete, and structural steel were verified. In process con-struction activities were witnessed.
Task D addressed the adequacy of selected American Society of Mechan-l ical Engineers (ASME) piping welds and concrete structures by testing and inspection in conjunction with review of test records. Specific welds were visually inspected, radiographic film was reviewed, and in process radi-ography of welds was observed. Concrete buildings were visually inspected for flaws and strength tested using a rebound hammer. Concrete cylinder 3
h strength tests were verified by comparison with rebound hammer test results.
Task E was designed to verify compliance with applicable procedures and specifications of ASME piping material certifications, concrete test and inspection records, welder qualification records, and safety-related equipment maintenance and storage records.
Procedures and checklists wcre prepared for the execution of each task in order to establish a uniform and comprehensive method for conducting the verification, recording data, and documenting the work.
Whenever a question was raised during the review that the reviewer perceived to be a valid deviation (as defined in the applicable project procedure), a Potential Finding Report was prepared. Each Potential Find-ing Report was reviewed and evaluated through several steps and ultimately classified as Invalid, an Observation, or a Finding. A Finding is a devia-tion that potentially could result in a substantial safety hazard or an indication of a repetitive or generic deviation that could potentially create a substantial safety hazard. An Observation is a deviation that could not create a substantial safety hazard. A Potential Finding Report is classified as Invalid if additional information was provided that elim-inated the concern subsequent to the initial issuance of the Potential Finding Report. Each Observation and Finding is discussed in the appropri-ate section, and its implication is discussed in the task conclusion.
PSI initiated a Corrective Action Plan for each Finaing using a formal procedure established before the review that identified the cause of the deviation, steps to be taken to remedy the deviation, steps to be taken to identify similar deviations, and steps to be taken to prevent the recur-rence of the deviation. TPT reviewed and commented on the Corrective Action Plan prior to release of the final report.
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- 3. QUALIFICATIONS TPT, a division of GA, is qualified to review the construction of the Marble Hill Nuclear Generating Station for PSI because GA has been actively
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engaged in the nuclear power industry since 1959 and has a large staff of capable, experienced, and technically trained personnel. In addition, GA operates under the first Nuclear Regulatory Commission-approved QA program and has acknowledged expertise in QA. This independent construction veri-fication for PSI was conducted under the provisions of this QA progra.a.
( GA is a privately owned center for diversified energy research, development, and engineering. Activities have emphasized the creation of advanced systems of power generation and energy conversion.
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GA employs approximately 1900 people, of which 900 are degreed pro-fessionals, including 485 with advanced degrees. Many of the technical staff are recognized leaders and experts in their fields. The staff is highly experienced in the nuclear field and has an extensive background in water-cooled nuclear power plant work.
Prior to this construction review of Marble Hill for PSI, TPT con-ducted other independent reviews, such as the seismic design review of San Onofre Units 2 and 3 for Southern California Edison, a construction verifi-cation review of Shoreham for Long Island Lighting Company, a QA evaluation and design review of Palo Verde for Arizona Public Service Company, and a system design review of Waterford 3 for Louisiana Power and Light. TPT has also just completed a management review of the Zimmer Nuclear Power Station for Cincinnati Gas & Electric.
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GA and all its personnel on this program are completely independent of PSI, the managing and operating agent for participants in the Marble Hill
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Nuclear Generating Station project. Revenues from PSI are not, and have not been, a significant portion of GA's revenues. No person working on this program has a significant financial interest in PSI, nor does any person have any family member who is presently employed by PSI or who is engaged directly or indirectly in the design or construction of Marble Hill Nuclear Generating Station Units 1 and 2. (
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- 4. RESULTS 4.1. EVALUATION OF QA ORGANIZATION AND MANAGEMENT POLICIES TOWARD QA, TASK A Task A evaluated the organizational status of QA on the Marble Hill project, reviewed PSI management policies which affect QA, and assessed the degree to which those policies help to assure an effective QA program.
Task A was accomplished by (1) conducting interviews, (2) determining the organizational level and status of the PSI QA Department, (3) reviewing job descriptions and procedures relevant to defining the authority and responsibility of key QA personnel, (4) evaluating the access of the PSI QA Department to upper management, (5) evaluating the involvement of the PSI QA Department in project activities, and- (6) evaluating management's involvement in QA activities.
( During the execution of Task A, 24 PSI personnel from both corporate headquarters and the Marble Hill site were interviewed. Also, 23 addi-tional PSI personnel were surveyed at the Marble Hill site. More than 120 pertinent documents or sets of documents were examined, requiring five manweeks of effort.
The organizational level and status of the PSI QA Department were found to be consistent with the requirements for an effective QA program.
The QA Department had access to PSI upper management who, in turn, were aware of QA program status. The QA department was found to be adequately staffed and to interface at an appropriate level with counterpart organiza-tions. The department is actively involved in surveillance of Marble Hill I
QA activities and appears to have sufficient authority to carry out its responaibilities.
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One Finding resulted from this task. This Finding addressed manage-ment audits of the QA program. The reviewed audits, in TPT's opinion, did not adequately assess the effectiveness of the QA program, and one audit did not assess compliance with codes, standards, and Regulatory Guides.
A Corrective Action Plan was formulated by PSI to address this s Finding. The Corrective Action Plan requires a change (which has been effected) in project management procedures to ensure that a more substan- ,
tive statement is made about QA program effectiveness and that compliance to codes, standards, and Regulatory Guides is checked in the future. A check for similar problems was not necessary, since all mana'gement audits )
of QA made over the past three years were reviewed by TPT.
With the correction of the one isolated deficiency, the review in Task A leads to the conclusion that the PSI QA organization and the PSI manage-ment policies towr.rd QA are properly designed and implemented to ensure an effective QA program.
4.2. CONSTRUCTION DESIGN CONTROL, TASK B This task reviewed and evaluated the PSI system for control of approved design documents at the Marble Hill site, Sargent & Lundy-initiated design changes, and field-initiated design changes. It also evaluated the implementation of the system and its effectiveness in assuring that the approved design of safety-related components is used in construction.
Task B was accomplished by (1) a review and evaluation of the PSI Marble Hill systen and procedures for control and issuance of approved design documents, design changes, and field design changes against thy requirements of 10CFR50, Appendix B, and ANSI N45.2.11, 1974, and (2) a review of selected design documents, change notices, and field change documents for compliance with applicable procedures.
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l Current revisions of design control manuals and procedures were iden-tified and reviewed to determine whether these documents met the require-ments of 10CFR50, Appendix B, and ANSI N45.2.11, 1974. Design control records for 97 drawings, 59 Field Change Requests, 8 specifications, and 18 Engineering Release Authorizations were reviewed to determine if the above procedures were implemented. Including the manuals and procedures, more than 200 documents were examined and more than 1900 individual checks were
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made on those documents, requiring eight manweeks of effort.
One Observation resulted from this task. This Observation dealt with design review responsibilities. PSI has delegated design review to Sargent
& Lundy Engineers. However, the PSI project procedures were unclear on this point. Even though the procedures were unclear, no substantial safety f hazard was created. PSI intends to clarify their procedures based on this Observation.
Based on the review performed in Task B, the construction design control system and procedures are concluded to be adequate and properly implemented.
( 4.3. PHYSICAL VERIFICATION-WALKDOWN, TASK C
( This task determined whether the physical installation of selected portions of safety-related mechanical systems and civil structures of the Marble Hill Nuclear Generating Station Units 1 and 2 conform to the engi-neering design drawings and tpecifications. Approximately 100 manweeks of effort were applied to this task.
Due to the construction stage of Marble Hill Nuclear Generating Station Units 1 and 2 (currently approximately 50% and 25% complete, respectively), the scope of this task was limited to the verification of safety-related mechanical systems and structures which were furthest along in completion status. Electrical and instrumentation systems were not
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criteria which required inclusion of features supplied, installed, or constructed by major contractors, covering a range of sophistication in construction methods and covering a wide range of equipment, structural types, and complexity to provide balance in the review.
The physical verification was performed primarily on Unit 1. Features were selected from Unit I which fully satisfied the selection criteria; 4 approximately 25% of similar features were verified on Unit 2.
Three levels of verification were used in the review, as follows:
Level 1: Verify overall system installation as defined by the piping and instrumentation diagrams and major safety structures as depicted in the structural layout drawings and specifications.
Level 2: Verify mechanical and structural component installation in terms of identification, location, orientation, and configuration, as depicted by the design drawings, specifications, and related equipment documents.
Level 3: Verify installed details of the mechanical systems and structures, such as detailed dimensional checks of piping and pipe supports, details of structural members, welds and bolt torques at connections, details of tendon anchors, reinforcing steel details, and concrete placement.
4.3.1. Verification of Mechanical Systems Features were selected and verified in four safety-related mechanical systems: (1) Reactor Coolant System, (2) Auxiliary Feedwater System, (3) Component Cooling Water System, and (4) Residual Heat Removal System.
These systems were the most advanced in construction and contained a cross section of mechanical features which satisfied the selection criteria.
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l The physical verification of mechanical equipment and piping was organized into 52 walkdown packages, involving more than 630 reference f documents. These packages consisted of 87 levels of verification (i.e., 5 level 1,-61 level 2, and 21 level 3). The verification at levels 2 and 3 covered 251 items of piping, pipe supports, and mechanical equipment. More
( than 4500 individual checks were made in the mechanical walkdown, resulting in two Observations and no Finding.
The first Observation pointed out a deviation in the location of a rigid pipe restraint. Investigati.on by TPT, including independent pipe-stress calculations based on the as-built location, determined that the f as-built restraint location does not cause pipe or support stresses to exceed ASME allowable stresses. This support and other pipe supports installed prior to June 1982 will be reverified by Cherne; a Nonconformance
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lleport written against the support at the time would be subject to engi-neering disposition.
The second Observation pointed out an inconsistency between the design
[ requirements in the Westinghouse specification and the installation of several valves in the Component Cooling Water System. Further investiga-( tion determined that the change adding position-indication switches to the valves was required; however, over a four year period, work had not been
( started because PSI had not completed processing the required purchase order. Subsequent to the issuance of this Observation, PSI has released the required purchase order.
The results of the physical verification of selected portions of par-tially installed mechanical systems indicate that the mechanical components and piping are installed in accordance with the engineering requirements.
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4.3.2. Verification of Civil Structures Features were selected and verified in five safety-related structures.
The structures included the two Reactor Containment Buildings, the Auxil-iary Building, the Fuel Handling Building, and the Ultimate Heat Sink and were considered representative of the different types of structures at the s site. Since construction was ongoing, the verification covered both completed structures and in-process construction activities.
The physical verification of civil structures was organized into 69 walkdown packages, involving more than 200 reference documents. These packages consisted of 146 levels of verification (i.e. , 24 level 1, 39 level 2, and 83 level 3). Verification at levels 2 and 3 covered 493 items of reinforced concrete, structural steel, and cable tray supports. More than 3500 individual checks were made in the structural walkdown, resulting in four Observations and no Finding.
The first Observation concerned a minor deviation in the location of rebars at the hanger box of a removable roof slab of the Auxiliary Build-ing. Rebar locations were not dimensionally apecified in the drawing.
Subsequently, a Contractor Drawing Approval Request was issued specifying the rebar as installed. S&L approved the change request. The structural integrity was not compromised. Thus, no safety hazard was created.
The second Observation pointed out an inconsistency in connection detail between the contractor's erection drawing and the design drawing from Sargent & Lundy Engineers. The design detail shova on the engineering drawing was not constructable and was replaced with an approved alternate shown on a shop drawing. No safety hazard was presented, even though the design drawing did not reflect the as-built condition.
The third Observation pointed out a construction deficiency in as-built velded studs on embedded plates on the Unit 1 Reactor Containment 12 -
Building dome liner. Several studs were bent out of tolerance. TFT calcu-lations showed that the load carrying capacity was still adequate without
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[ The fourth Observation identified out-of-tolerance conditions on rebar spacing and minimum rebar concrete coverage. This should have been reported in a Nonconformance Report. This deficiency was found to be an isolated incident and did not affect the structural integrity of the wall, since the extent of the out-of-tolerance condition was within Sargent &
Lundy's criteria for disposition of Nonconformance Reports without rework.
The results of the physical verification of the selected portions of civil structures indicate that the structures are constructed in accordance with engineering requirements.
4.3.3. Overall Conclusions, Task C Based on the physical verification performed under Task C, the physi-cal installation of selected portions of safety-related mechanical systems and civil structures of Marble Hill Nuclear Generating Station Units 1 and 2 conforms to the requirements of engineering design drawings and specifications.
4.4. TESTING, TASK D Task D was structured to verify acceptability of ASME pipe welds and concrete in safety-related structures by performing tests and inspections of hardware in conjunction with a review of test procedures and records.
The execution of this task required eight manweeks of effort.
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ASME Piping Weld Inspection, Subtask D1 This subtask verified acceptability of ASME piping welds by reviewing inspection records and witnessing inspection activities.
All applicable nondestructive examination procedures were reviewed to s verify that they were in compliance with and met all the requirements of the applicable sections and editions of the ASME Code. A sample of 54 welds was selected from piping segments from the Task C walkdown, including ]
both field welds performed by Cherne and shop welds performed by ITT Grin-nell. Inspection records and radiographic film were obtained and reviewed
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for the selected welds. Fourteen welds were also visually examined and the results compared to the original examinations. Radiography of four welds performed by Cherne nondestructive-examination personnel was witnessed.
During this review, 442 pieces of film were examined, and over 850 individual checks were made.
One Finding resulted from this subtask. The Finding addressed a radi-s ograph with double images caused by film or x-ray source movement during exposure of the film. Industry practice requires that the double-image film be rejected and the weld raradiographed. Vagueness in the inspection procedures allowed this deficiency to occur.
s PSI formulated a Corrective Action Plan which states that the affected weld will be raradiographed and evaluated for acceptability, a statis-tically significant sample of existing radiographs will be reviewed to verify that this incident was an isolated case, and inspection procedures will be changed to prevent the acceptance of double-image radiographs in the future.
Based on the review performed in Subtask D1, when the above Corrective Action Plan is implemented, the procedures and methods used to perform the radiographic and visual examinations of ASME welds will be satisfactory and 14
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4.4.2. Concrete Inspection, Subtask D2 This subtask was structured to inspect c'oncrete in selected structures using visual inspection and rebound hammer techniques to verify if the
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structures have any major defects and if the compressive strength of the concrete meets specifications.
The concrete surface of five structures was inspected visually and tested with a rebound hammer for compressive strength at 50 locations. Ten areas were inspected and tested in the Ultimate Heat Sink of the Essential f Service Water Cooling Towers; five in the fuel storage pool of the Fuel Handling Building; 14 in each Reactor Containment Building of Units 1 and
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and seven in the Auxiliary Building. The inspection covered 25 concrete pours. One of the pours was made on December 28, 1978, before stoppage of safety-related work. The remaining pours were made between May 20, 1981 and April 21, 1983, after the stoppage. Results of cylinder strengths for
( these pours and the calibration records of the testing machine used to test the cylinders were reviewed.
During this review, more than 100 procedures and design documents were examined, and over 350 individual checks were made of those documents.
No Observation or Finding resulted from this subtask.
Based on the review performed in Subtask D2, the compressive strength of concrete met specifications in all cases and the concrete areas inspected had no significant defects.
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4.4.3. Overall Conclusione, Task D Based on the tests and inspections performed and the review of test procedures and records under Task D, the selected ASME pipe welds and selected portions of concrete structures conform to engineering requirements.
The radiographic film deviation detected in this review is considered an isolated procedural deviation which is within the limits of what can )
normally be expected in any major construction project, and the implementa-tion of the Corrective Action Plan will correct this concern.
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4.5. CONSTRUCTION DOCUMENT REVIEW, TASK E The task was structured to review ASME piping material certifications, concrete test and inspection records, welder qualification records, and safety-related equipment maintenance and storage records to verify compli-ance with applicable specifications and code requirements. The execution )
of this task required 13 manweeks of effort.
s 4.5.1. ASME Piping Material Certification Review, Subtask El This subtask reviewed piping and weld filler Certified Material Test Reports for compliance with the applicable specification requirements.
More than 190 Certified Material Test Reports were reviewed, and over 1300 individual checks were made of selected ASME Code Class 1 and 2 items )
in five safety-related piping systems. The Certified Material Test Reports were compared with requirements of the ASME Boiler and Pressure Vessel Code,Section III, Division I. The review compared the Certified Material Test Reports with the chemical composition and mechanical property require-ments of the applicable specifications. Different size pipelines, material types, and pipe spools were selected from Units 1 and 2 that were part of the ASME piping weld inspection review in Subtask D1.
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One Observation resulted from this subtask. The Observation dealt with an inspection of a weld wire Certified Material Test Report which showed a manganese content out of the range allowed by 0.28%. PSI will generate a Nonconformance Report to record the deviation. An evaluation by a TPT metallurgist shows that an additional 0.28% manganese will not adversely affect the structural integrity of the affected welded
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Based on the review performed in Subtask El, the selected Certified
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Material Test Reports were found to be satisfactory.
4.5.2. Concrete Test and Inspection Review, Subtask E2 This subtask reviewed testing and inspection records associated with construction of five safety-related concrete structures for compliance with f code and construction specification requirements.
Records reviewed included (1) calibration of the testing machine, (2)
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certification of batch plant and truck mixers, (3) initial qualification tests of portland cement and aggregate, (4) concrete mix design and com-pressive strength test results, (5) physical and chemical properties of cement, aggregate, reinforcing steel, and bearing plates, (6) cadweld inspection, testing, and welder qualification, (7) preplacement inspection of reinforcing steel, tendon ducts, and other embedments, (8) production, f delivery, placement, and curing of concrete, and (9) diaposition of Noncon-formance Reports.
The test and inspection records were selected to provide a compre-hensive review of inspections and tests associated with construction of safety-related concrete structures at Marble Hill and to be compatible with areas covered in Subtask D2, " Concrete Inspettion."
s During this review, more than 200 procedures and design documents were f examined and over 550 checks were made of these documents.
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One Observation resulted from this subtask. The Observation was con-cerned with an improperly filed petrographic examination test rcport
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required for the fine aggregate used in construction of safety-related concrete structures. Subsequene investigations revealed that the petro-graphic examination had been conducted on the fine aggregate used in construction, but was erroneously reported to have been obtained from s another company in the test report. While the documentation was filed incorrectly, the fine aggregate used in construction was properly tested; therefore, no safety hazard exists. )
Based on the review performed in Subtask E2, the selected concrete
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testing and inspection records were found to comply with code and construc-tion specification requirements.
4.5.3. Welder Qualification Records Review, Subtssk E3 This suhtask was structured to review welder qualification records for ASME piping welds for compliance with code requirements. )
Welder qualification records were reviewed for 11 welders (eight from Cherne and three from ITT Grinnell) who welded the joints selected in the radiographic review performed in Subtask D1. The records for the welders selected were reviewed for compliance with the ASME Code and Marble Hill specification requirements.
During this review, more than 30 procedures and documents were examined, and over 150 individual checks ware made of those documents.
No Observation or Finding resulted from this subtask.
Based on the review performed in Suhtask E3, the selected welder qual-ification records meet the requirements of the applicable sections of the ASME Code.
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4.5.4. Safety-Related Equipment Maintenance and Storage Review, Subtask E4 This subtask reviewed maintenance and storage procedures for safety-related equipment for compliance with requirements.
Applicable PSI procedures that describe the safety-related equipment maintenance and storage requirements were obtained. These procedures were reviewed to verify that the storage and maintenance program for safety-related equipment complied with the requirements of ANSI N45.2, " Quality
( Assurance Program Requirements for Nuclear Power Plants," Section 14, and ANSI N45.2.2, " Packing, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants - During the Construction Phase."
Ten components were selected from Task C to verify compliance with procedures. Five were in storage and five in place in the plant. The requirements in the Storage and Maintenance Instruction were compared to the storage and maintenance records for each component. In addition, each of the 10 components was physically inspected and its storage and mainte-(
nance status verified.
During this review, more than 30 procedures and documents were examined, and over 150 checks were made of these documents.
No Observation or Finding resulted from this subtask.
Based on the review in Subtask E4, the applicable PSI storage and maintenance procedures are determined to be adequate and to meet the f
requirements of ANSI N45.2, Section 14, and ANSI N45.2.2. The review of the storage and maintenance records and inspection of 10 components indi-cated that the components are stored and maintained in accordance with procedures.
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4.5.5. Overall conclusions, Task E 1:
Based on the review performed in Task E, construction documents selected (ASME piping material certification records, concrete test and inspection records, welder qualification records, and safety-related equipment maintenance and storage records) are judged to comply with the requirements of applicable procedures and specifications.
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- 5. OVERALL
SUMMARY
AND CONCLUSIONS TPT conducted an independent review of the QA organization and f construction of Marble Hill Nuclear Generating Station. The review was organized into several tasks. Task A evaluated the adequacy of the PSI QA organization and the effectiveness of management policies in promoting quality consciousness in the construction of Marble Hill. The major program effort evaluated the adequacy of the construction process in converting the engineering design into the constructed hardware. Task B reviewed the construction design control system and its implementation. Tasks C and D
( verified the physical installation of selected portions of safety-related mechanical systems and structures. Task E reviewed selected construction f documents.
5.1.
SUMMARY
OF OBSERVATIONS AND FINDINGS
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This program used Potential Finding Reports to document and resolve questions raised during the review process. This mechanism was formalized to ensure that no pressure could be applied which could sway the reviewer's technical judgment, allowing the reviewer to raise any potential concern.
Potential Finding Reports were reviewed to ensure that questions raised were f accurately communicated and that pertinent information had not been over-looked by the reviewer. Still, some Potential Finding Reports were ini-tiated because reviewers lacked information or had an inadequate under-(
standing of the process or approach used by PSI, Sargent & Lundy Engineers, Westinghouse, Cherne, or Newberg in the area of concern. Thus, 8 out of the 19 Potential Finding Reports were satisfactorily answered during the process and were declared Invalid.
Of the 11 valid Potential Finding Reports, nine were Observations, and f two were Findings. The nine Observations were distributed between Tasks B, 21 I - - - - - -
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C, and E (1, 6, and 2, respectively). The two Findings were associated with Tasks A and D.
The 11 Observations and Findings fall into four types of de.viations:
(')1 inadequate procedure, (2) procedure not followed, (3) installation not to engineering documents, and (4) improper documentation.
Six Observations were of type 3 (installation not to engineering docu-ments). In all cases, the ivact of the difference between the installed
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condition and the design was accommodated within design margins. In one case, engineering drawings had been changed, but the installation had not yet reflected the changes, because the purchase order had not been processed. .
One Observation was of type 1 (inadequate procedure), concerning a vagueness in PSI project procedures regarding the delegation of certain ]
design review functions. Clarification of the procedure will correct this deviation.
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Two Observations were of type 4 (improper documentation). In both
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cases, either an engineering document or report had not been updated to reflect an approved or acceptable condition in the field.
The two Findings resulting from this review are of type 2 (procedure not followed). One Finding questioned the acceptance of a weld inspection radiograph containing a double image. If the x-ray source or the film is moved during exposure, geometric imperfections occur in the radiograph )
which could result in a loss of flaw detection sensitivity in the weld area under inspection. Industry practice is to reject all double-image radi-ographs and reradiograph the weld to eliminate the possibility of obscuring flaws in the weld.
The second Finding addressed concerns regarding PSI management audits of the QA program. Review of management audit reports over the last three 1
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f The following section discusses Corrective Action Plans prepared by PSI addressing the concerns identified in the two Findings.
5.2.
SUMMARY
OF CORRECTIVE ACTION PLANS PSI prepared a Corrective Action Plan for each of the two Findings resulting from this construction review. These Corrective Action Plans describe the planned approach to correct deviations identified in the Find-ings. TPT reviewed the Corrective Action Plans to ensure that the devia-f tions were properly understood, that the implemented Corrective Action Plan would remove any concern identified in the Finding, and that it addressed
( possible generically similar deviations.
The Corrective Action Plan submitted by PSI for the Finding concerning weld inspection radiographs will require the affected weld to be reradio-graphed. Recurrence will be prevented by revising the radiograph inspec-tion procedure to make double-image radiographs unacceptable, training the inspectors accordingly, and performing a reexamination of existing radio-f graphs to determine if any other double images exist using a statistically rigorous sampling plan.
The Corrective Action Plan addressing the concerns in the Finding on I management audits of the QA program requires a change (which has been effected) in the Project Management Procedures to ensure that a more sub-stantive statement regarding QA program effectiveness is made and that future audits check compliance of the QA program with codes, standards, and Regulatory Cuides.
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Both Corrective Action Plans demonstrated that the deviations in the Findings were indeed properly understood, and when implemented, the planned
- actio'n, taken in concert with the rest of the program, would rencve the concerns that the Findings may have raised.
In summary, both Findings will be satisfactorily closed out upon implementation of the Correc.cive Accion Plans. )
~5.3. CONCLUSIONS
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This program for an independent construction review of Marble Hill Nuclear Generating Station covered a broad range of activities of PSI, the managing /oparatit.g agent and construction manager, and its major civil /
structural and mechanical contractors. The various aspects of quality J assurance.and construction process reviewed were representative of activ-ities since resumption of safty-related work at Marble Hill in 1980. At )
the time of the review, construction was approximately 50% complete on Unit 1, and 25% complete on Unit 2. The conclusions on status of the QA organi-
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zation, the attitude of PSI management toward quality, and the construction change control system encompass the entire Marble Hill project, while the conclusions on the construction of hardware are specific to the type of hardware actually verified.
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Other contractor activities were not reviewed (e.g., electrical installation by Commonwealth-Lord, Joint Venture) due to the very early stage of construction. ]
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L The construction review of Marble Hill from various perspectives pro-vides a basis for the following conclusions:
- 1. The status of the PSI QA organization is considered to be at a level consistent with that required for an effective surveillance of QA activities at Harble Hill. PSI management policies affect-( ing quality, augmented by extensive involvement and interest by management in QA activities, have a positive influence in ensur-ing quality in the construction of Marble Hill.
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- 2. The PSI system for controlling design changes during construction is adequate, and the procedures were rigorously implemented in the construction of the selected mechanical systems and struc-tures reviewed.
( 3. Construction of the selected portions of safety-related mechan-ical systems and structtires conforms to engineering requirements, bac-d on on-site physical verification of hardware, verification
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by tests and inspections, and review of construction documents.
Overall, the project segments reviewed by TPT are indicative of a project with good management attitude and policies toward quality and an adequate QA organization, resulting in adequate construction at Marble Hill Nuclear Generating Station.
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L GA-C17258 L
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( INDEPENDENT CONSTRUCTION REVIEW OF MARBLE HILL NUCLEAR GENERATING STATION UNITS 1 AND 2 l
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[ VOLUME 2 PROGRAM RESULTS
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Prepared for
! Public Service indiana l
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! SEPTEMBER 1983 I
Jd E*cY$way A (>rs on of GA Technologies Inc.
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