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l SCOPE COMPARISON l
I Comodity Unit No. 1 Unit No. 2 Change St. Lucie St. Lucie Percent Concrete (CY) 116,320 141,300
'2L Formwork (SF) 1,258,000 1,676,020 33 l
Reinforcing Steel (lb) 28,127,410 28,135,429 l
,F,mbedded,, parts (lbj*
2,425,800 3,983,017 64 u
Main Steel (Tn) 2,105 2,993 42 l
1 Miscellaneous Steel (Tn) 453 548 21 Conduit (LF) 140,000 419,400 200 Duct (LF) 180,000 490,900 173 Cable Tray (LF) 40,000 41,700 4
PowerCable(LF) 540,000 565,000 5
ControlCable(LF) 3,300,000 3,643,000 10 Ground Cable (LF) 150,000 193,000 29 Piping 2" and Under (LF) 177,000 216,800 22 Piping 2\\" and Above (LF) 79,400 80,300 1
Valves, for piping, 2 " and Above (Ea) 1,000 1,300 30 j
Welds, for piping, L
2 " and Above (Ed) 5,700 9,000 58
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L FPL Witness:
J. W. Williams, Jr.
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Exhibit No.
Document No. 1 L
Page 1 of ITJin'uary 31,1983) i FotA-M -2h3
d 1
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ST. LUCIE UNIT No. 2 CllRONOLOGY OF LICENSING PROBLEMS AND RESULTING CONSTRUCTION DELAYS Elapsed Time l
May 14, 1973 0 mo.
Application formally filed with the Atomio I
Energy Commission (AEC) to construct and operate St.
Lucie Unit No. 2 l
g July 1, 1973 2 mo.
Florida Legislature enacted the Florida APower t
Plant Siting Act (F.S.
403.501) to be effective October 1, 1973.
I September 4,1973 4 mo.
Complete Application docke ted after Environmental Report is accepted by AFi..
January 23, 1974 8 mo.
Pursuant to the Sta te of Florida's Electric Power Plant Siting Act, an application for Sta te Site Certification was filed with the Department of Pollution Control (DPC).
July 24, 1974 14 mo.
Pollution Control Doard adopted favorable IL findings and recommended Order of Hearing officer on above matters.
p October 16, 1974 17 mo.
Environmental and Site suitability hearing L
begins before Atomio Safe ty and Licensing Board ( ASLD).
February 28, 1975 21 mo.
Partial Initial Decision on environmental and site suitability matters issued by the Nuclear Regulatory Commission (NRC) successor agency to the AEC, ASLD.
The order directed the NRC S ta ff to issue a Limited Work Authorization (LWA), allowing certain work to be undertaken pending receipt of a full construction permit (CP).
March 17, 1975 22 mo.
The LWA was issued by the NRC staff, but could not to used due to delay in receiving certification of the site from the State of Florida.
An application for Sta te Sito Certifloation had been filed on January 23,
- 1974, and although sta te law mandated a
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maximum 14 month time period for certification
)
duaision, it was not granted until May 18, 1976.
(See Kny 13, 1975 through May 18, 1976.)
FPL Witnoss:
J. W. W1111ama, Jr.
Exhibit No.
Document No. 2 Page 1 of 3 (January 31, 1983)
a-l Elapsed Time May 13, 1975 24 mo.
Order of State Hearing Officer ruling that issues of radiological health and
- safety, j
also considered by the NRC in the construction permit proceeding and previously raised by other parties (DPC, FDER, and others), were f
not relevant to the proceedings under the doctrine of pre-emption, Northern States Power vs. Minnesota l
June 16, to 25 mo.
State site Certification hearing.
July 16, 1975 Radiological health and safety issues were Ls.f.. tMe n. s. tN./ pp*e' lexcluded in acco da order.
J g., i* m r a, m, nw N e f. se I
IntOv9n7r's,Dil'e* a a
or Partial Initial July 3, 1975 26 mo.
Decision to the NRC's Atomic Safety and Licensing Appeal Board (ASLAD) after two extensions were granted.
W October 8, 1975 29 mo.
State Hearing Office filed Findings of Fact, Conclusions of Law and Recommended Order.
December 16, 1975 31 mo.
Governor and Cabinet deny State Site Certification Application.
Remanded to Hearing Examiner for additional hearings on radiological health and safety.
February 23-25, 1976 33 mo.
State Site Certification hearing considering radiological health and safety matters.
April 8, 1976 35 mo.
State Hearing Officer's Supplemental Findings of Fact, Conclusions of Law, and Recommended Order.
Hay 18, 1976 36 mo.
State Site Certification granted by Governor and Cabinet.
June 4, 1976 37 mo.
Limited construction at St. Lucie begins in accordance with the LWA.
June 29, 1976 NRC Appeal (ASLAD)
Doard issues Order remanding alternative sites contention back to Licensing Doard for further hearings to allow Intervenors to cross-examine NRC Staff regarding their 1974 analysis of the issue.
LWA allowed to remain in effect with one member dissenting.
FPL Witness:
J. W. Williams, Jr.
Exhibit No.
Document No. 2 Page 2 of 3 (January 31, 1983)
7 l
1 Elapsed Time July 28, 1976 38 mo.
Intervenors file motion with NRC Atomio Safety and Licensing Board ( ASLB) to reopen "Need for Power" contention.
August 2,1976 39 mo.
Inte rvenors file petition for review of the Partial Initial Decision (PID) with the U.S.
Court of Appeals for the Washington, D.C.
]
Circuit.
E August 13, 1976 39 mo.
In tervenors file Motion for Summary neversal of the PID and other injunctive relief.
q October 21, 1976 41 mo.
U.S.
Court of Appeals denies Intervenors motion for summary reversal of the Partial Initial Decision, but decides to stay the LWA.
By subsequent o rder, FPL was allowed until November 8,
1976, to stop all construction activity in an orderly manner.
November 8, 1976 42 mo.
FPL oenses all construction activity on St.
Lucie Unit No. 2 pursuant to Court of Appeals order.
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December, 1976 43 mo.
Seven days of hearings before the ASLB on alternate sites for St. Lucie 2 and Need for Power.
April 19, 1977 47 mo.
Initial Decision by AGLD issued authorizing Construction Permit (CP).
l April - Hay 1977 Various Ittions for Stay of the effectiveness of the CP were filed by Intervenors before NRC and Court of Appeais.
FPL responded to Hotions with supporting affidavit depicting costs of stay. Motions were denied.
Hay 2, 1977 48 mo.
CP issued by NRC.
Hay 12, 1977 Court of Appeals issued Order dissolving October 21, 1916 stay of construction.
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June 1, 1977 49 mo.
FPL resumes construction of St. Luote Unit No.
2.
i FPL Witnessi J. W. Williams, Jr.
Exhibit No.
Document No. 2 Page 3 of 3 (January 31, 1983) 9
I REGULATOHY IMPACT ON ST. LUCIE UNIT NO. 2 9
i Since October 1972, over 1,000 formal NRC requirements have been issued to 2
nuclear plant licensees.
These requirements include Regulatory Guides, l
3 Standard Review Plans, Bulletins, Circulars, Information N c.tices, NUREG's, E
4 the Code of Federal Regulations (10CFR) and NRC Generio Letters.
The 5
requirements provide for new design criteria requirements, analytical
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6 evaluations, inspections, etc.
The attached chart graphically depicts an 7
overview of the cumulative number of regulatory requirements by year during 3
the St.
Lucie 2 design period.
It should be noted that other NRC 9
requirements transmitted vis NRC correspondence to FPL, NRC questions during i
10 the Safety Analysis
- Reviews, and the verbal requests for additional l
11 information are not included in the above.
12 I
[3 Although the impact of some of the documents discussed above may be small on 14 an individual basis, the summation of their impact is major, and the l
13 resultant cost increases have been significant in terms of direct plant costs
'6 and indirectly due to increased complexity in construction.
[3 Hany significant regulatory requirements imposed through the years have 19 resulted from events beyond FPL's control (Drown's Ferry, Three Mile Island).
'l 20 As an example, shown below is a chronology of the constant reevaluations of 2[
criteria for fire protection systems and the resultant plant impacts.
The 22 cumulative impact of these reevaluations is frequently called the " ratchet" 23 effect.
I FPL Witness:
J. W. Williams, Jr.
Exhibit No..
Document No. 3 Page 1 of 4 (January 31, 1983)
Fire Protection Requirements 6
Issued Date Description of Plant Impact SRP 9.5.1 5/76 Summary - A comprehensive fire hazard analysis l
APCS 9.5.1 5/76 was initiated which identified potential fire i
App A 7/76 hazards in all
- areas, postulates credible l
R0 1.120 1977 fires and evaluates the effects of these t i(
R0 1.75 1/78 postulated fires on the operability of systems required to safely shutdown the plant and control the release of radioactivity.
As a result of the complete fire haza rds analysis, equipment was required, by tne NRC, to be added.
S( 'e examples are ftre seals, hose s ta tions, fire extinguishers, smoke detecteas and emergency lighting.
l 10CFR50 10/78 Appendix R, to 10CFR50, required the applicant l
App R to assume a fire has been established. The applicant must now prove that a fire that is contained in a qualified 3hr fire barrier will not damage redundant trains. As a result of this idealogy the following was added:
- 1) Stairway Enclosures
- 2) Raise Charging Pump Oubiolo Walls
- 3) Cable Loft Barrier Tray Riser Enclosure
- 4) A DC Equipment Enclosare
- 5) Swgr/ Cable Spread Room Wall
- 6) Pressurizer Ifeater Switchgour Room
- 7) RCD Electrical Penetration Darrier
- 8) Cable Tray Dottoms
- 9) llatch Covers
- 10) Diesel Generator Duilding and Reactor Auxiliary Building Sprinkler System
- 11) Cable Heroute/ Wrap
J. W. Williams, Jr.
Exhibit No.__.
Document No. 3 Page 2 of 4 (January 31, 1983) 1
I J
l Other examples of NRC " ratchets" that have increased plant cost are:
l l
- 1) Containment Sump Redesign
- 2) Lew Temperature Overpressure Protection (LTOP)
. l
- 3) Three Mile Island (TMI) Helated Items i
- 4) As-Built Piping Review
- 5) Additional Startup Transformer Switchyard Modifications
- 6) Physical Independence of Electrical Systems
- 7) Seismic Design Criteria / Qualification
- 8) Missile Protection
- 9) Main Stream Line Break Analyses
- 10) Pipe Rupture / Jet Impirgument./IEALA
- 11) Equipment Qualification
- 12) Quality Assurance E
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FPL Witnnsst J. W. Williams, Jr.
Exhibit No.___
Document No. 3 Page 3 of 4 (January 31, 1983) i 6
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- Ii l3 FLORIDA POWER AND LIGHT COMPANY
'g ST. LUCIE UNIT 2 I
REGULATORY IMPACT TOTAL REGULATORY REQUIREMENTS ISSUED VS TIME 9
000 940 900 TOTAL NUMBER OF 800 MAJOR NRC REQUIREMENTS-1018 700 TOTAL REGULATORY 641 R
REQUREMENTS ISSUED 600
,R 500 N
464 l
400 300 2y 200 1
10 0
_74 40 1
l972
'73
'74
'75
'76
'77
'70
'79
'80
'81
'82 Fl't. Witnesa:
J.W. WL11L.ims, Jr.
Exhlbtt No. _ Document No. )
l' age 4 of' 4 (Janu.try 31, 1961)
l
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R MANAGEENT C00fTHOLS OII PSL-2 FPL employed a strong Project Management approach in order to achieve its 2
cost, schedule and quality performance objectives during the construction of 3
St. Lucie Unit No. 2.
All of the project functions were carried out by a 4
project organization team assigned to the Project General Manager (PGM).
The 5
PGM reports to a Director of Projects who reports to the Vice President for l
6 Engineering, Projects and Construction.
Figure 1 shows the Project Organization 7
Chart and the major project team members.
The utilization of a Project Control 3
Supervisor helped to ensure integration of all cost and schedule information to l
9 the PGM for use in timely deoision-making.
FPL personnel were assigned to all 10 major project control activities.
They included Engineering, Construction, 11 Purchasing, Contracts, Licensing, Startup, Quality Control, Scourity, Quality 12 Assurance and Cost and Schedule.
l 13 14 l
FPL's commitment to strong Projoot Management and utility control was most 15 evident at the St. Lucio Site.
FPL assumed full responsibility for all 16 construction activities utilizing an integra ted site organization comprised of 17 botn utility and contractor personnel with a single owner site manager, as shown 13 in Figure 2.
FPL personnel were assigned to all of the lead support services E
19 positions while Ebasco personnel directed the Field Enginooring and construction 20 activities.
The combined use of an integrated organization and integrated I
4, FPL Witness:
J. W. Williams, Jr.
Exhibit No.
Document No. 4 Page 1 of 7 (January 31, 19tl3) e
r 1
project plan enabled FPL to be more effective in eliciting the best possible 2
performance from the site contractors.
FPL personnel received and verified all 3
construction activities, invoices, payroll costs and contract scope changes.
4 Contract administrators were assigned to a 1 major site contractors.
5 l
6 q
The Project Management controls on St. Lucie Unit No. 2 included numerous 7
systems and reports designed to provide information on virtually every project 11 8
activity that could impact meeting budget and schedule commitments made to FPL 9
upper management.
The primary management baseline control tools included the 10 project integrated schedule and the current approved budget.
Monthly cost and ll schedule status was reported to the utility management throughout the project 12 lifetime in the FPL Project Management Reporting System (PMRS).
The mas ter l
13 schedule on St. Luole Unit No. 2 was adopted in March 1977 and maintained 14 throughout the job through the use of a detailed Critical Path Method (CPM) i 1
15 network which contained over 30,000 project activities.
Project monthly reports 16 were issued by Ebasco on the engineering services and by the site on the l
17 construction and startup activities.
18 l
l 19 Figure 3 lists the aujor site control tools that were used to monitor l
20 construction productivity and performance.
These tools were augmented by daily 21 meetings at the site to ensure the timely identification and resolution of l
22 problems. The effectiveness of these tools can be measured by the exceptional 23 performance history of the St. Luote Unit No. 2 project, which exceeded all 24 other recent nuclear plants by a considerable margin.
FPL Witness:
J. W. Williams, Jr.
Exhibit No.
Document No. 4 Page 2 of 7 (January 31, 1983)
I k
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In addition to those control tools employed by FPL, each of the major 2
contractors had their own project cost and schedule reporting systems used to 3
ensure this performance to the overall project objectives.
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)i FPL Witness:
J. W. Williams, Jr.
Exhibit No.
Document No. 14 Page 3 or 7 (January 31, 1983)
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ST. LUCIE UNIT NO. 2 SITE ORGANIZATION CHART SITE MANAGER CONST RUCTrON ASSISTANT PROJECT CONSTRUCTION SENIOR PROJECT SERVICES SECURITY TEST WANAGER CC CONTROL RESIDENT SUPERINTENDENT OA SUPER VISOR SUPERnNTENDENT ENGINEER SUPERINTENDENT SUPERINT ENDENT SUPERVISOR
-CONTRACTS CONSTRUCTION SU R SOR ENG NE SUPERINTENDf MT ST AF F OF FlCE ADMINISTR A-TION e', ?T T
-PIPING ii _ r=
t ADMIN.
=
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((=5 AREA
,Y STORES 2
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PLANNih3 PORCNASING s.a 6 E AND LABOR SCMoutig R E LATIONS
.- 3 3:
E S UPER VISOR 3,3 8:5zo t-s.
AREA DIRECTORS (4)
FIG U RE 3 M AJO R P R OJECT C O NTR OL TOOLS USED O N ST. LU CIE U NIT N O. 2 l
Control Tool Description j
1.
Project Master Schedule Shows top level Project Milestones and Activities 2
Level II/III Schedule Computerized CPM Network - Construction 3
Startup Schedule Computerized CPM Network - Startup 4.
Schedule Interface System Shows Cost Account to schedule cross-reference 5.
Resource Loaded Schedule Shows levelized quantities and manhours per l
l schedule 6.
Physical Accomplishment Curves Shows area and project quantity and manhour tracking l
7.
Productivity Curves Shows area & project productivity based on actual vs. estimate 8.
Material Tracking System Computerized tracking of all materials on job 9.
Electrical Management System Computerized tracking of all cable, conduit and terminations 10.
Project Quantity and Manhour Production and productivity report for each Report job cost account 11.
Bulk Commodity Curves Shows scheduled vs. actual installation rates t
12.
System Turnover Computerized tracking by plant system 13 SCAT Startup Controlled Accelerated Turnovers allowed for partial system turnover in order to accelerate the startup and testing program.
- 14. Budget and Cash Flow System Systems to explain all cost variances by cost category and project category 15.
Reforecasting Program Semi-annual cost report tied to the definitive cost estimate (1977) i l
FPL Witness:
J. W. Williama, Jr.
I Exhibit No.
Document No. 4 Page 6 of 7 (January 31, 1983)
I
B l
16.
Construction Report Monthly report presenting results of all I
control system indicators Program used to estimate probability of
- 17. Risk Analysis meeting schedule and budget l1 Monthly tracking of scope and cost
- 18. Trend Program evaluation Monthly report to upper management on l
19 PMRS progress, budget and trends for all projects
/
- 20. Management Presentations Formal semi-annual project progress review presentations to upper management i
,k FPL Witness:
J.W. Williams, Jr.
Exhibit No.
Document No. 4 Page 7 of 7 (January 31, 1983)
1' N
I 1
FPL INITIATIVES IN MANAGEMENT OF ST. LUCIE UNIT NO. 2 l
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1 The entire history of the St. Lucie Unit No. 2 Project has been one of l
ll 2
implementing management action directed towa rd overcoming obstacles and t
3 instilling a sense of urgency in the project team.
Literally hundreds of I'
4 specific actions have been taken by FPL and its contractors to improve 5
productivity, recover schedule time and correct quality concerns.
These efforts
)
6 can best be illustrated by identifying the following five major initiatives taken 7
by FPL which have had the greatest impact on schedule performance.
3 9
1)
The decision to complete engineering and material purchasing during the 10 Limited Work Authorization (LWA) shutdown period.
This reduced the number 11 and severty of schedule impacts which could have resulted from incomplete 12 engineering and material delays.
13 14 2)
The integra tion under FPL management of the FPL/Ebasco/ Subcontractor site 15 organization and operating procedures.
This approach aided in the timely 16 identification and resolution of project problems and concentrated overall 17 responsibility under FPL personnel.
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18 y
19 3)
The use of a single integrated Project plan, developed early in the job, 20 with total management commitment to meeting the schedule for all major 21 milestones. The benefits of a total commitment to meet all major milestones FPL Witneas:
J. W. Williams, Jr.
Exhibit No.
Document No. 5 Page 1 of 2 (January 31, 1983)
R I
was evident in actions taken to overcome impacts on construction of having 2
an operating unit next to it, labor disputes, ilurricane David damage, 3
potential delays in setting the reactor vessel and steam generators, N
contractor changes in the piping area.
It was also evident in FPL's efforts 0
to expedite delivery of orders from many of the equipment suppliers.
6 7
4)
Early initiation of FPL's system startup program which included development
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8 of start-up procedures, refined start-up schedules, identifications of
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I 9
start-up system turnover of partially completed systems to operations 10 personnel and prioritization or construction activities to support system 11 completion.
12 13 5)
Lastly, FPL demonstrated considerable initiative in expediting the NRC's 6Y % tha# L 14 review of our application for an operating license on PSL-2.
This effort 15 included submittal of a letter from the entire Florida State Delegation to 16 the NRC Chairman expressing the need for timely issuance of an operating l
17 license, and establishment of a temporary office near the NRC to facilitate 18 a closer working relationship.
19
(
20 Each of the above efforts was undertaken by FPL in order to construct and 21 start up St. Lucie Unit No. 2 in the shortest possible schedule, thereby directly 22 reducing costs.
I FPL Witness:
J. W. Williams, Jr.
Exhibit No.
Document No. S Page 2 of 2 (Januan 31, 1983)
1 i
CONSTRUCTION TECilNIQUES I
1 The optimization of the construction effort was the result, to a large degree, 2
of the early planning and innovative thinking that went into the formulation s
3 of the overall construction plan and schedule for this project.
The following l
J 4
are some examples of this:
6 1.
Reactor Auxiliary Building " Stair Stepping" Concept 7
3 One of the ideas that went into the initial plan and schedule was the 9
" stair stepping" concept for the construction of the reactor auxiliary i
10 building.
In this plan, the building was constructed with emphasis 11 placed on early completion of the west end of the building.
The 12 benefit of this approach was that early completion of the west end of 13 the structure would provide an early start on the installation of the 14 more critical types of equipment in the building, such as the control 15 room and the reactor auxiliary control boards, the cable vault area, 16 and NSSS auxiliary equipment.
FPL Witness:
J. W. Williams, Jr.
Exhibit No.
Document No. 6 Page 1 of 6 (January 31,1983) 1
I I!
1 2.
Slipforming on Reactor Containment Building 2
f 3
Another innovative construction approach at St. Lucie Unit No. 2 was 4
the "slipforming" of the concrete containment shield wall for the 3
reactor containment building, in lieu of the traditional " step-form" 6
method.
"Slipforming" is a continuous concrete casting process which 7
involves the steady movement of a single set of forms up a concrete t.
3 structure until the entire structure is complete.
The shield wall is a 9
three foot thick concrete cylinder which is approximately 190 feet high to with an inside radius of 7
4 feet.
It is supported 11 by a reinforced concrete ring wall (9 feet thick and 4 feet high) 12 which, in turn, rests on the reinforced concrete base mat.
The shield 13 wall contains more than 1,000 tons of reinforcing steel with another 23
(
j 14 tons of embedded materials such as electrical conduits, grounding 15 cables and anchor bolts.
16 17 Shield wall placement through slipforming of 10,000 cubic yards of 13 concrete averaged vertical 11 feet per day, and the operation took g
19 place without interruption in only 16 days in November, 1977.
l[
20 Manpower for slipforming averaged 398 craf t workers, and the crafts 21 worked three shifts a day, seven days a week until completion.
If Immediately after completion of slipforming, construction on the steel 22 23 containment liner was able to start inside the shield wall.
24 Constructing the shield wall using the traditional " step-form" approach 25 would have taken 98 days and utilized more than double the manhours.
FPL Witness:
J. W. Williams, Jr.
Exhibit No.
Document No. 6 Page 2 of 6 (January 31, 1983) f
h 1
3.
Nuclear Steam Supply System (NSSS) Installation ji 3
An important benchmark in the NRC's assessment of nuclear plant 4
construction is the installation of the nuclear steam supply system I
l 5
major equipment, i.e.,
the reactor vessel, steam generators and 6
pressurizer, We were able to reach this milestone on a very short j
q 7
schedule by adopting two innovative approaches, j
s 9
The first of these innovations was the design of the steel containment 10 liner to utilize a " tops-off" approach, together with the early 1
J L1 planning necessary to allow the use of that approach.
Basically, this 12 method allowed the steel walls of the containment to be heat treated 13 when it was complete while at the same time leaving the top of the 14 structure open.
As a result of using the " tops-off" approach, 15 interior concrete work started months earlier than otherwise would have 16 been possible and ensured that support structures were ready for NSSS 17 installation.
18 l
19 Secondly, a system of temporary bracing was used to support the polar J
20 crane while the reactor vessel was being placed inside the containment 21 building.
By using this temporary bracing it was possible to place the c
22 vessel without waiting until the interior concrete was brought up to
]
FPL Witness:
J. W. Williams, Jr.
h Exhibit No.
Document No. 6 Page 3 of 6 (January 31, 1983)
I I
i i
the operating level, as would usually be the case.
Thus saved j
2 considerable schedule time and enabled construction forces to meet the 3
target date of June 1980 for setting the reactor vessel.
4 5
5 4.
Jobsite Labor Relations 6
1 7
Specific labor relations programs instituted include the following:
g 8
9 a) Quarterly labor-management meetings designed to open lines of f
10 consnunication in a non-adversary atmosphere and provide a means of 11 informing the building trades as a group on upcoming project
}l 12 manpower needs.
It also provided a means of resolving grievances 13 and jurisdictional disputes and generally improving the labor-14 management climate.
15 16 b) Special training was given electrical foremen.
This was 17 supervisory-type
- training, and included a
formal course 18 concentrating on how improved planning and work process analysis by 19 foremen can lead to major productivity gains.
Electricians also 20 received training in the methods used at St.
Lucie Unit No. 2 in 21 cable spooling and cable terminations; this has resulted in 22 reasonably smooth operation in these arers.
In addition to the 23 above, welding training was made available to all appropriate 24 crafts.
FPl. Witness:
J. W. Williams, Jr.
Exhibit No.
Document No. 6 Page 4 of 6 (January 31,1883) s 7
l I
c) An attitude survey was taken of craf t personnel concerning their 2
attitudes and perceptions about the project.
The results were then l
3 used to make corrections, where required.
This led to an 4
improvement in morale as well as productivity gains.
Concurrently, 5
seminars were held for superintendents and general foremen on 6'
" productivity improvement" aimed at assuring that all components 1
7 necessary for performing work had been arranged and in place; the l
8 seminars also discussed a method for planning and scheduling work 9
which maximizes production and eliminates non-productive time.
Il 10 Following the seminars there was a measurable gain in productivity 11 in specific areas of the project.
12 l,
13 d) Failures of comunication between management and labor are of ten a 14 major area of difficulty in the relations between these two groups 15 in construction projects.
To prevent this problem from arising at Of 16 St. Lucie, FPL established the St. Lucie Communicatiew as a site I~
17 newsletter designed to provide up-to-date, accurate information 18 about developments at the project. The Communicator has developed 19 into one of the most important means of changing and improving IY 20 attitudes that has been used on site to date.
21
/
22 The items outlined above, in conjunction with firm but fair application 23 of labor agreement provisions and project work rules have steadily l
24 decreased work stoppages and generally improve labor relations.
FPL Witness:
J. W. Williams, Jr.
Exhibit No.
Document No. 6 Page 5 of 6 (January 31,1983)
I N
1 Enlightened and prudent management techniques recognize that management q
2 cannot " drive" a work force--it must lead and motivate the work force 3
'k to reach achievable goals.
We believe that the St. Lucie Unit No. 2 management team has effectively employed this leadership philosophy in the labor relations at the project.
l 6
7 5.
Safety 8
9 Jobsite accidents have a costly impact on the $300 billion-a-year 10 United States construction industry.
Work-related injuries and 11 illnesses, including f atalities, occur in construction at a rate that 12 is 54% higher than the rate for all industries, making it one of the 13 most hazardous occupations.
14 15 FPL has tried aggressively to improve on this record at St. Lucie Unit 16 No. 2.
17 18 The safety program in effect at the St. Lucie Unit No. 2 site has 19 resulted in receipt of two safety awards for 1982 for working over one 20 million manhours without a lost time accident.
In 1981, the site 21 0.S.H.A.
index was 98.29 percent better than the Bureau of Labor 22 Statistics average.
This performance has resulted in significant 23 direct and indirect savings to FPL by reducing insurance and accident 24
- claims, and by avoiding the loss of productivity and schedule 25 disruptions which result from accidents.
FPL Witness:
J. W. Williams, Jr.
Exhibit No.
Document No. 6 Page 6 of 6 (January 31,1983)
s i
FLORIDA POWER & LIGHT COMPA NY i
r UNITel VS. UNIT #2 SCHEDULE MILESTONES 1977 1978 1979 1980 19 81 1982 1983 PSL 2 bk b
93 36 MONTHS 33 MONTHS z
h 1970 19 71 1972 1973 1974 1975 1976 P SL-I AM MA A
AA AAA A DEC 1976 39 MONTHS 30 MONTHS
[
=
b START RCB BASE MAT CONC.
d COMMENCE COLD HYDRO b START INTAME STRUCTURE BASE MAT CONC.
d START NOT OPS e l b START RAB BASE MAT CONCRETE b COMMENCE CORE LOAD k COMP ERECT & TEST 5 TEEL CU TO EL I47 b START CRITERIA PERFORMANCE TESTS k START RCB INTERNAL CONCRETE d COMMENCE POWER ESCALATION k START FHB BASE MAT CONCRETE d COMMERCIAL OPERATION I
b START SETTING N555 MAJOR EQUIPMENT FPL Uitness: J.W. 'Vi l l hlrts, J r.
Exhibit No.
Doctront No. 9 Page 1 of 1 (January 31, 1983)
L
ST. LUCIE UNIT NO 2 SCHEDULE COMPARISON I
(SOURCE NRC YELLOW BOOK)
FUEL UNIT LOAD 2
MCGulRE I 1/ 81 ti7
=p67 IU3 LASALLEI 4/82 10 3
i GRAND OULF I S/82 92 a
~ ' ' ' ' '
a 96 l
SUSQUEHANNA 8/82 10 0 q,
=100 l
'E
' n' 112 SUMMER 1 8/82 11 2 b
k 12 4 SHOREHAMi 2/83 12 4
=
1 96 SAN ONOFRE 2 2/82 96
'=
' ~ > ' ' '
I 10 2 WATERFORD3 S/83 10 2
=
I ST. LUCIE 2 3/83 71 71,
j 10 0 BYRON I 8/83 10 0 l
16 9 ENRICO FERMI 2 6/83 L69
' ' ' ' =
i i
i 4.
e
i e
11 10 4 i
COMANCHE PEAKl 6/83 10 4 153 CALLAWAY l 4/84 10 3
,. = 'l24 MIDLAND 2 7/83 12 4 r'
WATTS BAR I 8/83 127
= :127
=l87!
!l PALO VERDE I 8/83 87 7:
I WASH. NUCLEAR 2 W83 13 3 a
13 3i
' =
_a;idsi I
PERRYI II/83 10 9
'. a
>l 99 I SEABROOK l 9/84 99 e e WOLF CREEK I 10/84 93
(
93 ' ! '
l
=
17 3 LIMERICK I 10/ 8 4 17 3
=
=
' = l125l CATAWBA I IO/84 12 5
'l31 l
HARRIS I 12/8 4 131
- =
11 6 ;
BRAIDWOOD I 4/85 11 6
=
I i
l l
72l RIVER BEND I 4/85 72
' ' < =
i i
g 12 8 BELLEFONTEI S/85 12 8 a
7
=
h'
' =!98, !
WASH. NUCLEAR 3 6/85 98
=139 l
MILLSTONE 3 12/8 5 13 9 3
' =l40 l
BEAVER VALLEY 2 12/85 14 0
~
l l
l i
l 29 PLANTS j
j I
i l
i 0 10 20 30 40 50 60 70 SO 90 40 0 ilo 120 130 140 ISO 660 870 17 5 CONSTRUCTION PERIOD MONTHS FPL Witness:
J.W. Williams, Jr.
Exhtbit No.
Document No. 10 Page 1 o f' 1 ( J 1niia ry 31, 1963)
~M February 11, 1983 L-83-70
,IE HQ FILE COPY Mr. James P. O'Reilly Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 f1arietta Street, Suite 3100 Atlanta, GA 30303
Dear fir. O'Reilly:
Re:
RII: WPA St. Lucie Unit No. 2 Docket No. 50-389/82-71 Florida Power and Light Company has reviewed the subject inspection report which identified one violation.
Please find attached our response to this violation.
Very truly yours, Robert E. Uhrig Vice President Advanced Systems and Technology REU/PPC/njb Attachment Fora-84-113 bfI80 mi-t-0406 830318 PDR ADOCK 05000389 a
.t
/.
VIOLATION 10CFR50, Appendix B Criterion V as implemented by Section TQR 5.0 of FP&L Topical Report FPL TQAR-1-76A, requires that activities affecting ouality be prescribed by documented instructions, procedures and drawings and be accomplished in accordance with those instructions, procedures and drawings.
~
Contrary to the above, on December 7,1982, the following examples of failure to comply with instructions, procedures and drawings were identified.
1.
QC inspected and accepted pipe support SI-2407-60A included a mechanical snubber, piece 2.
Bergen Patterson drawing, SI-2407-60A Rev. 6 requires the snubber to be installed perpendicular to the pipe.
Contrary to the above, the snubber was found to be installed at approxi-mately a 78 angle from the pipe.
2.
QC inspected and accepted pipe support SI-2407-67 included a rigid strut, piece 1.
Bergen Patterson drawing SI-2407-67 Rev. 9 requires piece 1 to be attached to a pipe clamp 19" below the centerline of the pipe.
Contrary to the above, piece 1 was found to be attached to the pipe clamp approxi-mately 22" below the pipe centerline.
3.
Bergen Patterson drawing SI-2407-84 Rev. 7 requires the bottom horizontal member, piece 3, of pipe support SI-2407 to be welded to an embedded plate with a 5/16" fillet weld all around piece 3.
Contrary to the above, support SI-2407, which had been OC inspected and accepted, was not welded to the embedded plate on a six inch length across the bottom of piece 3.
This is a severity level IV violation
RESPONSE
1.
Florida Power & Light agrees with the finding regardina pipe support discrepancies.
2.
The discrepancies are attributed to lack of attention to details durina inspection.
3.
The three restraints in question were inspected durino the beginning of the restraint / hanger inspection program.
Pipe support SI 2407-60A was inspected and documented on Inspection Report (.IR) tiH 81-0225, dated 8/1/81; support SI 2407-84 was inspected and documented on IR MH 81-1609, dated 9/9/81.
During the early phase of this program, all inspection reports were reviewed by Office Engineering personnel for ccmpliance with specification requirements. This requirement was included in revision 0 of procedure QI 10.18 and remained in effect until October 14, 1981 when the procedure was revised.
Ns. '
RESPONSE
(cont'd) 3.
(cont'd) i Management recognized the need for further training and indoctrination of the inspectors after they were certified and started field inspections.
Consequently, periodic training classes were held with the inspectors to ensure that they understood site requirements and that common discrip-ancies noted during inspections were discussed to increase their effective-ness. These documented training classes were given on 11/30/81, 12/1/81, 12/2/81, 12/15/81, 1/20/82, 2/3/82, 5/10/82, 6/18/82, and 7/19/82.
We feel that sufficient corrective action has been taken to ensure proper inspections.
In regards to the three specific pipe supports noted by the NRC inspector,
.the discrepancies were documented on non-conformance reports 5758MH, 5760MH and 5759MH.
4.
In addition to the above mentioned training for QC inspectors, all safety related seismic restraints inspected during the early phase (June 22 -
October 14, 1981) of the restraint inspection program were identified for additional inspection (performed during 12/10/82 - 1/17/83) based on sta-tistical sampling in order to establish a degree of confidence in those early inspection reports.
The following attributes were used during this reinspection program:
A.
Are all weld joints welded per drawing requirements?
B.
Are specified dimensions from pipe centerline to clamp pins correct?
C.
Are specified box dimenstions correct?
D.
Are rigid struts or snubbers oriented properly?
E.
Are pA/SA offset differences correct and oriented properly?
The restraint drawings were highlighted by the Mechanical QC Superviser using the attributes as guidelines and then given to inspection personnel for verification. A group of 125 randomly selected restraints, out of a total of 700, were reinspected.
The result of the reinspection showed that restraint MS 4102-6012A was improperly installed for pA/SA require-ment and NCR 6202MH was issued.
Restraint SI 2414-44 was originally in-spected to revision 3 of the cut sheet, but revision 4 added a shim plate which required subsequent re-inspection, however, the re-inspection did not indicate any discrepancy on previously inspected items.
The reinspec-tion effort of the remaining 123 restraints indicate that they were originally properly inspected.
The reinspection of early program inspected hangers indicates to a high degree of probability, that these were inspected properly.
5.
Full compliance is complete.
,e
,e G
r.*
February 17, 1983 L-G3-05 Mr. James P.
O'Reilly 3EQ7E3 COPY Regional Administrator, Regien II U.
S. Nuclear Regulatory Coir.ission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Re:
RII: GAB St. Lucie Unit 2 Docket No. 50-389/82-57 On January 14, 1983 Florida Power & Light Cc=pany provided a final respense tc the violation, " Failure to Correct a Condition Adverse to Quality Prorptly".
Per :elecen with your Mr. G. A. Belisle on February 8,1983, Florida Pcwer &
Light is previding a supplenental response tc the above violatien.
1.
FPL agrees with the Finding.
2.
This audit ite= sid recuire an inordinate length of time from initial identification until closure; however, FPL does not consider this a true viciation of the intent of 10CFR50, Appendix B, Criterien XVI (as per-taining te prenptness), since it is, indeed, an excepticnal case which recuired numercus meetines invciving upper level management at the constructicn site and at the FPL Juno Beach and Miami offices to arrive at a satisfactory solution.
Emphasis must be placed on the word satisfactcry.
Many solutiens were offered which took time to evaluate, but only cne combination of solutions was acceptable to satisfacterily rescive the prchlen.
This was the major reascn why this treblem was held open for so lcnc--the strivinc for a satisfactory sclution.
The intent of ICCFR50, Acpendix 3, Criterion XVI, as pertains to "crengt."
is net te be preret to the extent of settling for partially satisfactory solutiens to conditions adverse to quality.
During the nine menths that this problem was open, continuous pressure was beine applied to chtain a satisfactory solution, and, until final resciutien, continuous surveillance was established to assure that no further instances occurred of a similar nat re which right adversely af fect quality program ecmmitrents.
3.
In crder to properly effect caesure of this FPL audit iter, precedures were chanced te require cuality Assurance review and concurrence cf new Cuality Instructicns or revisions theretc pricr te their issuance.
F8IA.N -29 3 L. *23I 8304tt0407 830405 PDR ADOCK 05000335 m
.' *q.,s
r.
Jares F. C'Feilly D:::<e t I:c. 50-289/S2-57 Face :
4.
Tull :: pliance has been achieved.
'lerv truly yours,
' ". ).
e'.
//.l.s&d'v [ li}
sc(
Fober: E. Uhric
'Jice President Advanced Systems and Technolecy FIU/FJS/JCC/njb a
o e
' s,.
o W
s ?rI,ard March 10, 1983 L-83-132 Mr. James P. O'Reilly Regional Administrator, Region II U.S. I'uclear Regularoty Cormission 101 Marietta Street, suite 3100 Atlanta, Georgia 30303 RE: RII: WPA St. Lucie Unit No. 2 Docket !b. 50-389/82-71 Florida Power & Light, on February 11, 1983 provided a Final Response to the violation " Pipe Support D isc repa nc ie s".
Per telecon with your :tr.
7.
Blaue on February 22, 1983, Florida Fower & Light is providing a supplemental response to the above violation.
On February 17, 1983, subsequent to filing a response to the violation 50-339/82-71-01, FPL was requested per telecon to either reinspect the original sample of 125 hangers for all characteristics or select 50 more hangers from the group in question and inspect them for all characteristics.
FPL elected the later and reported the results to "r.
J.
Blake of Region II on February 22, 1983.
Discrepancies were found, though of a minor nature; therefore, FPL committed to reinspecting the apprcximately 525 hangers remaining from the original 1931 group.
Restraints not accessible will be reviewed for reinspections which have been performed during 1992 and 1993.
All discrepancies noted will be docu: dented per applicable site procedures.
All reinspections will be ecmpleted by March 11, 1983.
Very truly yours,
'hw
(
Robert E. Chrig Vice President Advanced Systers and rachnM g; Fo r A + 493 Nb 83041TO40r 830318 PDR ADOCK 05000389 G
r fuw MAR 181993 TEN lt ILE00FF Florida Power and Light Company ATTN:
Dr. R. E. Uhrig, Vice President Advanced Systems and Technology P. O. Box 14000 Juno Beach, FL 33408 Gentlemen:
SUBJECT:
REPORT N0. 50-389/82-71 Thank you for your letters of February 11 and March 10 1983, informing us of steps you have taken to correct the violation concerning activities under NRC Construction Permit No. CPPR-144 brought to your attention in our letter of January 13, 1983.
We will examine your corrective actions and plans during subsequent inspections.
We appreciate your cooperation with us.
Sincerely, R. C. Lewis, Director Division of Project and Resident Programs cc:
B. J. Escue, Plant Manager N. Weems, Assistant QA Construction Manager bcc: Document Management Branch State of Florida NRC Resident Inspector RII RII -
RII RCLcw(>is flf,-)
.j'.
HCDa,IT y
WPAng:es lake i Herdt nce 3/,c/83
/;1/83 3/ n/83 2/
/83 2/, /83 Sfd 3//'I A
Fo r4 -N -2%
9304r1~0397 830318
( SQ PDR ADOCK 05000389 G
PDR h
4
,o,.... ;.
APR 5 333 Florida Power and Light Company M 7IIac0Pr ATTN:
Dr. R. E. Uhrig, Vice President Advanced Systems and Technology P. O. Box 14000 Juno Beach, FL 33408 Gentlemen:
SUBJECT:
REPORT NOS. 50-335/82-38 and.50-389/82-57 Thank you for your letters of January 14 and February 17, 1983, informing us of steps you have taken to correct the violations concerning activities under NRC Construction Permit No. CPPR-144 brought to your attention in our letter of December 14, 1982.
We will examine your corrective actions and plans during subsequent inspections.
We appreciate your cooperation with us.
Sincerely, R. C. Lewis, Director Division of Project and Resident Programs cc:
C. M. Wethy, Plant Manager N. Weems, Assistant QA Construction Manager B. J. Escue, Plant Manager bec: NRC Resident Inspector Document Management Branch State of Florida RII:
RII RIL RII.,3 RI g,i g t..,
GABelisle CMVpright ARHerdt P JA01shinsi C ewis 9/ /83 3/ /83 4/\\/83 a/i/83 l Q /83 po/g.t4-195 3304TTO~400 830405 PDR ADOCK 05000335 PDR g3y G
J